Fraud Awareness Policies and Procedures

Purpose

To protect consumers from fraudsters who engage in fraudulent transactions, Anh Minh Money Transfer has established policies and procedures to enable agents, management, and employees to become aware of fraudulent activities and fraudulent red flags and mitigate those fraudulent activities.

The Scope of the Issue

According to the Commissioner’s supervisory memorandum “The use of wire transmitters by telemarketers and scam artists in and outside the United States to defraud consumers has become increasingly prevalent in the past few years and more and more cases of fraudulent wire transfer activity is being seen today. These scam artists tend to prey on elderly individuals but also target any person who is willing to provide money for the obtainment of promised lottery winnings, game prizes, advance-fee credit cards, loans, merchandise, or a variety of other assets. Vulnerable consumers are tricked into sending substantial sums of money through schemes involving contests, sweepstakes, and advance fee credit card loan scams. Scam artists normally require the consumer to send cash via wire transfer for a promise to deliver the goods to the consumer. But unfortunately, consumers are left empty-handed and soon realize that they have been scammed by unscrupulous telemarketers and other crooks whose sole goal is to steal money”.

Fraud Risk Assessment and Implementation of Wire Fraud Consumer Awareness Programs

Being a holder of money transmitter license, and conducting business through authorized delegates, Anh Minh Money Transfer realizes the risk associated with this type of activity. Having high and sound AML/BSA compliance standards in place, Anh Minh Money Transfer’s Compliance Department controls, and monitors daily operations in order to protect itself from being used for criminal’s illicit conduit as well as protect our consumers from becoming a victim of fraud. The conduct of business transactions through appointed independent agents increases the risk of potential wire transfer fraud. Therefore, it is Anh Minh Money Transfer’s responsibility to mitigate this risk by ensuring that awareness regarding wire fraud is brought to the frontline of compliance defense, and educating employees, agents, and consumers about scam artists’ activities.

Consumer Warning

Anh Minh Money Transfer requires its agent to post the copy of Anh Minh Money Transfer’s Consumers Fraud Awareness Notice at the agency location. The agent is mandated to conspicuously post these documents so that they are readable for a consumer (with 20/20 vision) conducting a transaction. Below is the language for the disclosure contained in Anh Minh Money Transfer’s consumer warning notice:

Are you sending money to unknown persons or companies.

• 
    Are you sending money to someone you cannot verify their identity.
  
    Are you providing personal financial information to someone you do not know.
  
    Are you sending money to claim a foreign prize, lottery or to claim large sums of
  
  cash.
  Are you responding to an internet offer or phone offer unless you can confirm that the offer is legitimate.
  
    Are you sending money because you were "guaranteed" a credit card or loan?
  If so, ask the teller to stop your transfer immediately, or call (Anh Minh. at 1-714-893-
  
  4348.) If your money has not been picked up yet, it will be returned to you. Fraud Red Flags
  
  Telemarketing Scam – Someone you do not know calls requesting advance payment or personal information to obtain a benefit that is never delivered.
  
  Grandparent Scam – someone calls or sends email identifying as a relative or a grandchild requesting money to be sent for payment of emergency medical bills, kidnapping or some other financial emergency.
  
  The prize Promotion Scam – Request for advance payment or taxes in order to receive a prize or lottery winning.
  
  Advance Fee Scam – Fraud occurs when you send money to some unknown person on the promise to receive a gift, contract, or loan and receive nothing in return.
  
  The Counterfeit Check Scam – Someone sends a check in an amount larger than what the check was supposed to cover. Sender requests that excess balance be transferred immediately.
  
  Fraud prevention good practices
  
  Anh Minh Money Transfer’s employees and its agents are required to be alert for possible transactions conducted by fraud victims. Any time an employee or an agent detects fraud or possible fraud attempt on its consumers, please call the fraud hotline 1-714-893-4348 to file a report. in the event an Anh Minh Money Transfer employee or an agent suspects fraud, the employee or agent should remind the consumer to refrain from:
  
    Sending money to unknown persons or companies.
  
    Sending money to someone you cannot verify their identity.
  
    Providing personal financial information to someone you do not know.
  
    Sending money to claim a foreign prize, lottery or to claim large sums of cash.
  
  Responding to internet offer or phone offer unless you can confirm that the offer is legitimate.
  
    Sending money because you were "guaranteed" a credit card or loan?
  

If so, ask the teller to stop your transfer immediately, or call (Anh Minh. at 1-714-893-4348.) If your money has not been picked up yet, it will be returned to you.

Consumer Education

Currently, Anh Minh Money Transfer is conducting business exclusively through authorized delegates and branches. In order to help consumers understand the dangers of fraud through wire transfers, Anh Minh Money Transfer will post the warning stated above in all Anh Minh Money Transfer branch and agent locations.

Reimbursement Policy

The consumer is entitled to reimbursement of wire principal amount and associated fees for money transferred that has not yet been paid to the beneficiary for consumers who make a reasonable claim that the transfer was fraudulently induced. The reimbursement would only take place when the money transferred has not been paid out to the beneficiary.

Agent and Employee Training

Current agent and employee training programs describe the “red flags” associated with fraudulent wire transfers and ways to recognize if a consumer may be a victim of wire fraud. This information is included in the training Power Point Presentation, and Agency Welcome Package disseminated to agents upon Anh Minh Money Transfer’s approval.

Agency Termination

Anh Minh Money Transfer shall terminate agents that are involved in fraudulent transfers or who deliberately avoid the knowledge of fraud conducted (willful Blindness). The same principles shall apply to employees exposed in fraud-induced transfers or who deliberately avoid the knowledge of fraud conducted (willful Blindness). The closure or suspension of an agent shall take place if the reasonable measures to prevent the fraud discovered by Anh Minh Money Transfer have not been implemented.

Blocking of Transfers

Upon receipt of the law enforcement authority notice regarding occurring or potential fraudulent transfer Anh Minh Money Transfer shall block the suspected transaction unless instructed otherwise by the notifying agency. Anh Minh Money Transfer` shall contact the sender with information on potential scam occurrences. In case the consumer still wishes to proceed with the transaction in question, Anh Minh Money Transfer shall complete the transaction, and notify the informing party if the transfer is resumed.

Sharing of Complaint Information

In the case that money transfer was proved to be fraud or deception induced, Anh Minh Money Transfer shall seek the permission of the consumer to share the complaint information with the state regulatory agencies and United States law enforcement officials.