UCP 600 Article 37 — Bank to Bank Reimbursement Arrangements: Examination Checklist

Introduction

This checklist provides a step-by-step examination protocol for banks processing reimbursement requests under UCP 600 Article 37. It is designed for use by nominated banks preparing reimbursement claims and by reimbursing banks evaluating incoming requests. Each item corresponds to a specific requirement of Article 37, ISBP 745, or established banking practice.

Examination Checklist

Section A: Reimbursement Authorization Verification

• [ ] A1: Is the reimbursement authorization in writing (SWIFT or equivalent)?
• [ ] A2: Does the authorization reference the correct credit number?
• [ ] A3: Does the authorization specify the correct currency and amount?
• [ ] A4: Does the authorization name the correct beneficiary (requesting bank)?
• [ ] A5: Does the authorization include any "on receipt" or "on demand" conditions? (If yes, reject — prohibited under Article 37(a))
• [ ] A6: Is the authorization issued by the issuing bank or its authorized agent?
• [ ] A7: Does the authorization conform to all terms and conditions of the credit?

Section B: Compliance Declaration Review

• [ ] B1: Has the requesting bank provided a signed declaration?
• [ ] B2: Does the declaration confirm that documents have been presented?
• [ ] B3: Does the declaration confirm that documents comply with the credit terms?
• [ ] B4: Is the declaration signed by an authorized officer of the requesting bank?
• [ ] B5: Does the declaration reference the correct credit number and amount?

Section C: Reimbursement Request Completeness

• [ ] C1: Does the reimbursement request specify the amount claimed?
• [ ] C2: Does the request specify the currency?
• [ ] C3: Does the request reference the reimbursement authorization?
• [ ] C4: Has the requesting bank provided SWIFT confirmation of presentation (MT734 or equivalent)?
• [ ] C5: Are all data elements in the request consistent with the authorization and the credit?

Section D: Reimbursing Bank Internal Compliance

• [ ] D1: Has the reimbursing bank confirmed that the request conforms to the authorization terms?
• [ ] D2: Has the reimbursing bank refrained from demanding document examination? (Article 37(c))
• [ ] D3: Has the reimbursing bank processed the request within a reasonable timeframe?
• [ ] D4: Has the reimbursing bank provided payment confirmation or acknowledgment?

Section E: eUCP-Specific Checks (if applicable)

• [ ] E1: Does the credit specify eUCP applicability?
• [ ] E2: Has the reimbursement authorization referenced eUCP 2.1?
• [ ] E3: Have electronic documents been presented in compliance with eUCP format requirements?
• [ ] E4: Has the requesting bank confirmed the integrity and authenticity of electronic documents?

Deterministic Resolution Architecture

Step 1: Complete Sections A–E Before Submission

Do not submit a reimbursement request until every checkbox in the applicable sections has been verified. Incomplete submissions create delays and expose the requesting bank to rejection.

Step 2: Flag and Resolve Non-Compliant Items

For any item that fails verification, document the specific discrepancy and take corrective action before submission. Common corrective actions include requesting an amended authorization, obtaining a compliant declaration, or correcting data mismatches.

Step 3: Retain Documentation

Maintain a complete file of all checklist items, supporting documents, and correspondence related to the reimbursement. This file serves as evidence in the event of a dispute.

Step 4: Submit With Confidence

Once all items pass verification, submit the reimbursement request with a transmittal letter referencing the completed checklist. This signals to the reimbursing bank that the request has been thoroughly vetted.

Conclusion

This examination checklist operationalizes Article 37's requirements into a repeatable process. Banks that apply it consistently will reduce rejection rates, shorten reimbursement cycles, and maintain compliance with UCP 600 obligations.

Frequently Asked Questions

1. What if the reimbursement authorization contains a prohibited "on receipt" condition?

Do not submit the reimbursement request. Contact the issuing bank and request an amended authorization. Submitting a request under a prohibited condition may result in indefinite delays.

2. Can the reimbursing bank add conditions not present in the authorization?

No. The reimbursing bank's obligations are limited to the terms of the reimbursement authorization (Article 37(c)). Any additional conditions imposed by the reimbursing bank are inconsistent with UCP 600.

3. Is the checklist mandatory under UCP 600?

UCP 600 does not prescribe a specific checklist format. However, using a standardized examination protocol is considered best practice and is recommended by the ICC Banking Commission.

4. How should the checklist be adapted for confirmed credits?

For confirmed credits, the confirming bank may also request reimbursement. The checklist applies equally — the confirming bank must provide a compliant Article 37(b) declaration.

5. What documentation should be retained after reimbursement?

Retain the credit instrument, the reimbursement authorization, the Article 37(b) declaration, the reimbursement request, SWIFT messages, payment confirmations, and all correspondence. A minimum retention period of five years is recommended.

Source Notes

Context only — no primary source text was extracted for this guide. All references to UCP 600, ISBP 745, and eUCP 2.1 are based on the well-known published rules. Source URLs from the batch data point to ICC and ICC Academy publications: "UCP 600 - Uniform Rules and Practice for Documentary Credits" (ICC, 2023); "Certified UCP 600 Specialist (CUCP)" (ICC Academy, 2025); "Uniform Rules for Documentary Credits (UCP 600) - eBook" (ICC Academy, 2024); "Commentary on UCP 600" (ICC, 2019).