Fraud Monitoring Policy – Wiztoss Pty Ltd

Overview

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.

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 Detection Rules)

• Failed login attempts exceeding 10 within 1 hour automatically lock the user account to prevent unauthorized access.
• Customers conducting more than 3 remittance transactions within a calendar month 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 profile scoring via internal Customer Risk Assessment
  • Reaching internal TM thresholds
• Upon activation of these triggers:
  • Customers are prompted to submit additional SOF documentation.
  • Transactions are paused pending verification.
• 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 daily.
• 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 behavior scoring data
• 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.
• If fraud is confirmed:
  • 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 external AML/CTF adviser Mr. Sumeer Pai (retainer-based).
• 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.
• Additional external monitoring tools (e.g. CheckMarble integration scheduled by July) are being implemented to further strengthen transaction monitoring capabilities.