{"id":55574,"date":"2026-11-01T22:29:32","date_gmt":"2026-11-01T21:29:32","guid":{"rendered":"https:\/\/www.altares.be\/?p=55574"},"modified":"2026-11-01T22:29:33","modified_gmt":"2026-11-01T21:29:33","slug":"who-pays-your-invoice-the-blind-spot-in-third-party-payments","status":"publish","type":"post","link":"https:\/\/www.altares.be\/en\/blog\/compliance\/wie-betaalt-jouw-factuur-de-blinde-vlek-bij-derdenbetalingen\/","title":{"rendered":"Who pays your invoice? The blind spot in third-party payments"},"content":{"rendered":"

Part 5 of 6 in our series on the compliance lessons from the FIU Annual Review 2025.<\/em><\/p>\n\n\n\n

The invoice is in your customer\u2019s name, but the money comes from another company. That does not have to be suspicious. A parent company may, for example, pay on behalf of a subsidiary. Yet the FIU Annual Review 2025 shows why third-party payments deserve more attention.<\/p>\n\n\n\n

In one analysis of third-party payments to Dutch companies, 2,000 transactions were declared suspicious, with a combined value of \u20ac300 million. The Belgian Financial Intelligence Processing Unit (CTIF-CFI) also warns against the misuse of third-party payments. Why should the payer also be part of your customer and transaction overview?<\/p>\n\n\n\n

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What are third-party payments?<\/h2>\n\n\n\n

In a third-party payment, a party other than the buyer pays for goods or services. There may be a logical explanation for this, such as a payment arrangement within a corporate group. Extra attention is needed when that relationship is unclear or the payment pattern does not fit the business relationship.<\/p>\n\n\n\n

FIU-Nederland, for example, identified a company that received money from several hundred different payers across multiple European countries. The Belgian CTIF-CFI describes how professional money launderers use companies as financial intermediaries in international trade transactions. This conceals financial connections and makes money flows harder to trace.<\/p>\n\n\n\n

The order itself may be entirely legitimate. A correct invoice and a received payment do not yet provide clarity about the origin of the money.<\/p>\n\n\n\n

Interesting read:<\/strong> Perpetual KYC: why customer due diligence does not stop after onboarding<\/a><\/p>\n\n\n\n

Why finance and compliance need each other<\/h2>\n\n\n\n

This is where a blind spot can easily arise. Compliance<\/a> investigates the customer, credit management assesses the debtor risk, and finance sees that the invoice has been paid. But who checks whether the payer has a logical connection to the transaction?<\/p>\n\n\n\n

It is precisely this information that needs to be brought together. Finance sees who transfers the money and knows the payment pattern. Compliance can investigate how the payer and the customer are connected. Together, they can assess whether a discrepancy calls for further investigation.<\/p>\n\n\n\n

Interesting read:<\/strong> Top 5 supplier risks and how to manage them<\/a><\/p>\n\n\n\n

When is it wise to ask further questions?<\/h2>\n\n\n\n

A third-party payment does not automatically have to be rejected. A practical assessment starts with three questions:<\/p>\n\n\n\n