Composite scenario · Online platform · payouts

One EMI froze, and payouts stopped

A platform paying out to partners ran everything through a single EMI account. A routine review froze it, and payouts stopped with it.

Composite scenario: built from the kinds of mandates we handle, with details changed and combined. It does not describe a specific client. Results depend on the business, the providers and the file.

Setup: One EMI for collections and payouts
Trigger: Periodic review after volume growth
Impact: Partner payouts delayed
Goal: No single point of failure

The situation

Volume had grown well beyond what was declared at onboarding, and the provider wasn’t told. A periodic review asked for updated information and restricted the account while it waited.

With no second account, there was no way to keep paying partners during the review.

What we changed

Answered the review fully and quickly with updated forecasts, counterparties and flow-of-funds documents.
Opened a second EMI and a bank account in parallel, and split collections and payouts across them.
Set up a simple rule: tell providers before volume steps up, and keep at least one working route for every critical flow.

What held

Restriction lifted once the review was answered.
Collections and payouts now run across separate providers, so one review can’t stop the business.

The lesson
Tell your provider about growth before their monitoring tells them.

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