services for the payments industry - bmr advisors

The Payments Industry

Risk, Compliance & Analytics Services

Private & Confidential

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

Delivered in 40+ countries 7 Locations

USA Largest client base

3 Centers of Excellence Alliance Partners 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 hoursdelivered 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 above manager level

BMR Advisors

http://www.taxand.com/



BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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 GroupRetail Energy

Financial

MarketsTechnology Media Real EstateManufacturing

Process Financial Legal Structuring Tax

Co

mp

ete

nce

Serv

ice L

ine

sIn

du

str

y

BMR Advisors


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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




tax firms

2014

BMR Alliance Partners

2015


World Transfer Pricing

2014 guide

Most Active transaction

advisor for Private

Equity and M&A by

Venture Intelligence




tax firms, 8th year in a

row


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



http://www.www.translink-int.com/

http://www.www.translink-int.com/


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


► 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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction

Our Relevant Services45,380 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%

Netherlands, 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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


• User Policy Breach

• Frauds

• Purchaser identity

Other Re-sellers on Client

Site


• User Policy breach

• Frauds

• Seller identity and linkages

• Seller controls & due

diligence

Identified Risks | Payment Processors

Trends & Risks


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


Our Services | Addressing Risks for the Payments Space

The Risk Program

Third Party RiskOnline

Monitoring


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.




BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


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


Users

Banks, NBFCs, Payment Services, E-Commerce Companies,

Financial Services, Investment Banks, Digital Wallets, Online

Transaction Gateways & Payment Processors.




BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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




Online Monitoring Services

Social Listening for RiskMonitoring of Social Media, Blogs, Forums and other unstructured information

sources to indicate and assess probable red flag areas across supply chains

Online Monitoring



BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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 ReviewDetermining regulatory charges, watch lists or sanctions checks, in addition to

unearthing pending or disposed litigation matters including bankruptcy

Third Party Risk ProgramDevelopment of a comprehensive & holistic third party risk assessment program

for an organization based on business realities & regulatory requirements

Users




Third Party Risk



BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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




Earnings Assurance



BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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




Process Automation



BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


Users







BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


Training

Major Components of the Program

Users




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



BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


Risk & Advisory Leadership

Sanjay MehtaPartner & Head of Risk &

Advisory Services

[email protected]

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 SinghPartner

Risk & Advisory Services

[email protected]

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

https://in.linkedin.com/in/harkishanbhatia2009





BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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 ChopraAssociate 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 BhatiaDirector

Abhishek BaliVice President

The BMR Team





https://in.linkedin.com/in/abhishekbali85

https://in.linkedin.com/in/abhishekbali85


BMR Advisors

Identified Concerns

Trends & Risks

Earnings Assurance

Process Automation

The Risk Program


Online Monitoring

Our Work

The BMR Team

Value Proposition

Third Party Risk


Introduction


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

[email protected]

Sarabjeet Singh

Partner

+91 991 034 5454

[email protected]

Abhishek Bali

Vice President

+91 783 838 3549

[email protected]

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