Risk Management Considerations and Merchant Responsibilities

Merchants must ensure compliance with all applicable local laws and regulations.
Merchants must employ transaction monitoring mechanisms to detect anomalous activity, including fraud and money laundering, as well as the misuse of the disbursement for the payment of goods and services
Merchants must have a robust, bank reviewed and approved Anti-Money Laundering (AML) program in place in accordance with local laws and regulations.
Merchants must not disburse a daily amount greater than the amount held in their account used to fund disbursement activity. The account is generally opened at the Sponsor Bank and should be pre-funded with ~1 day of processing activity. TabaPay will set a daily aggregate disbursement limit and sends Merchant an alert once a certain threshold is reached (default 90%)
Merchants must provide appropriate terms and conditions, disclosures, fee information, transaction confirmation, receipts, and notifications to customers and users.

Required Transaction Receipt Content:
☐ Sender name ☐ Recipient name ☐ Sender’s payment credential (masked and/or truncated) ☐ Date and time of transfer ☐ Amount of transfer in the sender’s currency and/or recipient’s currency ☐ Total amount paid (i.e., amount of transfer plus any fees) ☐ Fees associated with the transaction ☐ Foreign currency conversion rates for cross-border transactions ☐ Sender Reference Number ☐ Description (e.g., Money Transfer)

Required Transaction Receipt Content:

☐ Sender name
☐ Recipient name
☐ Sender’s payment credential (masked and/or truncated)
☐ Date and time of transfer
☐ Amount of transfer in the sender’s currency and/or recipient’s currency
☐ Total amount paid (i.e., amount of transfer plus any fees)
☐ Fees associated with the transaction
☐ Foreign currency conversion rates for cross-border transactions
☐ Sender Reference Number
☐ Description (e.g., Money Transfer)

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A Merchant’s transaction monitoring system should consider the following:

Transaction limits

The geographies from and to which transactions are sent

Models of expected behavior for each account holder, including types of disbursements they send, frequency of disbursements and subsequent withdrawal activity, the number of disbursements, and the senders and recipients of the disbursements.

Accounts that may have historical suspicious activity should be monitored with enhanced due diligence.

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Examples of Suspicious Activity

Change in account credentials following out-of-pattern disbursement activity

Large volume of transactions immediately followed by cash withdrawals, conversion to monetary instruments, payments to a third-party or transfer of funds to a different account

Significant activity on account reactivated from inactive or dormant status which may or may not include subsequent withdrawals to deplete transferred money

Increasing volume of disbursements or significant fluctuations in type or volume of disbursements that are inconsistent with patterns identified in a customer’s profile

Several disbursements during the same day or over a span of a few days from the same sender (sender data is included in every disbursement) or different senders who share the same common identifiers such as family name, address, or telephone

Large disbursements from foreign jurisdictions not consistent with account activity or from countries known to be associated with terrorist activity

Upon receipt of disbursements, increasing volume of cross-border transfers or transfers to beneficiaries in countries known to be associated with terrorist activity

Recipient reports that they do not know the sender(s) of disbursements

Bust-Out/Sleeper Fraud: A fraudster opens an account and establishes a history of successful transactions over a period and then ‘busts-out’ of this pattern with large transactions.