China Supplier Bank Account Verification Checklist

Before paying a China supplier, compare the current payment instructions with the contract, order record, and prior instruction version. Pause unexplained changes and confirm them through a previously established or independently obtained contact channel—not contact details supplied only with the change request. Document the contracting entity, beneficiary, claimed relationship, confirmation contacts, and unresolved differences. A mismatch or offshore account requires review but proves neither fraud nor legitimacy. Only an authorized reviewer should decide whether to hold or release payment.

1. Establish the payment-instruction baseline

Start with controlled records that show what the parties agreed and whether the instructions have changed. Keep these terms separate:

• Contracting entity: The legal entity identified as the seller in the governing contract, purchase order, or applicable order record.
• Beneficiary: The exact person or entity named to receive the bank transfer.
• Payment instructions: The beneficiary name, bank, jurisdiction, account identifier, and related transfer details communicated for payment.
• Instruction version: A dated copy or record that distinguishes the original instructions from later changes.

Before attempting confirmation, record:

• Order or transaction reference.
• Contracting Chinese legal entity exactly as written.
• Beneficiary name exactly as provided.
• Bank name and jurisdiction.
• Masked account identifier suitable for internal comparison.
• Date, source, and version of the instructions.
• Person and channel that supplied the instructions.

Compare the current version with:

1. The contract, purchase order, or other applicable order record.
2. Previously accepted payment instructions, if any.
3. The latest authorized amendment or documented update.

Flag material differences without assigning a conclusion:

• A new beneficiary.
• Changed beneficiary spelling or legal suffix.
• A different bank or jurisdiction.
• A new Hong Kong or other offshore account.
• A changed account identifier.
• A new contact person or communication channel.
• A request to disregard prior instructions.
• Urgency intended to accelerate payment before review.

A match supports consistency between the records being compared, but it does not independently certify account ownership. A difference requires explanation and confirmation, but it does not by itself establish fraud.

Payment-instruction review should sit within the broader supplier verification process before a first order, rather than replace checks on the supplier and transaction.

2. Assess a beneficiary-name or jurisdiction difference

Do not treat the following records as interchangeable:

1. The contracting seller named in the transaction documents.
2. The beneficiary named in the payment instructions.
3. The bank and jurisdiction where the beneficiary account is maintained.

If the beneficiary name differs from the contracting seller, request records addressing:

• The claimed relationship between the seller and beneficiary.
• The beneficiary’s role in receiving the specific payment.
• The seller’s authority or instruction directing payment to that beneficiary.
• The order or transaction to which the instruction applies.
• The people authorized to issue or approve the instruction.

For a Hong Kong or other offshore-account arrangement, document:

• The contracting Chinese legal entity.
• The offshore beneficiary’s exact name.
• The claimed corporate, agency, collection, or other relationship.
• Why that beneficiary is instructed to receive this payment.
• Which authorized representative confirms the arrangement.

These records can document the supplier’s explanation and provide material for internal review. Their contents can also be compared with the contract, order, and payment instructions. They do not provide public-source certification of account ownership, guarantee that funds will reach the intended party, or determine that payment may safely be released.

Apply conditional decision paths:

• Names and jurisdiction align: Continue to independent confirmation and authorized review.
• The beneficiary differs, but a relationship is claimed: Record the claim, request relationship and authority records, and confirm the arrangement through an independent channel.
• The explanation or authority remains incomplete: Mark the difference unresolved and escalate it.
• The account is in Hong Kong or another offshore jurisdiction: Apply the same confirmation and documentation controls. Do not treat location alone as proof for or against legitimacy.

A name or jurisdiction mismatch is evidence of a difference requiring review, not a finding of fraud. A documented explanation is evidence of what was represented, not conclusive proof that the representation is legitimate.

3. Independently confirm original and changed instructions

Independent confirmation is required when:

• A new beneficiary is introduced.
• Existing beneficiary details change.
• The bank, jurisdiction, or account identifier changes.
• A different employee or intermediary supplies the instructions.
• The instructions conflict with the contract, order, or an earlier version.

Use a confirmation contact obtained from:

• A contact method established before the change request.
• An existing controlled record maintained by the buyer.
• Another independently obtained channel allowed by the buyer’s procedures.

Do not rely solely on:

• A phone number included only in the change-request email.
• A reply within the same potentially compromised email thread.
• New contact details supplied only with the revised instructions.

The FBI’s business email compromise guidance recommends verifying payment or account changes through a known contact method rather than relying only on the communication requesting the change.

Structure the confirmation around recorded facts:

1. Identify the relevant order or transaction.
2. Read back or compare the beneficiary’s exact name.
3. Confirm the bank and jurisdiction.
4. Compare only an appropriately masked account identifier under the buyer’s secure process.
5. Ask whether any details changed and who authorized the change.
6. Ask the contact to explain any difference between the contracting seller and beneficiary.
7. Record what the contact confirms, declines to confirm, or cannot explain.

Keep both sides of the confirmation trail:

• Original instruction contact and channel.
• Independent confirmation contact and channel.
• Origin of each contact detail.
• Confirmation date and reviewer.
• Details confirmed.
• Differences that remain unresolved.

Independent contact reduces reliance on the channel that delivered the change. It does not certify bank-account ownership, replace the buyer’s approval controls, or guarantee that payment should be released.

4. Escalate unresolved differences for an authorized decision

An unresolved difference is an inconsistency that remains unsupported, unexplained, or unconfirmed after the documented review.

Record unresolved conditions without assigning a fraud finding. These can include:

• The contract seller and beneficiary differ, but no relationship or authority record is supplied.
• The claimed relationship is documented incompletely or inconsistently.
• A previously established supplier contact cannot confirm the change.
• The only available confirmation contact came from the change request.
• Current instructions conflict with another controlled record.
• The bank, jurisdiction, or beneficiary changed without a traceable instruction version.

Use this decision sequence:

1. Pause processing of the unexplained change.
2. Preserve the original and revised instruction versions.
3. Record the evidence obtained and its source.
4. List every unresolved difference explicitly.
5. Route the record to the person or function authorized under the buyer’s controls.
6. Record the authorized hold or release decision without describing it as account-ownership certification or a guarantee.

The evidence reviewer documents records, contacts, and differences. The authorized decision-maker applies the organization’s approval rules. Documenting the review does not determine whether a specific payment should be made.

Related commercial questions should also be recorded before positions harden. See the process for documenting payment milestone questions before they become disputes.

If business email compromise or a fraudulent transfer is suspected, follow the organization’s incident-response process. The IC3 business email compromise resource provides FBI/IC3 prevention and response information. IC3 is related to the FBI; it is not independent corroboration of account ownership.

5. Copyable supplier payment confirmation record

Copy this blank record for each payment-instruction review. Keep entries factual and attributable. Do not infer account ownership merely because the form has been completed, and do not publish a completed record containing sensitive bank information.

Check	Recorded value / evidence	Contact / channel origin	Date / reviewer	Difference / next action
Order and instruction version
Contracting Chinese legal entity
Beneficiary exact name
Bank / jurisdiction / masked account identifier
Claimed beneficiary-seller relationship
Original instruction contact
Independent confirmation contact
Confirmation of any changed details
Unresolved differences
Authorized hold / release decision

Operating notes:

• Use a previously established or independently sourced contact, not contact details supplied only in the change request.
• Mask account identifiers according to the organization’s security and privacy requirements.
• Identify the origin of each document, contact, and communication channel.
• Preserve the original instructions and every changed version.
• Write “unresolved” where evidence is missing instead of filling gaps with assumptions.
• Record the authorized decision and decision-maker under the organization’s process.
• Retain sensitive evidence in the buyer’s approved secure system.
• This blank form does not verify or certify account ownership.

Copy the blank template, fill it only with the buyer’s own evidence, and retain unresolved issues for an accountable reviewer.

Sources

• FBI — Business Email Compromise
  Used for the limited prevention principle that payment or account changes should be verified through a known or independently established contact method. It does not establish that a particular supplier account is legitimate. Source-package check date: 2026-10-08; URL and time-sensitive details must be rechecked before publication.

• Internet Crime Complaint Center — Business Email Compromise
  Used for FBI/IC3 business email compromise prevention and response context. IC3 is related to the FBI and is not independent corroboration of account ownership. Source-package check date: 2026-10-08; URL and time-sensitive details must be rechecked before publication.

Scope and limits

This checklist provides an operating method for documenting independent confirmation before an authorized payment decision. Its practical contribution is the blank operating record, not a completed supplier investigation.

The checklist does not establish that:

• A public source certifies ownership of a bank account.
• Matching contracting-entity and beneficiary names prove legitimacy.
• A name mismatch proves fraud.
• A Hong Kong or other offshore account proves fraud or legitimacy.
• Completing the checklist guarantees safe payment release.
• The process replaces legal, banking, compliance, or other professional advice.

Do not publish completed account records. Use masked identifiers where an identifier is necessary, and retain sensitive documents and communications in the buyer’s approved secure system.

Before release, identify the author and reviewer; confirm the canonical URL; recheck factual accuracy, source applicability, URLs, privacy, usage rights, internal links, and the call to action; and obtain final article and image approval. Any illustration must be clearly distinct from actual supplier or bank evidence. This draft must not be published automatically.