Overview

zerohash audits invoice-based business-to-business transactions every month, after they settle. The audit looks for misuse of the product to exchange controlled or restricted goods and services, including those subject to export or import restrictions, in cross-border trade. When a transaction is selected, the Platform must provide the invoice and, for some triggers, enhanced due diligence (EDD) information within 15 calendar days. For some Payors, EDD is always triggered automatically as soon as zerohash receives a deposit from them, regardless of sampling. See Automatic EDD triggers below.

Monthly Sample Audit Triggers

These triggers define the population from which zerohash Compliance draws a random sample. Each selected transaction triggers a request for a copy of its invoice. They apply to all MCCs except those listed under Automatic EDD triggers and Prohibited MCCs.

Audit procedure

1. Selection: at the end of each month, zerohash identifies the transactions triggered for audit and sends the full list, by transaction ID, to the Platform.
2. Collection: the Platform obtains the invoice for each listed transaction from the relevant business. Where an EDD trigger applies, it also completes the EDD questions.
3. Submission: within 15 calendar days, the Platform uploads the invoices and EDD responses to each relevant business's profile with the POST /participants/entity/documents endpoint.
4. Review: zerohash reviews the documents and decides whether further action is needed. Further action can include closing the business's account or placing limits on the Platform's relationship with zerohash.

Automatic EDD triggers

These triggers always apply. zerohash sends a targeted EDD form to the Platform that asks for a copy of the invoice associated with the transaction and supplemental EDD information on the business or businesses involved. In most cases, EDD only needs to be completed once.

Automatic EDD Merchant Category Codes (MCC)

If a deposit is received from a Third Party Payor with one of the following Merchant Category Codes, EDD will be triggered automatically. zerohash will reach out to the Platform to provide EDD information within a fifteen day grace period. After this period ends, additional deposits from the Third Party Payor will be rejected.