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Transaction declined or disputed

How to respond when a counterparty declines or disputes a Travel Rule message.

A counterparty may decline or dispute a transaction for compliance or data-quality reasons. This page outlines the typical operational response and the records you should keep.

Use it to define your dispute handling and escalation process.

What you'll learn

  • Why counterparties might decline or dispute transactions
  • What records and evidence should exist
  • How to coordinate follow-up actions across teams

Why declines happen

  • Missing or inconsistent Travel Rule data
  • High-risk beneficiary or originator flags
  • Counterparty policy requiring additional verification

How to respond (offline workflow)

Declined transactions are typically handled outside of real-time settlement:

  1. Notify and contain - Alert compliance and customer support. Pause broadcast if it has not occurred; if the transfer was already broadcast, handle the decline as a post-broadcast exception.
  2. Collect additional information - Request missing data or clarification from the customer.
  3. Document the decision - Record the decline reason and any remediation steps taken.
  4. Decide the next action - Before broadcast, cancel, correct the data, or proceed under a documented exception policy. After broadcast, document the outcome and follow your remediation procedure.

Evidence to retain

  • The decline reason and timestamps
  • Any customer communication or remediation steps
  • Final disposition (cancelled, re-submitted, or approved under exception)

Next steps