Skip to main content

How to Handle and Reject Problematic Trade Requests

Overview​

As a Transfer Agent on the WhiteLabel Community Deals Platform, you'll encounter P2P trade requests that cannot be approved due to compliance issues, regulatory concerns, or other problems. Properly handling and rejecting these problematic requests is crucial for maintaining regulatory compliance and platform integrity. This guide will walk you through the process of identifying non-compliant trades, documenting issues, communicating with investors, and properly rejecting transactions that don't meet requirements.

Prerequisites​

Before rejecting P2P trade requests, you should:

  • Have an active Transfer Agent account on the platform
  • Have completed the initial review of the trade request
  • Be familiar with the compliance requirements for the specific deal
  • Understand the common reasons for trade rejection
  • Have authority to reject transactions for the deal in question

Step-by-Step Instructions​

Step 1: Identify Non-Compliant Trade Requests​

  1. During your review process, watch for these common compliance issues:

    • Incomplete or invalid KYC/AML verification
    • Seller's tokens still subject to lockup or vesting restrictions
    • Buyer not eligible to purchase the tokens (jurisdiction, accreditation)
    • Suspicious transaction patterns or pricing
    • Incomplete or inconsistent documentation
    • Transfer restrictions specific to the deal
    • Regulatory prohibitions

  2. Review the automated compliance checks:

    • Red indicators typically signal non-compliance issues
    • Yellow indicators require your judgment based on additional context

Step 2: Thoroughly Document the Issues​

  1. Click on the "Add Note" button

  2. Select "Rejection Notes" from the dropdown

  3. Document all identified issues in detail:

    • Specific compliance violations
    • Missing or problematic documentation
    • Regulatory concerns
    • Any suspicious patterns or red flags
    • Reference to specific rules or restrictions that apply

  4. Be factual and objective in your documentation

  5. Include references to relevant regulations or platform policies

  6. Click "Save Note"

Step 3: Consult Compliance Resources (If Needed)​

  1. For complex or borderline cases:

    • Click on "Compliance Resources" in the sidebar
    • Review relevant compliance guidelines for the specific issue
    • Check previous similar cases in the knowledge base
    • Review deal-specific transfer restrictions

  2. For significant issues:

    • Use the "Request Compliance Review" button
    • Select the specific compliance question
    • Add your preliminary assessment
    • Submit for review by the compliance team

  3. Wait for guidance if the case requires compliance team input

Step 4: Document Rejection Reason​

  1. Click on the "Reject" button

  2. A rejection note field will appear

  3. Select the primary reason for rejection from the dropdown menu (if available):

    • Seller Ineligibility
    • Buyer Ineligibility
    • Transfer Restriction Violation
    • Incomplete Documentation
    • Suspicious Transaction
    • Regulatory Prohibition
    • Other (requires explanation)

  4. Write a clear, concise explanation for the rejection:

    • Be specific about the issue(s)
    • Avoid legal jargon when possible
    • Explain which requirements were not met
    • Reference relevant rules or policies
    • Be professional and objective

Step 5: Include Remediation Instructions (When Applicable)​

  1. If the issue can be remediated, include in your rejection note:

    • Clear steps to address the issue
    • Specific documentation or actions needed
    • Whether resubmission is possible after remediation

  2. For non-remediable issues, include in your rejection note:

    • A clear statement that the transaction cannot be resubmitted
    • An explanation of why the issue cannot be remediated
    • Alternative options if available

Step 6: Review Rejection Note​

  1. Review your rejection note for:

    • Clarity and completeness
    • Factual accuracy
    • Professional wording
    • Compliance with communication guidelines

  2. Ensure you've included:

    • The specific rejection reason
    • A detailed explanation
    • Remediation instructions (if applicable)

  3. Make any necessary adjustments before submitting

Step 7: Apply Digital Signature and Reject​

  1. Click the "Reject" button

  2. The system will prompt you to apply your digital signature

  3. Options for signature application:

    • Use your pre-configured digital signature
    • Draw a new signature
    • Type your name for a text-based signature

  4. Review the legal statement regarding your rejection

  5. Apply your signature

  6. Click "Submit Signed Rejection"

Step 8: Verify Rejection Notification​

  1. After rejection, the system will:

    • Update the trade status to "Rejected"
    • Send notifications to the buyer and seller
    • Record your rejection in the audit log
    • Archive the rejected transaction

  2. Review the confirmation screen showing:

    • Rejection timestamp
    • Your digital signature
    • Notification status
    • Audit trail information

Step 9: Handle Post-Rejection Inquiries​

  1. After rejection, investors may have questions or concerns:

    • Monitor the "Messages" section for inquiries
    • Respond promptly and professionally
    • Refer to your documented reasons for rejection
    • Direct them to remediation steps if applicable

  2. For escalated inquiries:

    • Use the "Escalation Notes" feature to document communication
    • Involve compliance or legal teams if necessary
    • Maintain a professional tone throughout

Step 10: Share Insights with Team (When Relevant)​

  1. For significant or unusual rejections that may be educational for the team:

    • Document the case in your team's shared resources
    • Summarize the case (without identifying information)
    • Highlight key decision factors
    • Note any precedent established

  2. This helps maintain consistency across the transfer agent team

Best Practices​

  • Be Thorough: Carefully document all compliance issues before rejection
  • Be Clear: Provide specific, factual reasons for rejection
  • Be Consistent: Apply the same standards to all transactions
  • Be Helpful: Include remediation instructions when possible
  • Be Professional: Maintain objectivity and professionalism in all communications
  • Be Prompt: Process rejections in a timely manner
  • Be Knowledgeable: Stay updated on regulations and platform policies
  • Be Consultative: Seek guidance on complex cases
  • Be Detailed: Document your reasoning thoroughly for audit purposes
  • Be Educational: Use rejections as opportunities to educate investors about compliance requirements

Troubleshooting​

Common Issues​

  1. Investor Disputes Rejection

    • Solution: Refer to your detailed documentation of the issues
    • Solution: Escalate to compliance team if the investor provides new information
    • Solution: Maintain professional communication throughout the dispute

  2. Uncertainty About Rejection Reason

    • Solution: Consult with the compliance team before rejecting
    • Solution: Review similar past cases in the knowledge base
    • Solution: Document your decision-making process thoroughly

  3. System Issues During Rejection

    • Solution: Save your work frequently during the rejection process
    • Solution: Take screenshots of any error messages
    • Solution: Contact technical support if the rejection cannot be processed

  4. Borderline Compliance Cases

    • Solution: Use the "Request Compliance Review" feature
    • Solution: Document your preliminary assessment
    • Solution: Wait for guidance before proceeding

  5. Post-Rejection Communication Challenges

    • Solution: Stick to the documented rejection reasons
    • Solution: Avoid engaging in arguments about the decision
    • Solution: Refer complex disputes to the compliance team

Getting Help​

If you encounter any issues during the rejection process:

  1. Navigate to the /support Support center by clicking on the "Support" link in the main navigation
  2. Select the appropriate category for your issue
  3. Provide specific details about your issue, including the trade request ID
  4. Submit your support request
  5. Support staff will respond through the platform's notification system