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ITU-T Focus Group Digital Financial Services
                                               Consumer Experience and Protection



                    b)  false transactions – agents transfer a consumers funds to their own account

                    c)  registration fraud – creating false accounts for the purpose of obtaining extra registration commissions
                    d)  overcharging – agents charging unauthorised or incorrect fees
               3    Internal – fraud which may be committed by an internal employee

                    a)  internal fraud – employees colluding for unfair personal gain
                    b)  identity theft – employees accessing and exploiting customer information without authorisation
               Examples of when fraud has occurred include lottery scams in Bangladesh where users were told they must
               send a fee in order to gain access to their winnings. In Uganda cases of reversal requests were reported
               where SMS requests were sent to users informing them that funds had been incorrectly deposited in their
               account and that they should return them (McKee, Kaffenberger, & Zimmerman, 2015). While the occurrence
               of fraudulent activity is relatively low the perception of the threat of fraud is high. The key issues for fraud
               prevention are described below:


               Table 3: Fraud prevention issues
                          Key issues                                   Examples

                1. DFS PROVIDERS ARE LICENSED   DFS can only be provided by licensed entities (banks and non-banks) and are
                AND SUPERVISED UNDER A REGU-  regulated by the financial regulator. The DFS provider is required to adhere to
                LATORY FRAMEWORK             the licensing requirements at all time.
                2. REGULAR NETWORK TESTING,   To prevent and detect fraud there should be ongoing checks to ensure that
                REAL-TIME MONITORING AND     information systems and applications are working correctly.
                ONGOING CHECKS FOR SECURITY
                SYSTEMS AND PROCESSES
                3. DUE DILIGENCE TO BE CON-  Due diligence is carried out on all staff (employees, contractors, agent etc.)
                DUCTED ON STAFF AND AGENTS   prior to hiring.

                4. PROVIDERS ARE RESPONSIBLE   Providers are responsible for the conduct of their agents, ensuring providers
                FOR THEIR AGENTS             effectively manage and train their agents.

                5. AGENT MONITORING          To ensure that agents comply with regulations and guidelines their activities
                                             are monitored by providers. This may be done through onsite checks or mys-
                                             tery shopping. Clear sanctions are in place for agents who are found to be not
                                             complying.
                6. AGENT TRAINING            Providers ensure agents are trained to a high standard to reduce the chance of
                                             errors occurring and to be able to offer knowledgeable support to consumers.
                                             Ideally training should be compulsory and ongoing.

                7. TRANSACTIONS OCCUR IN REAL   When the network is down, consumers sometimes leave money with agents to
                TIME                         carry out the transaction later. This can leave customers open to agent fraud,
                                             if the agent instead keeps the money. Real time transactions would cut down
                                             on this type of fraud, though in many geographical areas real time transactions
                                             are still challenging in practice.
                8. CONSUMERS ARE ENCOURAGED  Consumers are aware of and understand the process to report suspected inci-
                TO REPORT FRAUDULENT ACTIVITY  dences of fraud to their provider or to financial and telecom regulators.
                9. CONSUMER AWARENESS CAM-   Consumers are informed of the common types of frauds prevalent in the
                PAIGNS ON THE COMMON TYPES   market through various channels (such as SMS alerts, radio announcements,
                OF FRAUD                     signage at agent location etc.).









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