Unusual Consumer Activity

Overview

MGI has established a robust systematic control environment to monitor high-risk consumers for unusual patterned transaction activity that falls outside of the company's tolerance for risk; this environment includes, but is not limited to CRR Model, Top Down Rules, Targeted Alert Rules (CEP), and other front and back-end controls. Furthermore, it is subject to quality control, rules governance, monitoring testing and independent audits, which gives us additional confidence in its effectiveness.

As a result of these established processes, MGI does not generally require its agents and call center representatives to refer to us a consumer transaction activity when the only reason for such referrals would be the information that MGI is already aware of and monitors; this includes consumer transaction patterns and personal information recorded in transaction fields/drop-downs at the time of transaction. Therefore, such referrals, if any, are consequently closed.

Important

Any type of unusual consumer activity can result in money laundering, consumer fraud/scams, terrorist financing, illicit behavior and/or other violations that MGI is required to prevent; whenever you encounter any of these activities, make sure to report them via Compliance Referral Form (refer to Submitting CRF), but also consider asking follow-up questions to understand the transaction nature, however limit those questions to those relevant for decision-making only.

You are required to provide referrals containing information that would otherwise be unknown to MGI based on transaction data, e.g. you noticed that a customer was being coached by a third party, agent observed a customer engaging in a questionable activity prior to transacting (such as a possible drug sale/purchase), you learned that a customer sends money originating from illegal sources, etc.

Accepted vs Unusual Consumer Activity

Accepted Customer sends money to a friend/acquaintant/family member to support them. Customer sends money worldwide, to any destination country that supports MGI services. Customer sends money for business purposes to a business partner; refer to Country Pages for general country restrictions.

• Important: you should ask probing questions to eliminate any potential fraud scenarios; refer to Consumer Fraud, Probing Questions section. Customer sends money for emergency that requires their funding. Customer sends money for a confidential reason to someone they know in person. Customer uses MGI services for constant needs (daily, weekly, monthly, yearly, etc.). Counterparties have different name origins but know each other. Customer cannot fully and clearly explain transaction and/or activity details due to communication issues (e.g. they are not fluent in English, they are an elderly person, etc.). Customer sends money for humanitarian aid.
• Important: you should ask probing questions to eliminate any potential fraud scenarios; refer to Consumer Fraud, Probing Questions section.

Unusual

• Customer was instructed by a stranger to send or receive money on their behalf, but they do not know the source of these funds and/or suspect they may come from illegal sources.
• Customer sends amounts that significantly exceed:

• Actual needs based on transfer reasons, and/or
• Funds they could have accumulated by performing a declared profession, or obtained from declared sources of funds.

• Customer sounds confused and/or does not have a suitable knowledge on the nature/purpose of the initiated transaction.
• Customer receives many small incoming transfers from numerous countries/counterparties and/or initiates a large outgoing transfer without a proper justification.
• Customer attempts to buy a product/service that requires paying a commission, tax, down payment, etc. from an unknown person, e.g. US customer purchases an animal located in Mexico, counterparties do not know each other, product is considered non-portable and cannot be shipped to US.

Process

1. Complete the below process to assist a caller.

• Open a Consumer Support case as below; refer to Opening Consumer Support Case.

• Case Reason: Transaction Assistance
• Sub-Reason: Transaction Status Check
• Subject: Unusual Activity
• Description: enter the purpose and relationship, and identified red flags.
• Case Owner: MGO GEN

• Proceed to the next stage.

1. Proceed based on who you are speaking with. When you are speaking with...Sender
   Then...Proceed to Stage 4.

When you are speaking with...Sender Then...Proceed to Stage 4.

When you are speaking with...Receiver, agent or third party Then...Proceed to the next stage.

1. Ensure you are speaking with the receiver, agent or third party.

• Identify the transaction status/scenario and proceed as per below grid.

Transaction Status: Available

• You observe an unusual consumer activity while speaking to the receiver or receive agent.
• Agent, customer's family member or any third party acting on behalf of the sender calls to report an unusual consumer activity.
• Agent calls to report an unusual consumer activity.

1. Complete Placing Transaction on Hold.
2. Advise the caller that MGI needs to speak with the sender.

Transaction Status: Received or Pre-Transaction

• You observe an unusual consumer activity while speaking to the receiver or receive agent.
• Agent/customer's family member calls to report an unusual consumer activity.
• Agent calls to report an unusual consumer activity.

1. Open a Consumer Support case as below; refer to Opening Consumer Support Case.

• Case Reason: Transaction Assistance
• Sub-Reason: Transaction Status Check

1. Save and close the case; refer to Closing Case.
2. Complete Compliance Referral Form.

Transaction Status: Received

1. Complete Fraud Case - Transaction Received.

2. Ensure you are speaking with the sender.

• Note: if the transaction is on hold and you need to submit Compliance Referral Form, do not submit it until you have worked all the holds.
• Identify the transaction status and proceed based on the scenario.