Compliance Freezes, Refunds & Reversals
This page explains how Noah handles compliance freezes, refunds, and reversals across payin and payout flows.
Compliance Freezes
A compliance freeze occurs when a transaction requires Enhanced Due Diligence (EDD) review before proceeding.
When Freezes Occur
| Flow | Freeze Point | What Happens |
|---|---|---|
| Payin (Fiat → Crypto) | FiatDeposit stage | Fiat is received but not converted to crypto until review completes |
| Payout (Crypto → Fiat) | CryptoSettlement stage | Crypto is received but not converted and paid out until approved |
What to Expect During a Freeze
- EDD Request: Noah's Compliance team will request documentation based on your KYC model (Reliance or Standard)
- 10-Day Window: Customers have 10 days to provide requested documentation
- Resolution:
- Approved: Funds are unfrozen, converted, and sent to the destination
- Rejected: Transaction is rejected and funds are automatically refunded
Refunds
Refunds can happen as a result of an EDD/Compliance rejection.
Refund Destinations by Flow
| Scenario | Refund Destination |
|---|---|
| Payin (Fiat deposit) | Depositing Payment Method |
| Payout (Prefunded dashboard balance) | Custodian Stablecoin Account |
| Payout (Customer crypto deposit / automated payouts) | Sending Crypto Wallet |
Refund Lifecycle
Refunds progress through the following statuses:
| Status | Description |
|---|---|
Pending | Refund requested, being processed |
Completed | Funds returned to destination |
Failed | Refund could not complete (contact support) |
You will receive FiatDeposit webhook updates as the refund status changes. The Refunds array in the webhook payload contains the complete refund history.
Reversals
Reversals are distinct from refunds.
Key Difference: Refunds vs. Reversals
| Aspect | Refund | Reversal |
|---|---|---|
| When | Before transaction settles | After transaction has settled |
| Trigger | EDD/Compliance rejection | Regulatory or banking-level intervention |
| Frequency | Standard process | Rare |
| Handled by | Automated system | Compliance teams/representatives directly |
Transaction Finality
Noah transactions are processed with finality on Settled status for both payins and payouts. Once a transaction reaches Settled, under normal circumstances the transaction is complete.
When Reversals Happen
Reversals happen under rare circumstances where there is a regulatory or banking-level intervention. Such cases are handled directly between compliance teams/representatives—reversals are not handled through standard API flows.
Related Documentation
- FiatDeposit Event Webhook details for payin deposits
- Transaction Event Webhook details for payouts
- Bank Onramp US Guardrails Deposit source restrictions and EDD process
- Bank Onramp EU Guardrails Deposit source restrictions and EDD process