PST D7 - Fraud (Consumer Fraud)

Consumer fraud is a potential or actual theft of funds from a customer by means of deceit, trickery and/or manipulation. If you suspect that the customer is a fraud victim or perpetrator, ask them additional questions; refer to Probing Questions below. *Preventing fraudulent transactions from being completed protects customers, agents and MGI. *As an MGI representative, you can and should refuse processing send/receive transactions whenever transaction details match a known consumer fraud scenario; refer to Common Fraud Scenarios below.

If you deny/refund a transaction based on fraud concerns (transaction is potentially fraudulent), educate the sender accordingly and provide them with fraud prevention education; refer to Consumer Fraud Prevention Education below. *Important: remember that MGI employees and agents cannot directly accuse an individual of the fraudulent involvement.

Red Flags

• MoneyGram has implemented systematic transaction holds that are triggered when transactions are initiated and before they are received, in order to: *Enhance a consumer protection by attempting to verify if senders and receivers who use MGI products/services do not commit fraud, do not perform other foul activities and do not exceed internal/country-specific/regulatory-required thresholds, and *Adhere to compliance/regulatory requirements.

-As a result of the above, you should not suspect fraud on every transaction available for receive and ask probing questions on every call, but only when customer's behavior and/or explanations raise logical concerns. *Only such behavioral red flags, or behavioral red flags combined with transactional red flags should raise concerns and prompt further investigation; refer to the below grid for the list of potential red flags.

2 TYPES OF FRAUD: Behavioral Red Flags - Unwilling to answer questions, Sending to an unknown receiver, Sending with a third-party involvement, and Partial information on a transaction purpose and/or relationship between counterparties

Transactional Red Flags - Different names origin/place of birth and Transaction corridor

Probing Questions: Length of relationship Type of relationship (online or real-life) Purpose (remittance, purchase, investment, etc.) Circumstances behind a transfer and level of urgency (casual, urgent, sudden, etc.)

PROCEDURE: STAGE 1 - Gather a transaction purpose and relationship between the sender and receiver/third party, and compare them against common fraud scenarios and purposes characterizing them; refer to Common Fraud Scenarios below.

STAGE 2 - Proceed based on what you determined and who the caller is. *Potentially Fraudulent (Sender) - Advise them as per Consumer Fraud Prevention Education below. Complete Sender Refund. *Potentially Fraudulent (Receiver) - Inform them to have the sender call MGI for further assistance. Complete Placing Transaction on Hold.

STAGE 3 - Ensure the case description includes all the information gathered from the customer and justification of your decision.

COMMON FRAUD SCENARIOS

• Church, Charity
• Coyote
• Credit Card, Advance Fee
• Employment
• FTC Refund
• Immigration
• Inheritance
• Internet/Animal Purchase/Other Purchase
• Investment
• IRS, Imposter
• Loan
• Lost and Found
• Lottery
• MGI Prize
• Mystery Shopper
• Overpayment
• Person in Need
• Proof of Funds
• Rental Deposit
• Romance
• Windows, Malware

Consumer Fraud Prevention Education *Provide a customer with the below explanation guidance. - MGI and its systems are dedicated to ensuring customers' security, and preventing them from losing their funds. - Your transaction has been reviewed and based on the available information, MGI determined that it closely resembles past scam scenarios where our customers lost their money. - As a result, your transaction appears unsafe for you and MGI, and therefore we decided that we will not process it and only make it available for a refund.

*In addition to the above explanation, advise a customer of the below to help them avoid being victimized in the future. - Do not send money to anyone you do not know. - Screen your calls and make sure your callers are genuine. - Never provide confidential information to strangers calling. - Change your phone number or reach out to your phone company to block specific calls/numbers. - Instructions to mislead/not provide truthful responses to MGI are a clear warning sign that something might be wrong; if someone tells you to not share details of your transaction with MGI, do not continue with the transaction. - If needed, seek help from local organizations, Law Enforcement and your family members; refer to Victim Resources.