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The Payments Industry
Risk, Compliance & Analytics Services
Private & Confidential
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BMR Advisors
Identified Concerns
Trends & Risks
Earnings Assurance
Process Automation
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Trends & Risks
Earnings Assurance
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Services for the payments industry - BMR Advisors

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The Payments Industry (Payment processors, digital wallets, online transfer, financial institutions and digital currency players) is one of the most exciting and globally relevant sectors of growth. BMR Advisors has worked extensively in mitigating and confronting the risks & challenges in this space.

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Services for the payments industry - BMR Advisors

  1. 1. The Payments Industry Risk, Compliance & Analytics Services
  2. 2. Private & Confidential Page 2 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services BMR Advisors One Microsoft Tax & Advisory Risk & Advisory Mergers & Acquisition Legal Support Deliveredin 40+ countries 7 Locations USA Largestclientbase 3 Centersof Excellence AlliancePartners 40+ Partners Global Delivery Advantage 600+ Employees Experts & experienced consultants 750+ clients engaged Tier 1 Ranked Tier 1 in ITR’s World Tax 2014 guide to the world’s leading tax firms 250+ Fortune 1000 clients served Right-Shoring Choice of on-ground & offshore BMR was founded in 2004 by a group of former Arthur Andersen and EY partners. We are now recognized as one of the top 5 firms in India Chartered Accountants, MBAs, CPAs, ACAMS, ACL Specialists, SAP Specialists, CISA, CCISPL and CFE Ranked as a leading tax law firm by The Legal 500, Asia- Pacific Guide 2013 2+ million hours delivered to date Rated as a Great Place to Work in India Extensive engagements in AML, KYC and Analytics for Global Clients Industry Focus Energy, Financial Services, Retail Technology, Media, Communications, Infrastructure, Real Estate & Japanese Business Group Rated third most active transaction advisor in India by VCCedge League Table for FY2013 40% professionals abovemanager level BMR Advisors
  3. 3. Private & Confidential Page 3 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Our Services Risk & Advisory •Process & Performance Improvement •Risk & Control •Due Diligence •Analytics •AML & Financial Compliance Direct Tax •Transfer Pricing •Tax Litigation •Transaction Tax/ Restructuring •Corporate & International Tax •Expatriate Tax •Tax Policy & Advocacy •Tax Outsourcing & Compliance Services Indirect Tax •Advisory •Compliance •Litigation M&A •Corporate Finance •Transaction Support •Transaction Tax/ Restructuring •M&A Legal Legal Support •M&A Support •Direct Tax Litigation •Indirect Tax Litigation •Advocacy •Documentation Japanese Business Group Retail Energy Financial Markets Technology Media Real EstateManufacturing Process Financial Legal Structuring Tax CompetenceServiceLinesIndustry BMR Advisors
  4. 4. Private & Confidential Page 4 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Strategic Partnerships & Recognitions Ranked second Most Active Transaction Advisor (Private Equity) by Venture Intelligence League Table for Q1 2011 Rated as a Great Place to Work in India, 2010 Great Place to Work ® Institute Rated Tier 1 Tax Transactional Firm for fifth consecutive year by International Tax Review’s online poll, 2012 BMR ranked sixth (by deal count) in Thomson Reuters Mid-Market Insight, Jan-Sep 2012 Rated third most active transaction advisor by Venture Intelligence League Table for the first half of 2012 BMR Legal Ranked among the top Indian legal tax firms by the Chambers and Partners in the Asia-Pacific Guide 2012 Rated Tier 1 Tax Transactional Firm for sixth consecutive year by International Tax Review’s online poll, 2013 BMR Advisors ranked third leading financial advisor in India for the year 2012 by Thomson Reuters Mid- Market survey BMR Advisors rated as Number One transaction advisor by VC Edge for the year ending 2012 BMR Legal ranked as a leading tax law firm by The Legal 500, Asia- Pacific Guide 2013 Ranked as a Tier 1 Firm in India, International Tax Review, World Tax Survey 2009 2009 2010 2011 2012 2013 Ranked Tier 1 in ITR’s World Tax 2014 guide to the world’s leading tax firms 2014 BMR Alliance Partners 2015 Ranked Tier 2 in ITR’s World Transfer Pricing 2014 guide Most Active transaction advisor for Private Equity and M&A by Venture Intelligence Ranked Tier 1 in ITR’s World Tax 2015 guide to the world’s leading tax firms, 8th year in a row Ranked Tier 2 in ITR’s World Transfer Pricing 2015 guide BMR And Community The firm has a strong commitment to community service. As much as client service, we endeavor to fulfil our social responsibility under the aegis of BMR Foundation. Through our ‘Go Green Initiative’, we adopt environment-friendly practices at our workplace. We actively support initiatives such as SOS Children’s Villages of India, Indian Red Cross Society and MillionTreesGurgaon. BMR Advisors
  5. 5. Private & Confidential Page 5 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Our Clients | Financial Services Asset Management AIG Fidelity ING JP Morgan Chase Templeton Banking ABN AMRO Bank AIG American Express Bank Barclays Bank of America BNP Paribas Citigroup Corporation Bank Deutsche Bank HDFC Bank HSBC IDBI Bank ING Bank JP Morgan Chase Ratnakar Bank Royal Bank of Scotland State Street Standard Chartered Sumitomo Mitsui Banking Corporation Templeton Toronto-Dominion Toyota Financial Services Insurance Birla Sun Life Insurance ICICI Prudential ING Vysya PNB MetLife Baer Capital Blackstone Carlyle CVC Englefield Capital GIC Helion Ventures Henderson Halcyon ICICI Ventures IDFC Private Equity India Value Fund Lazard Mandala Capital Motilal Oswal New Vernon NVP Och-Ziff Old Lane Q Investments Sage Shriram Transport Finance Temasek Warburg Pincus Real Estate Funds Actis Aditya Birla Real Estate Fund Ascendas The Chatterjee Group IREO Deutsche Realty Kotak Realty New Vernon Realty Red Fort Capital Solitaire Capital Investment Banks ADM Capital Citigroup Credit Suisse Deutsche Bank Merrill Lynch NM Rothschild Goldman Sachs JPMorgan Lehman Brothers Morgan Stanley UBS Private Equity Alchemy Partners Apollo Investment Corporation BMR Advisors
  6. 6. Private & Confidential Page 6 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Our Clients | Non-Financial Services 24/7 Customer ABB Group Accenture Actaris ADM Capital Airtel Airwide solutions Alstom Apple Computers Assa Abloy AstraZeneca Avaya BAF Baker Huges BD BEA Systems BHP Billiton Biocon BlueDart Blue Foods BP Amoco Brightpoint British Gas Broadcom Cadbury Plc. Calleo Canon Cargill CGG Chevron Cisco Systems Claris Lifesciences Limited CNBC Continental Airlines Dabur Daikin EagleBurgmann Enfield Enpro Jubiliant Equant ExxonMobil Fujifilm India General Motors Genpact Goodyear Gujarat Gas GIC GMR Group GSK HDFC Chubb Helmerich & Payne Heidelberg Cements HP Hutch IBM ICA Domus Trust Indigo Airlines Ingersollrand Intel Interglobe Enterprises Itochu Corporation Ivy Comptech K Raheja Corp. Kennametal Widia Kobelco Cranes Kodak Lear Corporation Levi Strauss McKinsey & Co. Metal One Mindtree Consulting Mitsubishi Corp Mitsubishi Material Mosbacher NCR Corporation NDS Nokia Novartis Novo Nordisk Premier Oil Oxigen Panasonic Pepsi Perot Systems Petronas Quest Radhakrishna Reuters Regulatory Data Corp Reliance Industries Ltd Rolex Samsung Sanyo Schlumberger Shell SIA Engineering Socomec Sojitz Sony Star TV Sumitomo Chemicals Sumitomo Corporation Suzuki Synova Tally Teletech Ten Sports Texas Instruments Thomson Uni Products USV Valtech VSNL Xerox Yum! BMR Advisors
  7. 7. Private & Confidential Page 7 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Risk & Advisory | Key Services Anti-Money Laundering Anti-Bribery Compliance Intellectual Property Monitoring Risk & Advisory Data Analytics Process Development & Optimisation Internal Audit Process Integration Securitization Support Data Assets Impact Analysis Fraud Investigations Fraud Assessment & Prevention Fraud Analytics Financial & Tax Business Analysis Third Party Ecosystem Risk Management Framework Online, Mobile & New Age Crimes BMR Advisors
  8. 8. Private & Confidential Page 8 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Introduction ► The Payments space in India is going through an exciting phase ► With exponential growth, customer acquisition and increasing adoption by merchants/buyers/service providers, a number of risks are emerging ► It is possible to identify over 50 typologies of risks and concerns being faced by organizations in this space ► There are a variety of technologies, tools, processes and skills required to combat them ► Combined with growth pressures, fast changing and dynamic landscape, many organizations continue to struggle with developing solutions to mitigate risks BMR Advisors has developed robust, evolving and comprehensive risk oriented offerings, which align with the requirements of players in the Payments Space Introduction
  9. 9. Private & Confidential Page 9 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services ► Payment gateways, wallets and processors, across the globe struggle to operationalize compliance resources because of the breadth, depth & variance of their geographic & socio- economic connections. ► Extensive & varied exposure to dynamic regulatory and jurisdictional laws and regulators  FDA, European Medicine Agency and Therapeutic Goods Administration (TGA) for prescription drugs  Drug Enforcement Agency for illegal drugs  Copyright and trade mark laws for Intellectual Property Infringement  Legal cases and events for Counterfeiting  Diverse Trade Associations ► Exponential growth of the E Commerce business is causing stress on the system and payment processors alike, therefore leaving gaps open for proliferation of felonious activities. ► Invisible customers and Merchants. Payment gateways are facing customers without the rigor of due diligence maintained by banks. Most Payment processors and gateways verify clients post activation of the account. ► Dynamism of technologies and mediums in which they operate. Acclimatizing to this dynamism yet retaining a share of the market pie is a huge challenge for payment gateways and processors alike. ► Innovative techniques of willful defaulters, offenders & fraudsters. Investigators, Regulators & Payment Processors, usually find themselves playing catch-up with the evolving methodologies employed to circumvent existing checks & surveillance. Concerns & Issues of the Payments Industry Identified Concerns
  10. 10. Private & Confidential Page 10 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Categories ABC XYZ PQR Products which require medical prescriptions P P P Adult goods and services P P P Counterfeit and Unauthorized goods P P P Drugs, Endangered Species (plants/animals) P P P Gambling, Hacking and Cracking Materials P P P Weapons / Firearms P P P IP Infringement O P P Illegal Drugs & Paraphernalia O P P SMS based services P O O Alcohol P P P Body Parts P O P Unsolicited email messages' software P O O Copyright unlocking devices P O P Illegal and Offensive Goods, Securities (stocks/bonds/financial products) P P P Tobacco and Cigarettes P P P Multi-level marketing / Work-at-home P P O E-cigarette O P P Circumvention Products (Rippers, Emulators etc) O P P Credit / Mugshot Repair O P O Offensive (Nazi swastika etc) O P P Event Tickets O P P Encouraging Illegal Activity (human, sythetic urine) O P O Online Dating O P O Fraudulent Business O P O Real Estate O P P Automotive ( Motor vehicles, (VIN) plates etc) O O P Cash Equivalents, and Gift Cards, Currency, Coins O O P Electronics (Phones with bad (ESN), Micro SIM) O O P Hazardous & Dangerous Items O O P Jewelry & Precious Gems (Non Compliant) O O P Payment processors have been classified as money transmitters and require to comply with guidelines defined under  the BSA and Patriot act  Regulatory associations and departments To comply, all payment processors define a user policy that outlines do’s and don'ts of payments routed through them. The table alongside provides categories which the payment processors monitor to ensure compliance as required. Trends on the rise High Risk Priority Category Gaming applications offer virtual goods or currencies as credits which can be redeemed during in-app purchases. In order to bring a control, google has made it mandatory for such applications to use google play ‘s in-app billing service as a method of payment. Google, Windows and Apple are all offering wallet services which will enable cleaner application markets and a higher degree of PCI compliance. Merchants disguise violating products in numerous ways such as,  Neutral marketing  Not disclosing ingredients banned by FDA while listing pharmaceutical drugs,  Drug paraphernalia is sold in unrelated markets such as retail shopping websites. Merchants disguise payment mechanism by asking prospective clients to contact the seller through an email ID, once the deal is confirmed, the actual payment details are divulged. Adult service domains often indulge in these mechanisms of payment. ABC – Major Indian Payment Processor XYZ – Major Global Payment Processor Industry Trends Trends & Risks
  11. 11. Private & Confidential Page 11 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services 45,380 domains had active payment processors and gateways. These were screened for violation as per the user policy. 12,410 of these domains were classified as red flags at the initial screening stage and 2,976 (24%) were in violation as per our clients. USA, 64% Britain, 6% Russia, 6% Australia, 6% Germany, 5% Netherland s, 4% France, 3% Canada, 3% Sweden, 3% Spain, 1% Server Hosts of Concern  Top 10 countries that host the servers for 84% of the violating domains are illustrated below.  Observations from extensive projects related to screening rogue websites which violate IP regulations or user policies of payment processors. Case Study | BMR monitored over 1,00,000 domains from the perspective of IP infringement, online frauds, sanctions and payment due diligence. 2947 1765 1280 1032 533 567 396 1061 410 600 553 593 416 221 36 0 5000 10000 15000 20000 Counterfeits Prescription Drugs Alcoholic Beverages Firearms Illegal Drugs & Paraphernalia Mature Audience E-cigarettes Encouraging Illegal Activity IP Infringement Gambling Circumvention Products Adult Content Get Rich Quick Tobacco Other Compliant Red Flag Breakup of Cases & Identified Red Flag Cases Highlights | Cases of Violations • Counterfeits account for 37% of the violations • Prescription drugs like Viagra lead to 16% • Alcohol shipping to USA or from Japan, USA or Australia account for 10% • Firearms accounts to 7% of the violations • Marijuana or marijuana dispensaries and drug paraphernalia such as bongs and water pipes account for 5% of violations • Websites catering to adult content account for another 5% Insights | Based on our Work Trends & Risks
  12. 12. Private & Confidential Page 12 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Customer Client Seller Purchases Other resellers Client website Merchant website Payments Delivery Customer • Customer Identity • Source of funds • End use of purchase • Frauds Merchant Website as a Payment Processor • Merchant Identity • Regulatory breach • User Policy breach • Merchant’s controls & due diligence • Frauds Client as the Seller • Regulatory breach • User Policy Breach • Frauds • Purchaser identity Other Re-sellers on Client Site • Regulatory breach • User Policy breach • Frauds • Seller identity and linkages • Seller controls & due diligence Identified Risks | Payment Processors Trends & Risks
  13. 13. Private & Confidential Page 13 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Our Services | Addressing Risks for the Payments Space The Risk Program Third Party Risk Online Monitoring Fraud & Risk Analytics Process Automation Earnings Assurance Our services and offerings have been structured to ensure holistic and comprehensive coverage of all aspects of the present & emerging risk, frauds and compliance challenges. Anti-Money Laundering Our Relevant Services
  14. 14. Private & Confidential Page 14 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services New technologies and the evolution of criminal activity has led to the development of sophisticated methods to launder the proceeds of crime. Our Offerings AML Compliance Setup Transaction Monitoring Enhanced Due Diligence Sanctions Compliance FATCA Compliance Coverage Experience with two top Wall-Street banks covering over 240 jurisdictions, with 25+ countries delivered on ground. 30+ language capabilities and regulatory know-how on BSA and Patriot Act. AML Compliance Setup Transaction Monitoring Enhanced Due Diligence Sanctions Compliance FATCA Compliance Ensuring adherence to organizational, regulatory and relevant KYC/AML norms for customers/third parties including remediation, audit and process setup Identify suspicious activities, review controls and utilize analytics capabilities to assist clients to optimize their thresholds on alert monitoring Research based Due Diligence Reports based on updated legal, sanctions, media, registration information etc. created by an experience team of experts Setup, Test & Execution of processes for Clients/Customers/ Third Parties against Local, National, International and other Sanctions Lists Identification, classification, calculation, withholding and reporting, account remediation, designing & testing of documentation, withholding & reporting Anti-Money Laundering Users Banks, NBFCs, Payment Services, E-Commerce Companies, Financial Services, Investment Banks, Digital Wallets, Online Transaction Gateways & Payment Processors. Anti Money Laundering Our Relevant Services
  15. 15. Private & Confidential Page 15 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services With the increase in economic activity, migration of offline businesses to online and cultural acceptance of transactions in the online space, a number of risks have emerged owing to the avenues of fraud, slippages and anonymity Our Offerings KYOM Outsourcing Rogue Websites & Application Monitoring Screening Services Industry & Product Due Diligence Social Listening for Risk Coverage Experience with a leading global payment processor. 30+ language capabilities. Regulatory know-how on BSA, Patriot Act, multiple industry and jurisdictional compliances Know Your Online Merchants Outsourcing Industry and Product Due Diligence Rogue Websites and Applications Monitoring Screening Services Optimizing cyber footprint to ensure merchants and business vendors are in line with business objectives and risk appetite. Research based Due Diligence at the product level. Ensuring compliance with guidelines and sanctions laid by industrial and jurisdictional governance bodies. Monitoring rogue websites / applications which may be involved in money laundering, fraud, counterfeit, malware, illegitimate & content theft Regulatory, Operational, Financial & Reputational risks covered by red flag identification based on defined rules, requirements and scope of coverage Users Banks, NBFCs, Payment Services, E-Commerce Companies, Financial Services, Investment Banks, Digital Wallets, Online Transaction Gateways & Payment Processors. Online Monitoring Services Social Listening for Risk Monitoring of Social Media, Blogs, Forums and other unstructured information sources to indicate and assess probable red flag areas across supply chains Online Monitoring Our Relevant Services
  16. 16. Private & Confidential Page 16 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services The growing complexity, geographic spread and dependency on Supply Chains has led to multiple risks emanating due to the actions of either business partners or market & environmental developments beyond organizational control. Our Offerings Supplier/Vendor Due Diligence Business Partner Due Diligence Supply Chain Red Flag Monitoring Financial & Business Stability Regulatory Checks & Litigation Review Coverage Multiple Due Diligence & Risk Monitoring projects undertaken on Customers & Business Partners of clients across markets & geographies. Supplier/Vendor Due Diligence Business Partner Due Diligence Supply Chain Red Flag Monitoring Financial & Business Stability Holistic Due Diligence of Global Supplier/Vendor base to create a comprehensive & comparative scorecard on defined risk & business parameters Holistic Due Diligence of Business Partners, Dealer/Distributor base to create a comprehensive & comparative scorecard on defined risk & business parameters Continuous Red Flag monitoring related to global geographies, markets, regulations, business partners, clients, outlier events, risk & related scenarios Assessing the Financial & Business Stability of a Third Party at Empanelment or Renewal stage with coverage of both financial & non-financial parameters Third Party Risk Regulatory Checks & Litigation Review Determining regulatory charges, watch lists or sanctions checks, in addition to unearthing pending or disposed litigation matters including bankruptcy Third Party Risk Program Development of a comprehensive & holistic third party risk assessment program for an organization based on business realities & regulatory requirements Users Banks, NBFCs, Payment Services, E-Commerce Companies, Financial Services, Investment Banks, Digital Wallets, Online Transaction Gateways & Payment Processors. Third Party Risk Our Relevant Services
  17. 17. Private & Confidential Page 17 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Setting the Business Context  Revenue leakages in an online payment services company is typically attributed to the inability to accurately bill for a delivered service or receive accurate payments.  Intricate revenue chains comprising of multiple sets of inter- related technologies and processes, to provide a seamless set of services to the end consumer, add to the complexity.  As the set of technologies and business processes grows bigger and more complex, the chance of failure increases in each of its connections. Our Solution  Our customized tool provides companies the ability to move from the current segmented Revenue Assurance model to a robust Earning Assurance Program.  This program facilitates the company in focusing on continually improved process performance through both incremental and innovative process & technological changes/improvements. A risk based strategy is defined to evaluate the coverage of Revenue Assurance at specific intervals of time. Data Integrity Checks Access Management Data Sanitization Disputed Transactions Report Generation The tool is customized to include requisite data integrity checks to ensure accuracy of the data uploaded in the model Customized access levels for all resources utilizing the tool. A separate functionality to provide audit logs has also been incorporated. The tool can accommodate raw data in any form due to the automated data sanitization functionalities in-built in the tool A detailed log of all un-reconciled and disputed transactions is maintained till reconciliation Based on management requirement, the tool has the capability to provide detailed MIS and reports. These can be linked to automated email messages to a pre-defined group of recipients The final deliverable – Specifications of the Tool Earning Assurance Program | Automated Reconciliation Tool Users Banks, NBFCs, Payment Services, E-Commerce Companies, Financial Services, Investment Banks, Digital Wallets, Online Transaction Gateways & Payment Processors. Earnings Assurance Our Relevant Services
  18. 18. Private & Confidential Page 18 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Our Solution  Independent review of critical processes covering the business activities, people responsibilities and technological capabilities  Enhancement of segregation of duties matrix to ensure that critical business activities are adequately separated  Redesigning the process by focusing on the ‘ground-up’ design of the business activities in a bid to meet the business objectives  Establishment of ‘standardized’ access rights for employees as per their job responsibilities  Tangible value creation along with guiding and extending support for the revised business processes  Implementation and deployment of standardized business processes  Formalizing the mechanism to handle business exceptions Ten Commandments 1. Physical segregation of conflicting roles 2. Skill set alignment with job profile 3. Automated processes 4. Change in role definition 5. Workflow for approvals and exceptions 6. System alert configuration 7. Dashboards 8. Complete visibility of the transaction trail 9. Inability to tamper files 10. Effective fraud management The final deliverable – New Way of Life Implementation Support Roll-out and tracking against implementation timelines and responsibility matrix Critical Process Automation Users Banks, NBFCs, Payment Services, E-Commerce Companies, Financial Services, Investment Banks, Digital Wallets, Online Transaction Gateways & Payment Processors. Process Automation Our Relevant Services
  19. 19. Private & Confidential Page 19 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Setting the Business Context  Over the past few years, numerous instances of bribery, graft and fraud amongst multi-national corporates, have come to the fore.  Such instances have triggered intense regulatory investigations resulting in the imposition of expensive fines on corporations  In this context, more companies than ever before are seeking to consolidate their governance programs, with a specific focus on instituting appropriate internal controls and good governance Our Solution  BMR Risk has developed a comprehensive range of analytics based forensic services that can help companies in understanding the extent of misappropriation  This further assists in taking a long-term view of corruption and fraud risk management, and adopt a comprehensive framework to mitigate risk Setting the Control Environment Data Identification Transaction Analytics Risk Mitigation Planning Conduct interviews with the process owners to understand the enterprise business and assess controls required and monitoring frequency. Identify relevant data. Map and sanitize data into normalized databases that facilitate analytics. Identify the various scenarios of “What can go wrong” and perform data analytics to substantiate the impact of red flags. Perform predictive analytics and other patterns to identify fraud indicators. Perform Risk Profiling of exceptions. Efficient resolution of all exception cases Provide recommendations of process improvement and Cases to be sent to Legal / Compliance for further investigation Implementation Approach Fraud & Risk Analytics Users Banks, NBFCs, Payment Services, E-Commerce Companies, Financial Services, Investment Banks, Digital Wallets, Online Transaction Gateways & Payment Processors. Fraud & Risk Analytics Our Relevant Services
  20. 20. Private & Confidential Page 20 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services The Risk Program Setting the Context  Players in the payments space face some of the greatest risks across the spectrum, owing to business pressures, exponential growth, payment mediums and inherent liability regarding the quality and outcome of the transaction  A number of risks are related to frauds, chargebacks, third parties, collusion, lack of consumer understanding and even deviant mobile apps  To design a risk function around such negative events leads to a continuous game of catchup, while still leaving the organization open to rapidly evolving risk typologies Our Solution  Develop a holistic and comprehensive risk program for your organization, based on defined scientific, analytics and probabilistic parameters  The program will be designed to ensure seamless tech and human engagement and leverage, with an aim to tackle the underlying risk issues rather than individual events.  The program will be defined based on the business needs and realities of the organization Risk Based Framework KYC & Due Diligence Screening Transaction Monitoring Training Major Components of the Program Users Banks, NBFCs, Payment Services, E-Commerce Companies, Financial Services, Investment Banks, Digital Wallets, Online Transaction Gateways & Payment Processors. Financial Crimes & Regulatory Compliance Fraud, Risk and Negative Issue Scenarios Analytics and Testing Combines all the introduced offerings along with other solutions, specific to the Payments Industry, into a cohesive, holistic and scalable risk program The Risk Program Our Relevant Services
  21. 21. Private & Confidential Page 21 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Anti-Bribery Compliance Our Work Anti-Corruption Directory for UNODC • Developed a comprehensive database of Central and State Government departments and officials • Exhaustive database of detailed profiles of 10,000 officials • Easy to use web platform for managing the directory of 10,000 Central / State officials • Weekly and monthly updates on changes observed in country specific political events Development of a global PEP repository covering • Close to 1 million PEPs • Across 200+ countries/ territories • Expertise around Languages • One of the largest and most comprehensive PEP Databases • Over 150+ professionals contributed to the development • Used by Bank & Financial Services Organizations Globally • Comprehensive Database development rules and methodologies created Anti-corruption Policy Framework • Conducted a high level risk assessment to understand the potential exposure areas of Company’s business operations • Gap analysis between existing anti-bribery policies & the results • Strengthened procedures around identified high risk exposure areas • Enhanced corporate policies setting forth specific due diligence and documentation requirements for relationships with foreign officials and third party agents Baseline FCPA compliance review for US Multinational • Conducted an analysis of transactional activity included in the company’s books and records, in order to identify, any anomalies, that may have indicated unexplained payments or bid manipulation • Evaluated the adequacy of internal controls that existed around the in- scope review areas • Formulated a remediation action plan to plug-in the identified internal control lapses Online Monitoring Merchant compliance review for global Payment Processor • Regular monitoring of online merchant’s adherence towards corporate policies such acceptable use policy etc. • Monitoring of infringing and rogue websites & mobile applications across 18 primary violation categories • Designed processes to research alleged rogue websites associated IP Infringement, Money Laundering and other copyright violations Cross-industry registry of potential rogue websites • Client wanted an analysis to see how many partners are accessing medium and high risk sites • Purpose was to notify client on these high risk sites • Developed a risk-relevant intelligence regarding rogue websites, intellectual property theft, cybercrime etc. • Established risk scoring model quantifying various components of risk and ranking of each entry Anti-Piracy solution for Major Hollywood studios • Project oriented towards curbing copyright infringement, including sharing of copyrighted works via peer-to-peer file-sharing networks. • Established auditable framework for flagging each potential rogue site and a network around it. • Quantified the risk associated with such networks • Use of database as a source of auditable intelligence – rather than as a “black list” Brand Monitoring for comprehensive surveillance • American fashion designer brand wanted an online brand surveillance solution • Identification and analysis of online rogue network selling counterfeit products of this label carried out • Analysis and review of unauthorised product sales across all online channels such as rogue websites, marketplaces, social- networking sites etc Our Work
  22. 22. Private & Confidential Page 22 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Forensic Investigation Our Work JV of leader in the energy sector & Indian Promoter  Management received an anonymous letter regarding Questionable transactions by Indian promoters  Interest of foreign partners limited to monthly MIS and equity infusion  Inadequate background checks on the promoter before Investment  Detailed transaction analysis and employee surveys  Determined the key fraud indictors around Procurement, Inventory and accounting  Established fraud by Promoters Leader in the organized market for kids apparel  Allegations of financial mismanagement  Conducted process walkthroughs and detailed discussion  Analyzed critical cost components to establish their completeness, accuracy and authenticity  Conducted sales and inventory analysis  Identified compromised control checks, inflated sales figures  Established over/under valuation in the Balance Sheet & manipulation of accounts Indian bank faced with whistleblower allegations  Several whistleblower complaints against a senior executive  Quantified the loss suffered as a result of the corrupt practices  Conducted discreet and overt interviews of current and former employees of the bank  Analyzed over 10 suspicious procurement transactions  Identified the corrupt business practices with certain vendors  Established the modus operandi of received kickbacks Fraud committed by Traders  Entities acting in concert along with a clutch of trading outfits  Funding for the procurement was being routed through C&F agents  Quantities procured were transferred to one entity to control the stock position in the market  Established the relationships between the buying clients, selling clients, agents  Established the source of funding of the related entities  Verified Background, general reputation and track records Efficiency Diagnostics for one of the Top 10 Infocom company • Assisted in the development and implementation of a strategy to improve subscriber profiles and paying patterns • Conducted in-depth analysis of business performance data and process designs to identify gaps – this resulted in significant improvement in collections • Adopted the RACI (Responsibility, Accountability, Consult and Inform) model to assess employee empowerment Security risk & IT Review and Advisory | SOX • Conducted IT diagnostic review of entire wireless business support system including application and interface controls, data integrity, production support & system performance review and software development life cycle process • Conducted IT General Controls review • Documentation for SOX compliance Revenue Assurance Review and Dashboard • Identified and quantified revenue leakages through data analytics by conducting root cause analysis for identified risks and firming up action plans and Implementation support • Developed a root cause database for intuitive exception resolution • Automated key RA reconciliations • Designed RA dashboards which enabled the RA team to focus on exceptions Process Improvement • Detailed Review of Finance, Admin & HR functions at the company’s captive IT BPO operation • Particular focus on integration of processes and controls with the parent company in Europe • Developed a proposal of RA organizational structure, defining roles and responsibilities and recommending an implementation roadmap Process Consulting Our Work
  23. 23. Private & Confidential Page 23 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services BMR Value Proposition Global Effective Project Management Flexible Delivery Mechanism Thought Leadership Extensive experience working with global institutions and an understanding and knowledge of relevant regulations, systems, databases involved in these large-scale, multi-location projects. Our team comprises professionals with experience in the Big-Four as well as leading banks and are based out of India. This One-Global Team has led to significant cost benefits for our Clients. We have developed a flexible operational model, that caters to Client needs with complete data confidentiality/integrity along with effective coordination and project management. These include on-ground and in-premises models. High level of engagement of the senior team, with complete focus on problem definition, solution development and its implementation. An extensive emphasis on building knowledge of trends, regulations, processes and technology ensures that the team develops & executes pioneering & best-in-class engagements for Clients globally. Value Proposition
  24. 24. Private & Confidential Page 24 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Risk & Advisory Leadership Sanjay Mehta Partner & Head of Risk & Advisory Services sanjay.mehta@bmradvisors.com SANJAY MEHTA is a Partner with the firm, leading the Risk and Business Advisory practice. With over 30 years of experience of advising large Indian and multinational corporations – of which he spent nearly 15 years with Arthur Andersen, and a further 3 years with Ernst & Young. He became a partner in Andersen in 1995, and subsequently became Audit Head and national leader for the Business Risk Consulting Practice. Sanjay contributed to Andersen’s success by leading several pioneering initiatives in the US, Europe, Africa and the Middle East. Most Significantly, he led the Telecom practice for Arthur Andersen & EY for the APAC region. Sanjay is currently the Firm’s leader for Due Diligence assignments, spanning a number of industry sector. His experience in financial statements, business process reviews, due diligences, performance measurement work, revenue enhancement techniques, cost reduction and work practices review, reengineering and strategic consulting helps him provide clients with practical business advice. Sarabjeet Singh Partner Risk & Advisory Services sarabjeet.singh@bmradvisors.com SARABJEET SINGH is a Partner in the Risk and Advisory Services practice at BMR and is an expert in the Banking and Financial Compliances and Utilities Finance Systems, having spent over 9 years working on State Electricity Board clients. Prior to joining BMR in 2006, he worked for nine years at Arthur Andersen and a further 3 years at Ernst & Young. He has over 21 years’ professional experience, delivering a wide range of services in accounting, due diligence reviews, internal audit, financial reporting processes, solution development and analytics. Sarabjeet has also been primarily involved in assurance reviews and audits of large multi-location clients, formulating and implementing financial accounting packages, policies and practices, operational and financial controls review and financial systems related fraud investigations. He has extensive experience in AML/KYC matters across geographies and has implemented global AML/KYC solutions for large financial institutions and multinational banks. Partner with extensive consulting experience in Anti-Bribery, Analytics & Process Partner and head of Risk Advisory practice with noted leadership in Telecom at the APAC level The BMR Team
  25. 25. Private & Confidential Page 25 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services The Team MEETA CHOPRA has 9 years of experience of advising large Indian and multinational corporations. She has a vast experience in several service offerings including AML & KYC Remediation, Vendor Due Diligence, Forensics Investigations, Internal Audits, Risk assessment and Standard operating procedures. Meeta has gained diverse experience and knowledge of various industries including banking & financial institutions, wind power, insurance, software, hotels, healthcare, manufacturing and other sectors. Associate Director with extensive experience in Process Automation, Fraud Review & Anti-Money Laundering Meeta Chopra Associate Director HARKISHAN BHATIA is a Chartered Accountant, a Company Secretary and a Cost & Work Accountant by qualification and has over 14 years’ experience of advising large Indian and multinational corporations. He has worked on a range of assignments including investigation of serious frauds, developing functional frameworks, SOP documentation and implementation, Risk assessment reviews, ERP Reviews and Internal Audits. Also involved in number of process review projects for different business functions covering assessment of controls, defining authority matrix and management of exceptions. He has been involved in designing of functional framework and standard operating procedures for large number of blue chip companies across globe Director with consulting experience in Fraud Review, Process Implementation & Functional Frameworks ABHISHEK BALI has over 7 years of experience in areas related to Anti-Money Laundering, Anti-Bribery, Third Party Risk, Online monitoring and Database Services. He has assisted clients with developing data assets, executed AML Reviews for foreign clients, deployed third party risk solutions and contributed in global outreach exercises. He has also assisted Startups and High-growth companies in coming to terms with their Risk Management practices His other areas of work are related to Supply Chain - Risk Consulting, Risk Management Programs, Enterprise Risk Management, AML, Social Listening and Due Diligence. Abhishek has managed and carried out projects for clients across industries like Oil & Gas, Manufacturing, Technology, Banking, Automobile, Heavy Engineering, Startups, Cement, Private Equity, Venture Capital & Hospitality. Vice President with extensive experience in Anti-Money Laundering, Anti-Bribery and Database Services Harkishan Bhatia Director Abhishek Bali Vice President The BMR Team
  26. 26. Private & Confidential Page 26 BMR Advisors Identified Concerns Trends & Risks Earnings Assurance Process Automation The Risk Program Fraud & Risk Analytics Online Monitoring Our Work The BMR Team Value Proposition Third Party Risk Anti Money Laundering Introduction Our Relevant Services Contacts This presentation has been prepared for clients and firm personnel only. The information contained in this document is for general information purposes only. While the firm endeavors to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the document or the information provided therein. All information contained in this document may be acquired from publically available sources and hence any reliance you place on such information is therefore strictly at your own risk and the firm accepts no liability in relation to the use of the document. The firm reserves copyright of this document and hence, does not allow anyone to sell, re-publish or re-distribute the document or derivatives thereof. © Copyright 2015, BMR Business Solutions Pvt. Ltd. All Rights Reserved Sanjay Mehta Partner +91 981 003 7000 sanjay.mehta@bmradvisors.com Sarabjeet Singh Partner +91 991 034 5454 sarabjeet.singh@bmradvisors.com Abhishek Bali Vice President +91 783 838 3549 abhishek.bali@bmradvisors.com

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