Anti Fraud Policy

This Anti-Fraud Policy establishes Riz Remit Limited's commitment to preventing, detecting, and responding to fraud in compliance with UK legal and regulatory requirements.

The policy aims to:

• Protect customers, agents, and the firm from fraud risks
• Ensure adherence to applicable laws and FCA expectations
• Promote a strong anti-fraud culture across the organisation

This policy applies to:

• All employees, directors, and senior management
• All agents, partners, and third parties
• All customers and transactions processed through Riz Remit

This policy is aligned with the following legislation and guidance:

• Fraud Act 2006
• Proceeds of Crime Act 2002 (POCA)
• Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 (as amended)
• Terrorism Act 2000
• Data Protection Act 2018 and UK GDPR
• FCA Principles for Businesses
• FCA Financial Crime Guide

Fraud: Dishonest conduct intended to make a gain or cause loss (financial or otherwise).

Consumer Fraud: Fraud where customers are deceived into sending money.

Agent/Partner Fraud: Fraud that causes loss to agents, partners, or the firm.

MLRO (Money Laundering Reporting Officer): Responsible for financial crime risk management and SAR submissions.

SAR (Suspicious Activity Report): A report submitted to the National Crime Agency (NCA) under POCA.

Riz Remit adopts a risk-based approach to fraud prevention by:

• Identifying high-risk customers, corridors, and transaction patterns
• Applying enhanced controls where risks are elevated
• Regularly assessing emerging fraud typologies

• Establish and maintain effective internal controls
• Approve anti-fraud strategy and policy
• Ensure adequate resources for fraud prevention

The MLRO has overall responsibility for fraud risk management, including:

• Maintaining the anti-fraud framework
• Submitting SARs to the NCA
• Monitoring fraud trends and emerging risks
• Reporting significant incidents to senior management
• Ensuring staff awareness and training

Legal Obligation: All suspicious activity must be escalated to the MLRO. Tipping off is strictly prohibited under POCA.

• Ensure effective controls within their functions
• Monitor fraud risks and control effectiveness
• Promote a strong compliance culture

• Adhere to this policy
• Identify and report suspicious activity
• Complete mandatory training
• Protect customer information

Failure to comply may result in disciplinary action, including termination and potential criminal liability.

Includes scams such as:

• Romance scams
• Advance fee fraud
• Lottery/prize scams
• Rental/property scams
• Tech support fraud
• Family emergency scams
• Employment scams
• Charity fraud

Includes:

• System compromise (malware, phishing, hacking)
• Fraudulent transactions initiated under false instructions
• Underpayment scams
• Remote access fraud

• Mandatory fraud warnings on transaction receipts
• Transaction refusal where fraud is suspected
• Enhanced due diligence for vulnerable customers
• Staff questioning to assess transaction legitimacy

In line with FCA expectations, Riz Remit will identify and support vulnerable customers, including those who are:

• Elderly
• Emotionally distressed
• Financially inexperienced
• Digitally excluded

Transactions may be declined where exploitation is suspected.

The firm will monitor transactions for:

• Unusual patterns
• Multiple rapid transactions
• Changes in customer behaviour
• Transfers to unrelated recipients

Agents must:

• Verify funds before processing transactions
• Keep credentials secure
• Lock systems when unattended
• Prevent screen visibility to customers
• Reject suspicious requests

• Up-to-date antivirus and firewalls
• Strong password policies
• Protection against phishing and malware
• Restricted system access

Staff should be alert to:

• Urgent/emergency requests
• Emotional or distressed customers
• Requests involving secrecy
• First-time or unusual transactions
• Customers unable to explain purpose
• Multiple repeat transactions
• Elderly customers sending funds to unrelated individuals

If fraud is suspected:

1. Question the customer appropriately
2. Refuse the transaction if necessary
3. Escalate immediately to MLRO
4. Record the incident

• All suspicions must be reported internally
• MLRO will determine whether to submit a SAR to the NCA
• Tipping off is prohibited

Upon identifying fraud:

• Suspend or refuse transaction
• Notify MLRO immediately
• Record incident in fraud log
• Submit SAR (if required)
• Report to Action Fraud
• Review controls and implement improvements

Fraud incidents will be reported to:

• Action Fraud: https://reporting.actionfraud.police.uk
• National Crime Agency (NCA): via SAR

• Mandatory induction training
• Annual refresher training
• Targeted training for high-risk roles
• Training records maintained for audit

• Regular internal audits of fraud controls
• Ongoing monitoring of transactions and agent activity
• Reporting findings to senior management

All personal data must be handled in accordance with:

• Data Protection Act 2018
• UK GDPR

Any data breach must be reported per ICO requirements.

The firm will retain records for at least 5 years, including:

• SARs
• Fraud reports
• Training records
• Transaction data

This policy will be:

• Reviewed annually
• Updated to reflect regulatory changes and emerging risks