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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

FlowFreeze PointWhat Happens
Payin (Fiat → Crypto)FiatDeposit stageFiat is received but not converted to crypto until review completes
Payout (Crypto → Fiat)CryptoSettlement stageCrypto is received but not converted and paid out until approved

What to Expect During a Freeze

  1. EDD Request: Noah's Compliance team will request documentation based on your KYC model (Reliance or Standard)
  2. 10-Day Window: Customers have 10 days to provide requested documentation
  3. 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

ScenarioRefund 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:

StatusDescription
PendingRefund requested, being processed
CompletedFunds returned to destination
FailedRefund 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

AspectRefundReversal
WhenBefore transaction settlesAfter transaction has settled
TriggerEDD/Compliance rejectionRegulatory or banking-level intervention
FrequencyStandard processRare
Handled byAutomated systemCompliance 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.