Reminder: If you want to PayPal or Venmo some cash to someone without any hitches, do not put the word Iran in the memo field. On Wednesday, Jewish Currents got an annoying reminder of this rather blunt policy. The magazine tweeted that nine payments to its staff and contributors had been held up by PayPal because the transaction descriptions included the term Iran in reference to a piece that the magazine published.
PayPal, along with its subsidiary Venmo, uses a system that automatically flags keywords in the payment memo field that could indicate a violation of U.S. sanctions. Upon detecting a suspicious transaction, PayPal sends an email to both the sender and receiver reading, “To comply with government regulations, PayPal is required to review certain transactions. The payment you sent is currently being reviewed and we will complete this process within 72 hours.” So if, say, you try to send a friend money for “drinks at Cuba Libre,” you’ll quickly learn how dense PayPal’s system can be when it comes to context clues.
This longstanding PayPal policy has caused numerous headaches in the past. Users have run into trouble sending payments reading “Persian Nowruz”—a New Year’s holiday—because of the term Persian and making donations to Syrian refugees because of the term Syrian.
When asked about Jewish Currents’ conundrum, PayPal told Slate in a statement, “PayPal takes its regulatory and compliance obligations seriously, including U.S. economic and trade sanctions administered by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Our goal is to deliver as seamless of a payments experience as possible while we do our job in making sure payments made on our platforms comply with applicable law. We realize any delay in making or receiving a payment can be frustrating, and we appreciate our customers’ patience as we comply with our regulatory obligations.” Jacob Plitman, the publisher of Jewish Currents, told Slate that the payment specifically referring to Iran eventually went through, but that the eight others that came after are still under review. PayPal said those remaining delays are “related to standard bank transfer times for eCheck payments.”
PayPal mainly relies on lists of embargoed countries, organizations, and individuals that the Treasury Department’s Office of Foreign Assets Control has compiled to determine what payments require further review. Yet this leaves out a good number of illicit activities that the payment service could be facilitating—leaving the impression of a rather arbitrary flagging system. To get a better sense of what PayPal does and doesn’t deem suspicious, I sent my editor dozens of 1 cent transactions with different memo descriptions, which are listed below. It’s worth noting that this list is nowhere near complete, and PayPal has a number of other mechanisms to check for illegal behavior, such as fraud-prevention technology that uses machine learning.
As you can see, PayPal’s flagging has a fairly eager trigger finger when it comes to anything having to do with foreign sanctions and a laissez-faire stance toward weapons, drugs, human and animal trafficking, prostitution, and hate groups. It also seems that proper nouns referring to specific entities are under more scrutiny than general descriptions of criminal activity, which are perhaps more likely to be a joke. In fairness, it’s unlikely that someone actually in the market to blow something up would write bomb in the payment description, but then again a person trying to send funds to the Islamic State isn’t likely to attach the flagged term ISIS to their donation either.
Words and phrases that were flagged
Iran
ISIS
Persian
North Korea
Kim Jong-un
Bashar al-Assad
Qasem Soleimani
Real Irish Republican Army
Cuba
Cubano sandwich
Syria
Syrian refugee
Al-Qaeda
Sinaloa Cartel
Los Zetas
Shining Path
Words and phrases that were not flagged
Bomb
Car bomb
Weapons of mass destruction
Assassination
Hitman
Kidnapping
Terrorist
Cartel
Anthrax
Ricin
Sarin gas
AK-47
Glock 43
Dog fight
Nazis
Stormfront
Atomwaffen
Unite the Right
Proud Boys
KKK
Klansmen
David Duke
Prostitutes
Handjob
Blowjob
Revenge porn
Snuff film
Human trafficking
Slave
Fetus
Stem cells
Kidney harvest
Napalm
Coyote
Marijuana
MDMA
Ecstasy
LSD
Meth
Black tar heroin
Ketamine
Cocaine
Fake ID
Wire fraud
Little Women bootleg DVD
Fake Yeezys
Rhino horn
Elephant tusk
Pangolin
Shark fin
Irish Republican Army
MS-13
Iraq
Sudan
Yemen
Hezbollah
Venezuela
Somalia
Future Tense is a partnership of Slate, New America, and Arizona State University that examines emerging technologies, public policy, and society.
