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.

1. The Payments Industry
Risk, Compliance & Analytics Services

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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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