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4  A SURVEY OF EXISTING RESEARCH/                  an evaluation as to the efficacy of these consumer mes-
             INITIATIVES ON UNLICENSED INVESTMENT             saging initiatives.
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             SCHEMES                                            Malaysia, for example had an outreach campaign to
                                                              warn consumers and which informed where specifically
           To date, the global financial inclusion stakeholders have   to check the registration status of an investment; also
           not dedicated much attention in terms of research, nor   telling consumers that the words Sharia compliant does
           concerted action to unlicensed investment schemes let   not necessarily mean licensed, and engaging religious
           alone to UDIS. This lack of research and related failure to   actors too to help inform the public.  This is a very good
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           act is problematic given the significant negative impact   idea, because fraudsters often use religious figures and
           of these frauds on consumers, markets and financial in-  gatherings to promote and sell their phony investment
           clusion.                                           schemes. The aforementioned Ugandan COWE scheme,
             Failure to act may also be related to the perception   for example hired a preacher’s wife to recruit investors.
           that  first,  the  buyer/consumer  should  beware  of  the   She signed up the entire 700+ member congregation
           dangers of Ponzi schemes, or should know better than   and after the Ponzi collapsed had to move out of the
           invest in such schemes. It may also relate to regulators   community. Indian  Ponzi schemes  have often used
           and policymakers feeling powerless to address the is-  cricket stars and Bollywood actors (who were perhaps
           sue. The author believes that both of these sentiments   unaware of the illegitimacy of the offer) to promote in-
           are misguided. In fact, little effort has been made to   vestments which later turned out to be fraudulent. A
           find new, technology based solutions, nor to under-  Bangladeshi Ponzi called Destiny which stole an esti-
           stand the behavioral motivations of consumers for   mated USD 75 million was chaired and promoted by an
           finding these schemes credible or worth the risk of in-  ex-Army general.
           vesting.  Are consumers emotions driving the invest-  Outreach and consumer education efforts must be
           ment decision-making process or do we have low fi-  continuous, but often warnings appear only upon the
           nancial literacy levels to blame, or both?  And if   collapse of a particular ponzi, at which time, the regula-
           emotions are driving the process, can they be coun-  tor will respond by posting a warning message to con-
           tered by similar emotional appeals to avoid making a   sumers on its website. This is too little; and too late to be
           bad investment decision?  If so, how could these warn-  useful to the masses who have already lost money.  And,
           ings be effectively crafted, and who should deliver the   even its deterrent impact on other consumers likely to
           message?  For example, would it be effective to use   invest in other similar schemes is also likely to be low,
           the same public figures; like actors, sports stars and   simply because they have been told that the collapsed
           religious leaders to warn consumers; as those used to   Ponzi was a fraud, but may not be able to identify other
           pitch investments schemes?  We can only speculate   future Ponzi schemes as such.  Further, relying solely on
           regarding the answers to the above, because this type   one channel of communication where there is a diverse
           of research has not been done.                     group of consumers with varying literacy levels and who
             Aside  from  the  aforementioned  IMF  research  on   may or may not have internet access is insufficient to
           Ponzis (2009); the Cornell University study on the im-  protect consumers.
           pact of Ponzis on investor trust which are specific to the   The Working Group did identify one effective meth-
           Madoff scheme, and an Emory University study on char-  od of educating the public of the dangers of Ponzi
           acteristics of the typical Ponzi investor, there is very lit-  schemes which was a bait site online published by the
           tle existing research on the matter. There are even fewer   US Federal Trade Commission. The web page offered a
           studies on UDIS, or on effective regulatory prevention   too good to be true investment offer leading consumers
           efforts.                                           who took the bait to enter their credit card details on
             The authors propose that much more research is   the site to invest in the scheme; at which point the web-
           needed. Firstly, research is required on the best practic-  page then flashed a warning message stating “you al-
           es in Ponzi prevention, including the use of new artificial   most lost all of your money” and then directed the con-
           intelligence technologies to better monitor markets to   sumer to an educational page explaining the dangers of
           identify these schemes. Secondly, research should en-  unlicensed investment schemes and how to recognize
           quire how the use of well framed messaging from influ-  the signs of a potential financial fraud.
           ential sources can warn consumers and impact behav-  Another unique method of reaching consumers was
           ioral change. There is also need for research to study the   reported by the Nigerian security exchange commission
           impact of UDIS on consumers and markets, in addition   to the International Organization of Securities Commis-
           to the erosion of consumer trust. Lastly, we should ex-  sion that it is in the process of developing a weekly soap
           plore what is the impact on financial exclusion in the me-  opera in Nigeria based on Ponzi schemes to educate the
           dium and long terms on consumers and markets.      public about the dangers of Ponzi schemes.
             With regard to consumer capability trainings or    These are all good examples, but consistency may be
           awareness raising, there are a few examples of how the   just as important as the content, and the efficacy of
           financial sector and securities regulators are trying to   messaging should be measured as well so as to not
           educate the public. However, again there has not been   waste funds on ineffective messaging.



           10 • Unlicensed Digital Investment Schemes (UDIS)
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