Communicating Involuntary Terminations

This article describe Check’s process for identifying bad actors on our platform and provides advice on communicating with a customer that is terminated by Check for potential fraudulent or illegal activity.

While Check’s goal is to serve all of our partners’ customers, the unfortunate reality is that some customers are looking to use Check’s and our partners’ platforms for nefarious purposes. Allowing fraud or illegal activity exposes Check to financial loss and can cause our partners reputational harm. Check’s Risk team reviews numerous aspects of onboarding businesses - such as their business registrations, internet presence, bank account information, and media history - to ensure that the information they provide is not consistent with fraudulent or illegal intent.

At a high level, involuntary termination for fraud or compliance reasons at Check happen because we have evidence that the business is trying to conduct illegal activity, such as the following:

This is when a bad actor is impersonating a legitimate business using information about the business that is publicly available, stolen, or fabricated. These bad actors may have access to a business’s bank account credentials and may attempt to move funds into fraudulent accounts under the guise of paying the employees of the business they are impersonating.

ID theft often ties to business impersonation where the signatory’s credentials are compromised and are being used to sign up fraudulently.

The business may be using the payroll platform to launder money or conduct other illegal activity.

There are certain types of companies, workers and industries that Check cannot support. The full list can be found under the Check's Unsupported Features Help Center article. Companies with these features, may be flagged as compliance-breaking behavior based on our monitoring and will be terminated for industry.

By the time you receive notice that a company has been terminated for fraud, that company has run through Check’s automated review and has been screened by a member of our Risk team. We consult official third-party sources and utilize tools and logic to detect fraudulent patterns. Our teams are constantly recalibrating using the latest data and trends we observe.

One advantage Check has is the ability to see new businesses onboarding across multiple partners. Often a bad actor that is unsuccessful in enrolling with one payroll platform, or who is terminated after successfully committing fraud, will try other platforms. Where Check sees business names, individual names, or IP addresses associated with prior fraud or illegality, we can confidently make the decision to terminate these companies.

At times, during our review process we may uncover additional details or negative news about a company or associated individual who has committed fraud or related crimes in the past. Depending on the facts, this may put them into a higher risk category that Check is unable to support. These decisions are made after extensive research and discussion to make sure we are remaining within the realm of risk Check can take on.

You have received your first notification of a denial due fraud risk. What do you do?

The best approach is to communicate the termination to the customer with few details. While the communication can be empathetic, it should emphasize the limited options available to them, and should not allude to fraud or illegality being a reason for the decision.

Providing a detailed reason for a compliance termination is not advisable for several reasons:

While we are constantly updating our methods to detect anomalous activity. To maintain the integrity of our processes, and make sure we can protect both Check and our partners, please do not disclose specific reasons for account terminations to your customers.

Below are examples of concise language that can be used to convey a termination:

"We recognize that this news may be upsetting and apologize for any inconveniences this may cause. Please know that this course of action was not taken lightly and the decision was made to ensure the safety and integrity of our community. Unfortunately, due to the sensitive nature of the information involved, we are unable to provide additional details regarding the reasons for this termination."

"We are writing to inform you that, after careful consideration, we have unfortunately had to proceed with the termination of your account with [Partner Name], effective immediately. We recognize that this may come as disappointing news and sincerely regret any inconvenience it may cause. We appreciate your understanding and cooperation in this matter."

"After thorough review, we have terminated your account with [Partner Name] due to activities that violate our terms of service. While we can't share specific details for security reasons, we want you to know this decision was not made lightly. We appreciate your understanding and cooperation in this matter."

If you believe that additional information in your possession proves that Check’s decision was erroneous and you are confident this is not a fraudulent customer, you may appeal a fraud or compliance termination via our Secondary Review. Please find more information on what Secondary Review is here.