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Core rule. You may not use your 1Money Customer Account, any 1Money Wallet, Virtual Account, or the Services to process, facilitate, or transmit payments or transactions on behalf of, or for the benefit of, third parties whose identity or transaction activity is not visible to 1Money.

Overview

1Money prohibits nesting and other forms of Nested Payments because they obscure the true customer, the true owner of funds, or the true purpose of a transaction. Where funds or instructions are routed through one Customer on behalf of another party that has not been onboarded, screened, and approved by 1Money, 1Money may be unable to complete customer due diligence, sanctions screening, transaction monitoring, fraud review, or other compliance checks required for the Services.

In practical terms, the permitted use of the Services is for the benefit of the onboarded Customer itself and, where expressly approved, for structures that 1Money has reviewed and authorized in writing. A Customer should not use its 1Money Customer Account, 1Money Wallet, or Virtual Account as a pass-through layer for parties that 1Money cannot see and assess directly.

Contractual position in the 1Money terms

The 1Money Terms and Conditions classify nesting within the broader Restricted Activities framework and expressly prohibit the use of a 1Money Customer Account to process, facilitate, or transmit payments or transactions on behalf of, or for the benefit of, third parties whose identity or transaction activity is not visible to 1Money.

The terms also prohibit a Customer from acting as an intermediary, broker, or aggregator between 1Money and anyone else unless 1Money has expressly approved that structure through a separate arrangement, such as an approved Partnership Services model or another written agreement.

What 1Money means by nesting

Nesting, or Nested Payments, arises where one Customer uses its account, wallet, or payment functionality to move funds for another party that has not been onboarded, approved, or otherwise made visible to 1Money.

Common features of nesting include pooled or commingled third-party funds, batched instructions covering multiple underlying parties, withdrawals from an account that is not owned by the true payer, receipts into an account that is not owned by the true beneficiary, or any structure where a third party is effectively receiving access to the Services through the Customer rather than through its own relationship with 1Money.

Why nesting is prohibited

Risk area	Why it matters
Customer due diligence risk	1Money may be unable to identify the actual party using the Services or benefiting from a payment flow.
Sanctions and screening risk	When the true sender, recipient, or underlying counterparty is hidden, sanctions screening and adverse media review may be incomplete.
Transaction monitoring risk	Nested flows can mask the purpose, pattern, and economic rationale of transactions, making suspicious activity review unreliable.
Licensing and regulatory risk	A Customer may inadvertently operate as an intermediary, aggregator, or unlicensed money transmission layer for others.
Fraud and operational risk	Pooling and routing third-party funds increases reconciliation failures, documentation mismatches, returns, and disputes.

A simple test

Before initiating activity, ask whether the Customer is using the Services for its own funds, its own commercial purpose, and its own visible transaction activity — or whether it is moving value for someone else whose identity or activity is not visible to 1Money. If the answer points to the second scenario, the structure is likely nested and should not proceed without written approval from 1Money.

What usually indicates nesting

Funds in a Virtual Account belong economically to someone other than the onboarded Customer.
A payment request is supported by invoices, payroll records, or contracts naming a different party.
One Customer is collecting receipts for several underlying businesses, employers, funds, merchants, or end users.
One Customer is paying suppliers, employees, contractors, or investors for another entity that is not onboarded.
A Customer wants separate sub-accounts that each represent a different third party's money rather than the Customer's own money.

What is generally not nesting

A transaction is generally not nested where the onboarded Customer is acting for itself, the funds are its own funds, and the economic purpose belongs to that Customer. Legitimate revenue received for services rendered by the onboarded Customer, or ordinary business expenses paid by that Customer from its own account for its own operations, will typically not be treated as nesting.

A structure also may be acceptable where 1Money has separately onboarded the true underlying legal entity, or where 1Money has expressly approved a specific arrangement in writing under an appropriate service model with additional oversight, onboarding, controls, and documentation.

Illustrative examples

Scenario	Permitted structure	Nested / prohibited structure
Incoming collections	The onboarded Customer receives funds that are payment for its own goods or services.	The onboarded Customer receives funds that belong to another business or individual and is only acting as a conduit.
Outgoing supplier payment	The onboarded Customer pays its own vendor from its own account for its own business purpose.	The onboarded Customer pays a vendor on behalf of another entity that is not onboarded.
Treasury movement	The onboarded Customer moves its own funds between its own approved accounts or approved External Wallets.	The onboarded Customer routes funds through its account for another party's treasury activity.
Virtual Account use	The Virtual Account is used for the Customer's own approved commercial activity.	The Virtual Account is used to pool, batch, or commingle multiple third parties' funds or instructions.

Approved structure by common use case

Investment vehicles, funds, and SPVs

Area	Acceptable approach	Nested approach to avoid
Onboarding	The fund, SPV, or other investment vehicle itself is onboarded as the Customer or as its own separately approved entity, with ownership and control reviewed using the 1Money onboarding framework.	Only the fund manager, administrator, or adviser is onboarded while investor money for multiple vehicles is routed through that manager's account.
Accounts	Each approved vehicle uses accounts or wallets aligned to that vehicle's own activity.	Multiple vehicles are represented inside one manager account or one pooled account.
Collections	Investor subscriptions are directed to the approved vehicle that is receiving the investment.	Subscriptions are collected into an account held in the manager's or administrator's name on behalf of the vehicle.

Payroll, contractor, and payout processors

Area	Acceptable approach	Nested approach to avoid
Onboarding	The employer/business whose money is being used to pay workers must have its own 1Money account and must be approved by 1Money.	A payroll processor cannot use its own 1Money account to send payments for employers that 1Money has not separately onboarded and approved.
Accounts	The payment account used for payroll or payouts belongs to the approved employer or approved principal.	The processor pools multiple employers' payroll funds in its own account.
Payments	Payments are made from the approved employer or principal account using documentation that matches that entity.	The processor makes payouts from an account in its own name for an employer that is not visible to 1Money.

Payment processors and commercial settlement providers

Area	Acceptable approach	Nested approach to avoid
Underlying customer visibility	Each legal entity whose funds are being moved is separately onboarded or expressly approved under a written structure.	The processor uses 1Money relationship to move funds for many unseen customers.
Use of Services	The processor uses the Services only within the bounds of an approved model and documented control framework.	The processor effectively provides downstream access to the Services without 1Money's written approval.
Documentation	Supporting records identify the same entity that owns the account and is sending or receiving funds.	Documentation names one party while the payment is initiated by another unrelated account holder.

Operational controls and best practices

Control	Practical expectation
Onboard the true transacting entity	The legal entity that owns the funds, bears the economic purpose, or is the true sender or beneficiary should be the entity approved by 1Money.
Match documents to the account owner	Invoices, contracts, payroll files, redemption requests, and settlement instructions should identify the same entity that is sending or receiving funds.
Avoid pooled third-party funds	Do not batch, pool, or commingle multiple third parties' funds or transaction instructions through one Customer account unless 1Money has expressly approved the structure.
Use separate approvals for special models	Where a business model involves merchant acquisition, agency arrangements, Third-Party Payment Services, or another specialized structure, obtain explicit written approval and use the required agreement set.
Escalate early	If a transaction looks like it may involve an undisclosed principal, omnibus activity, or a hidden underlying customer, pause the flow and raise it with 1Money before processing.

Documentation alignment checks

Does the name on the invoice, contract, payroll file, or settlement instruction match the Customer using the 1Money Customer Account?
Does the source of funds belong to the same entity that is initiating the transaction?
Is the recipient the Customer itself, or a disclosed and approved counterparty connected to the Customer's own business purpose?
Are there multiple underlying parties hidden within one payment file, one receipt, or one omnibus balance?

When written approval may be required

Some business models involve layered payment activity, agency, merchant acquisition, payout programs, or other arrangements that require a separate written agreement, enhanced due diligence, additional oversight, and operating controls. In those cases, a structure that would otherwise look nested may only be permitted if 1Money has expressly approved it in writing and the Customer operates strictly within that approved model.

Customers should not assume that operational convenience, internal sub-ledgers, or contractual arrangements with their own customers are enough to make a nested flow permissible. Visibility to 1Money, direct onboarding of the relevant party, and written approval where applicable remain the key requirements.

Consequences of non-compliance

If 1Money determines that a Customer is engaging in nesting, Nested Payments, intermediary activity, or other Restricted Activities, 1Money may delay, reject, freeze, reverse where possible, or investigate the activity. 1Money may also request additional information, impose limits, suspend access to Services, or terminate the applicable 1Money Customer Account in accordance with the terms.

Where necessary, 1Money may also report suspicious or prohibited activity to applicable law enforcement, regulatory authorities, banking partners, payment partners, or other relevant counterparties, consistent with its legal and compliance obligations.

Customer action points

Do	Do not
Use the Services for the onboarded Customer's own visible business activity.	Do not route funds for hidden third parties through your account.
Ensure the true owner of funds and true transacting entity are visible to 1Money.	Do not pool, batch, or commingle third-party funds in your own name.
Keep supporting documentation aligned to the sending or receiving entity.	Do not submit payment support naming one entity while another entity's account is used.
Seek written guidance before launching a complex payment model.	Do not assume a commercial contract with your own customer replaces 1Money approval.

Reference terminology from the 1Money Terms and Conditions

This guidance intentionally uses the terminology reflected in the 1Money Terms and Conditions, including: 1Money Customer Account, 1Money Wallet, Virtual Account, Services, Restricted Activities, Prohibited Transactions, Partnership Services, Third-Party Payment Services, and Nested Payments / nesting.

Where there is any inconsistency between this guidance page and the governing customer terms, any applicable separate written agreement, or written instructions provided by 1Money, the governing terms and written approval framework should control.