Regulatory Requirements

DOCS

Last updated: Aug 15th, 7:15am

Important: This page is for partners who integrate with their own UI. The partner must ensure their UI meets all regulatory requirements, or the partner may be fined or shut down.

Some personal payments might require compliance with the legally mandated remittance transfer rule. This rule provides protections, including disclosure requirements, and error resolution and cancellation rights, to consumers who send remittance transfers to other consumers or businesses in a foreign country. The rule applies to any transfer in excess of $15 (USD) sent to a person or company in a foreign country through a remittance transfer provider, such as PayPal.

Some transactions require additional information:

Unilateral RTR transactions
Travel rule

Remittance transfer rule

PayPal must show mandatory disclosures in the user interface for remittance transfer rule (RTR) transactions. The broad categories of disclosures are:

The review phase
The done phase

Review phase

The review phase occurs after you generate a list of funding options.

The disclosures typically include the full display of payer information, payee information, and the estimated fees for this transaction.

Funding options response

1{
2  "regulatory_information": {
3    "remittance_transfer_rule": {
4      "action": "DISPLAY_TRANSACTION_DISCLOSURES"
5    }
6  }
7}

Done phase

The done phase occurs after invoking fulfillment.

The disclosures include fee information, payer and payee information, estimated date of receipt of funds in the payee account, and state agency information. Your app or portal should display all provided information to the user.

Fulfillment response

1{
2  "regulatory_information": {
3    "remittance_transfer_rule": {
4      "disclosure_details": {
5        "disclaimer": "NO_SPECIAL_LIMITS_VERIFIED_NO_PPZ_SEND_ENABLED",
6        "estimated_funds_arrival": "2014-11-13T09:43:15Z",
7        "state_agency": {
8          "name": "Illinois Department of Financial Institutions",
9          "phone": "(217) 785-0820",
10          "website": "https://example.com/"
11        }
12      }
13    }
14  }
15}

Unilateral RTR transactions

When the payee email or phone number is not registered (linked and confirmed) to any PayPal account and the transaction is RTR eligible, an additional collection of the payee's name and country code is required.

If you try to generate a list of funding options without these details for an RTR transaction, the following error occurs:

1{
2  "name": "TRANSACTION_DECLINED_ADDITIONAL_PAYEE_INFO_REQUIRED"
3}

To return the expected response, pass the correct country_code and name in the list funding options request:

1{
2  "amount": {
3    "value": "25",
4    "currency": "USD"
5  },
6  "payee": {
7    "id": "[email protected]",
8    "type": "EMAIL",
9    "name": "John Doe",
10    "country_code": "GB"
11  },
12  "fee": {
13    "payer": "PAYER"
14  },
15  "payment_type": "PERSONAL"
16}

Travel rule

Personal payments made while traveling require travel rule compliance similar to RTR compliance. The travel rule applies to transactions where a US-based sender sends $3,000 USD (or equivalent) an amount greater. Travel rule checks are performed when the fulfillment API is invoked.

Not all combinations of instruments and funding options trigger the travel rule. For applicable funding options, the travel_rule object is populated, as follows in the sample response for a funding options request:

1{
2  "funding_options": {
3    "payee": {
4      "type": "EMAIL",
5      "id": "[email protected]",
6      "name": "Mikey Merchant",
7      "country_code": "GB",
8      "is_paypal_account": true
9    },
10    "options": [{
11      "id": "9m0MW8ShF4mCJfAKz8Qr4E95wu4AFiDW6vq_yUZknatYVyhoYDe50mjzfTIJS2711iU3mW",
12      "funding_mode": "INSTANT",
13      "fee": {
14        "payer": "PAYER",
15        "amount": {
16          "value": "41.28",
17          "currency": "USD"
18        }
19      },
20      "sources": [{
21        "instrument_type": "PAYMENT_CARD",
22        "payment_card": {
23          "id": "CCEFDQXCXTADNZA",
24          "network": "VISA",
25          "last_4": "2816",
26          "amount": {
27            "value": "3041.28",
28            "currency": "USD"
29          }
30        }
31      }],
32      "regulatory_information": {
33        "travel_rule": {
34          "action": "PERFORM_DATA_COLLECTION",
35          "attributes": [
36            "GOVT_ID",
37            "DATE_OF_BIRTH"
38          ]
39        }
40      }
41    }],
42    "payment_type": "PERSONAL"
43  }
44}

The travel_rule object is returned only in those funding options where data collection is applicable. In the preceding response, the merchant is expected to collect the GOVT_ID and the DATE_OF_BIRTH of the sender and save them in PayPal’s system before trying to complete a payment. In cases when a merchant cannot collect sensitive data from a sender and the transaction cannot be completed, the merchant should direct the sender to log in to PayPal to update his or her sensitive data.

Possible data collection attributes include:

GOVT_ID. For example, social security number (SSN), tax payer identification number (TIN), or green card number of the payer.
DATE_OF_BIRTH. Date of birth of the payer.
NON_PO_BOX_ADDRESS. An address that is not a post office (PO) box address of the payer.