How to Implement
Guidance

Put in place an independent dispute arbiter.
The Scheme establishes an independent body to be a final arbiter (an Ombudsperson) of disputes between DFSPs and between DFSPs and customers when they are unable to determine whether a fraud has occurred or to determine liability. The arbiter includes women staff and makes it easy for a woman end user to reach those staff, if preferred.

Mandate fraud detection and management requirements for DFSPs.
The Scheme rules mandate that DFSPs should have processes or tools in place to capture and analyze transaction data to identify patterns that may indicate a transaction is suspicious and assign a risk score to indicate the likelihood that it may be suspicious.

Provide tools for funds refunds in cases of fraud.
The Scheme rules should also specify how funds are returned in the case of a confirmed fraudulent payment. Separate identification allows these transfers to be differentiated from other instant payments and also allows for tracking and analysis of the volume and value of confirmed frauds in the Inclusive IPS.

Provide risk management rules and tools.
The Scheme should support DFSPs by providing clear and detailed rules on strong risk management processes, providing tools for DFSPs to use, and sharing data and information to enable the tools and operational controls to be most effective.

Share data on fraudulent payments.
The Scheme rules promote continuous improvements in fraud mitigation by ensuring that DFSPs share data on confirmed frauds in on-us and off-us transactions.

Require complaint and resolution mechanisms by DFSPs.
The Scheme requires DFSPs to provide complaint and dispute resolution mechanisms for end users that are clearly communicated through various methods that include video and voice tools in local languages, are easy to find and to use, are freely available, and are appropriate to all end users in the local context.

Apply fraud definitions framework.
The Scheme provides a framework for defining fraud types that is used by DFSPs when sharing data on confirmed frauds.

Require DFSP controls on internal fraud.
The Scheme requires DFSPs to implement controls designed to prevent a DFSP employee from perpetrating fraudulent payments.
Why It Matters
This provides a set of standards to keep the Inclusive IPS safe and sound by preventing fraud from occurring in the first place, and if it does, to minimize its impact.
Seeing More Clearly
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Women’s Inclusion
Women face higher incidences of being defrauded, often have lower levels of fraud prevention training, and have an overall lower level of trust in digital payments. They especially benefit from Scheme rules that set strong fraud mitigation requirements for DFSPs.
Fraud Mitigation
Regulatory guidelines are helpful in highlighting expectations for strong fraud management, but they do not usually define DFSP requirements for participating in specific payments system (exceptions exist). The Inclusive IPS’ Scheme rules play a key role in providing that specific guidance and raising the bar on risk management and contributing to end user trust in the system.

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