Fraud Monitoring Policy – Wiztoss Pty Ltd

Wiztoss is committed to maintaining a robust fraud monitoring framework which integrates preventive controls, real-time detection, and comprehensive escalation and resolution processes. Our program is designed to address fraud risks in both domestic and cross-border remittance services, ensuring compliance with regulatory obligations while safeguarding customers.

This Fraud Monitoring Policy operates as a supporting component of Wiztoss’s broader AML/CTF Program and focuses specifically on fraud detection, prevention, and response.

1. Identity Verification and Risk Controls (Preventive Controls)

• All customer onboarding undergoes full identity verification using GreenID, aligned with KYC standards.
• Identity verification is renewed annually. Expired identification documents automatically trigger re-verification requests via GreenID.
• Customers and recipients are screened against OpenSanctions lists (Sanctions, RCA, PEP) on an annual basis to maintain ongoing due diligence.

2. Behavioral Anomaly Detection (Automated and System-Assisted Detection Rules)

• Failed login attempts exceeding predefined security thresholds may automatically lock the user account to prevent unauthorized access.
• Customers exceeding predefined transaction frequency thresholds automatically trigger Source of Funds (SOF) verification requests.
• Customers reaching defined transaction monitoring thresholds (daily/monthly/annual) trigger mandatory SOF review.
• Login attempts from high-risk or sanctioned countries are automatically blocked.
• Beneficiary account duplication (i.e. multiple senders remitting to the same beneficiary account) triggers system flags for internal review.

3. Remittance and Beneficiary Structure Validation

• Our system validates consistency between the remitter’s registered identity and the bank account used for payment.
• If discrepancies are detected, customers are directly contacted via secure messaging (KakaoTalk) for identity confirmation prior to releasing the first remittance.
• Beneficiary accounts linked to multiple unrelated senders are flagged and reviewed to prevent possible money mule or third-party misuse scenarios.

4. High-Risk Triggers & Customer Notification Process

• The following conditions automatically trigger SOF review:
  • Exceeding transaction volume or frequency limits
  • High-risk customer classification based on internal qualitative Customer Risk Assessment
  • Reaching internal TM thresholds
• Upon activation of these triggers:
  • Customers are prompted to submit additional SOF documentation.
  • Transactions may be temporarily paused for compliance and fraud prevention purposes, in accordance with Wiztoss’s Terms and Conditions.
• Throughout the remittance process, customers receive real-time email notifications upon:
  • Submission of a remittance request
  • Administrator processing initiation
  • Completion of the remittance
• These notifications serve both operational and fraud-prevention purposes by enabling customers to identify any unauthorized activity promptly.

5. Escalation, Investigation & Resolution (Incident Handling Process)

• The Compliance & Operations Team reviews flagged transactions on a regular and ongoing basis.
• Where fraud indicators are detected, cases are escalated to the Compliance Officer for formal investigation.
• Investigation procedures include:
  • Full transactional history review
  • KYC profile revalidation
  • Customer outreach for additional documentation or clarification
  • Cross-checking sanctions screening and behavioral risk indicators
• If fraud is confirmed:
  • The transaction is suspended or cancelled immediately.
  • The customer account may be frozen pending further investigation.
  • The matter is escalated for formal reporting to AUSTRAC and, if necessary, law enforcement agencies.
• Documentation and record keeping include:
  • Timeline of events
  • Investigation actions taken
  • Findings and conclusions
  • Corrective and preventive measures implemented
• Periodic internal audits are conducted to review fraud cases, refine monitoring rules, and improve overall fraud prevention controls.

6. Governance and Oversight

• Fraud monitoring policies are embedded within Wiztoss’ broader AML/CTF compliance framework.
• Our internal governance is supported by:
  • Internal Compliance Officer oversight
  • Independent advisory support provided by an external AML/CTF adviser.
• Ultimate oversight of the AML/CTF and fraud monitoring framework rests with the Board of Directors and senior management.
• The compliance team will continue to actively monitor, enhance, and strengthen the compliance and fraud management framework as the business evolves and transaction volumes grow. This framework is subject to periodic review and ongoing refinement to ensure continued effectiveness and regulatory compliance.
• Material fraud risks, incidents, or control deficiencies are escalated internally in accordance with Wiztoss’s governance procedures.

7. Record Retention

All records relating to fraud monitoring, investigations, customer communications, and reporting outcomes are retained for a minimum of seven (7) years in accordance with AML/CTF record retention obligations. This retention period is required under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth).