lot of things can cause this, I've had this error when doing:
Trying to send money from an unusual ip address
trying to purchase something to an unusual address (gift address, ebay different address etc)
trying to send a relatively bigger amount (account history's biggest amount - around 400$) to a relatively new paypal account (stealth account)
etc...
Lots of things can cause this. Try splitting payments, but do not try it a lot of times...
paypal even logs uncompleted send money forms, and if you try it a lot of times, you will get limited...
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