Anti-Fraud Policy / Антифрод-политика

Company: NetGain Solutions  |  Location: Hong Kong

1. Purpose and Scope
This Anti-Fraud Policy (“Policy”) establishes the principles and framework to prevent, detect, and 
respond to fraudulent or abusive actions related to the operations of [Company Name], a Hong Kong–registered IT company acting as a Payment Facilitator. 

2. Legal Framework
This Policy complies with applicable Hong Kong legislation, including the followingacts:
- Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615)
- Personal Data (Privacy) Ordinance (Cap. 486)
- Payment Systems and Stored Value Facilities Ordinance (Cap. 584)

3. Definitions 
Fraud is any intentional act or omission made for unlawful gain or to cause loss to the Company, 
its clients, or partners. Examples include payment manipulation, account takeover, identity fraud, synthetic IDs, and unauthorized access.

4. Principles 
• Zero tolerance to fraud and corruption.
• Reliance on trusted anti-fraud systems and partners’ frameworks.
• Transparency and accountability in all financial flows.
• Confidentiality and data protection.
• Continuous review and improvement.

5. Shared Responsibility with Partners 
The Company may rely on its partners’ anti-fraud mechanisms and monitoring systems 
to ensure payment security. Each partner, payment gateway, or acquiring institution is responsible for 
maintaining its own compliance and fraud prevention procedures.

The Company ensures that all such partners:
1. Maintain up-to-date fraud detection and AML systems;
2. Adhere to KYC and data verification procedures;
3. Provide regular reporting on fraud-related incidents;
4. Notify the Company of any fraud breaches impacting transactions.

6. Preventive Measures 
Technical and operational measures include:
- Transaction and behavioral monitoring;
- IP, device, and geolocation analysis;
- Encryption, access restriction, and secure data storage;
- Partner risk scoring and onboarding verification.

7. Incident Response 
Suspicious activity must be reported to the Compliance Officer within 24 hours. 
The Company may suspend operations, initiate investigations, and coordinate with partners’ anti-fraud teams.

8. Liability 
Employees, partners, or clients found engaged in fraudulent activity may face disciplinary, 
civil, or criminal consequences. Partners bear liability for fraud caused by their negligence or system failure.

9. Policy Review and Approval 
This Policy is reviewed annually and approved by the Company’s senior management.

Director : Cojuharenco Maxim
Date:  28.02.2025