Fraud

This Fraud Policy outlines the framework and procedures implemented by Yeeld Technologies LTD ("Yeeld" or "the Firm") to prevent, detect, and mitigate fraudulent activities in accordance with the relevant regulations, including but not limited to Money Laundering Regulations. The purpose of this policy is to establish clear guidelines for the prevention of fraud and to provide a structured approach for addressing fraudulent activities if they occur.
YEELD recognises that it has a duty to prevent any of its customers from falling victim to fraud through the use of the Firm’s services. Subsequently, YEELD pledges to allocate sufficient resources to the Firm’s internal controls, monitoring systems, human resources and staff training to prevent financial crime.
YEELD does not tolerate fraud in any form. The scope of the Firm’s zero-tolerance approach encapsulates all individuals, including management and employees of the Firm.
Any fraudulent behaviour, whether through wilful intent to defraud or negligence in preventing fraud, is unacceptable, and the individual(s) responsible will be subject to strict disciplinary measures.

When creating this policy, the Firm considered trusted industry best practices for fraud prevention, as well as its legal and regulatory duties under the UK regulatory regime. YEELD has taken into account the Fraud Act 2006, Proceeds of Crime Act (POCA) 2002, Economic Crime and Corporate Transparency Act 2023, Criminal Finances Act 2017, Consumer Rights Act 2022, UK-GDPR, and the FCA’s Financial Crime Guide (FCG).
The Firm is also aware of the near-final legislation that requires payment firms to slow down payment processing when there are reasonable grounds to suspect fraud. This underscores the Firm’s commitment to combating fraudulent activities within its payment services operations.
In addition, YEELD will apply the relevant rules and guidance detailed within the FCA’s Principles for Businesses (PRIN) and the Senior Management Arrangements, Systems and Controls’ (SYSC).
YEELD will remain vigilant in monitoring regulatory developments and adapting its fraud prevention strategies to ensure compliance with evolving regulatory requirements and industry best practices.

The definition of fraud referred to in this policy is derived from the criminal definition in the Fraud Act 2006, referring to the act of gaining a dishonest advantage, often financial, over another person. Under the Fraud Act 2006, a person can commit fraud by:
- False representation: Dishonestly making a false representation;
- Failing to disclose information: Dishonestly failing to disclose information when under a legal duty to disclose it;
- Abuse of Position: Dishonestly abusing one’s position with the intent;
- To gain for oneself or another, or cause loss to another or expose another to a risk of loss.
- YEELD acknowledges that there are many different types of fraud, including:
  - First-party fraud – fraud committed by an individual or group against a Financial Institution (FI) or business for personal gain.
  - Second-party fraud– fraud involving two parties refers to an individual or a group authorising another party to use their legitimate details, resulting in illegal activity.
  - Third-party fraud – fraud committed by a third party with the use of their victim’s information harvested without their knowledge or consent and used for the scammer's gain.
- Although there is no one defined way to categorise fraud typology, fundamentally, every type of fraud is either organisational or individual. Therefore, fraud can also be grouped in the following manner:
  - Against individuals - when a fraudster targets a single person — including identity theft, phishing scams and Ponzi Scheme and “advance-fee” schemes.
  - Internal organisational fraud - when an employee, manager or executive of an organisation deceives the organisation itself, i.e. embezzlement, cheating on taxes, and lying to
    - Market Abuse (e.g. market manipulation).
    - Phishing.
    - Insider trading
    - Identity theft.
- Relevant to YEELD’s business model, fraud may include, but is not limited to:
  - Theft or misappropriation of assets owned or managed by YEELD;
  - Submitting false claims for payments or reimbursement;
  - Accepting or offering a bribe or accepting gifts or other favours under circumstances that might lead to the inference that the gift or favour was intended to influence an employee's decision-making while serving the Firm;
  - Blackmail or extortion;
  - 'Off the books' accounting, or making false or fictitious entries;
  - Knowingly creating and/or distributing false or misleading financial reports;
  - Payment of excessive prices or fees where justification thereof is not documented;
  - Violation of the Firm’s procedures with the aim of personal gain or to the detriment of the Firm;
  - Wilful negligence intended to cause damage to the material interest of the Firm; and
  - A dishonourable or, reckless or deliberate act against the interests of the Firm.
Clients engaging in fraudulent behaviour to exploit vulnerabilities in the payment process. Examples include identity theft, account takeover, or the use of stolen payment credentials to conduct unauthorised transactions.
External vendors or suppliers involved in the payment ecosystem collude with individuals within the firm to perpetrate fraud. This could involve submitting inflated invoices, billing for fictitious services or kickback schemes to divert funds unlawfully.
Fraudulent actors outside the Firm target YEELD or its clients for financial gain. This includes various forms of cybercrime, such as phishing attacks, malware infections, or social engineering tactics to compromise payment systems, steal sensitive data, or defraud clients.

The Board plays a crucial role in fraud prevention by providing oversight, setting the tone at the top, and establishing a culture of integrity and ethical conduct within the organisation. This includes:
- Policies and Procedures: The Board of directors is responsible for establishing robust fraud prevention policies, procedures, and controls that govern YEELD’s business activities. This includes defining acceptable business practices, specifying authorisation levels, and outlining segregation of duties to minimise the risk of fraud.
- Risk assessment and management: Setting the Firm’s risk management strategy to mitigate fraud risks.
- Monitoring and oversight: Monitoring the Firm’s performance in preventing and detecting fraud by reviewing reports, MI and KPIs, ensuring that the Firm complies with relevant laws, regulations, and industry standards related to fraud prevention.
- Whistleblowing: Oversight of the implementation of whistleblower mechanisms that enable employees, clients, and other stakeholders to report suspected fraud or misconduct anonymously and without fear of retaliation.
- Training and awareness: Promoting fraud awareness and prevention throughout the Firm by supporting training programs, awareness campaigns, and educational initiatives.
The Board has devolved the following additional responsibilities:
MLRO & Chief Compliance officer
- Develop and maintain the fraud policy framework in line with regulatory requirements and industry best practices.
- Oversee fraud risk assessments and ensure the identification and evaluation of fraud risks across payment processes and channels.
- Establish fraud prevention controls and measures to mitigate fraud risks effectively.
- Monitor fraud trends and emerging threats to adapt fraud prevention strategies accordingly.
- Implement fraud prevention controls and measures to address compliance risks associated with fraud.
- Report fraud incidents to regulatory authorities and stakeholders as required by law.
HR Manager
- Lead fraud detection and investigation efforts, including the deployment of fraud analytics and investigative tools.
- Coordinate with internal teams and external stakeholders to respond to fraud incidents promptly and effectively.
- Ensure compliance with regulatory requirements related to fraud prevention and reporting.
- Ensure that the fraud policy aligns with regulatory requirements and industry standards.
- Implement fraud prevention controls and measures to address compliance risks associated with fraud.
- Regular reviews and assessments of the fraud policy should be conducted to identify areas for improvement.
- Provide training and awareness programs to employees on fraud prevention measures and reporting procedures.
- Monitor compliance with the fraud policy and investigate any instances of non-compliance.
- Report fraud incidents to regulatory authorities and stakeholders as required by law.
- Collaborate with internal audit and risk management functions to assess the effectiveness of fraud prevention measures.
Periculo
- Monitor IT systems and networks for signs of unauthorised access to Yeeld’s internal system, malware infections, or other security breaches indicative of fraud.
- Implement and maintain fraud detection tools, intrusion detection systems, and cybersecurity controls to protect against fraud.
- Conduct regular vulnerability assessments and penetration tests to identify weaknesses in IT infrastructure and applications.
- Provide guidance and support to IT and development teams on secure coding practices and fraud prevention measures.
- Monitor compliance with IT security policies and procedures and report any violations or vulnerabilities to management.
- All employees have a duty to guard against fraud. Employees are expected to identify processes and procedures that may be vulnerable to fraud and to draw such instances to the attention of management.
- Investigate security incidents and coordinate with other departments to contain and remediate threats.
Noto
- Noto monitors Fraud in relation to users that use our services for financial services:
- Continuously monitor transactions for signs of suspicious activity, including potential debit card fraud, device fraud, scams, and money laundering (AML) threats.
- Implement and maintain advanced fraud detection systems that use real-time data analytics to identify and flag fraudulent transactions.
- Use sophisticated algorithms to analyse transaction patterns and assign risk scores based on potential fraud indicators, ensuring prompt intervention when necessary.
- Track and detect unusual device activity, such as attempts to access customer accounts from unfamiliar or suspicious devices, triggering appropriate risk mitigation actions.
- Identify and block fraudulent attempts to deceive customers, such as phishing attacks, fraudulent account access, or manipulation schemes targeting users.

The Firm implements numerous systems and controls to prevent fraud from both internal and external perpetrators and manages and routinely updates these systems in line with pertinent fraud risks.
Pre-employment Screening
- During YEELD’s recruitment process, the Firm will undertake pre-employment screening of potential candidates. In doing this, the Firm will obtain and retrieve information that will help assess whether a potential candidate is likely to engage in fraud. The screening process will help reduce the likelihood that an individual with a history of fraud and unethical behaviour will be offered a role within the Firm. The Firm’s pre-employment screening techniques include:
- Confirming the professional qualifications of the candidate.
- Verification of the candidate’s employment background.
- Criminal history searches (DBS Checks).
- Credit checks.
- Only once YEELD is satisfied that a potential candidate does not pose any inherent fraud risks will he/she be offered a position in the Firm.
Due Diligence
- Due diligence is an important method for determining whether a particular client poses any interest fraud risks. In conducting due diligence procedures, the firm will look to satisfying:
- Clients are who they say they are.
- Whether the customer is acting on behalf of another.
- Any legal barrier to prevent providing the customer with the product or service requested.
- YEELD will conduct the appropriate level of due diligence on a client in accordance with the risk that the customer has been identified as possessing to the Firm. Please refer to the Firm’s BWRA for further information.
Risk Assessment
- YEELD shall always aim to protect the Firm and its customers from fraud. The Firm has undertaken a risk assessment of the various fraud risks that its operations can be vulnerable to. When considering the risks, the Firm also takes into account the effects that the risks can have on its customers, its reputation, and the market/industry in which it operates.
- The key fraud risks identified by the Firm, as confirmed by the most recent risk assessment, are detailed below:
- Vulnerabilities associated with online and remote processes;
- Unauthorised access, and account sharing due to inadequate identify verification measures;
- Risks associated with frequent changes in client identification data;
- Loss of sensitive client data;
- The risk assessment aids the Firm in developing an Anti-Financial Crime strategy as it provides the business with the ability to implement and maintain policies, controls, and procedures to identify, mitigate and effectively manage the risks of fraud. In understanding the appropriate tools and processes to prevent and control fraud risks, the Firm also considers how Anti-Money Laundering and Anti-Fraud efforts can complement each other.
- The MLRO is responsible for ensuring that the Fraud risk assessment remains up to date. As part of the Firm’s senior management team, CEO has been judged as having the appropriate level of expertise and seniority to complete this duty.

Reporting fraud according to the following procedure is mandatory for any employee who suspects that fraud has occurred. Persons who cover up, obstruct or fail to report (or monitor) a fraud that they become aware of or ought to have been aware of may be considered to be an accessory after the fact and may be subject to the Firm’s disciplinary code, which could involve action up to and including dismissal.
Persons who threaten retaliation against a person reporting a suspected fraud shall be subject to the disciplinary code which may include action up to and including dismissal or prosecution or both.
Great care must be taken in dealing with suspected dishonest or fraudulent activities to avoid:
- Alerting suspected individuals to an investigation underway;
- Treating employees unfairly; and
- Making statements that could lead to claims of false accusations or other charges.
Details of the incident, facts, suspicions or allegations should not be discussed with anyone inside or outside the Firm unless the investigating officer specifically directs this. Firm’s HR Manager (Or CEO if required) will appoint an investigating officer. In particular, the matter should not be discussed with the individual suspected of fraud.
Fraud can be detected at any level within the Firm, and the following will apply in the reporting of suspected internal fraud:
- An employee or other person who suspects that fraudulent activity is taking place should, in the first instance, report the matter to their line manager;
- If an employee does not feel comfortable raising a matter with their line manager – due to the nature of the concern, its seriousness, or for some other reason – they can raise it immediately with a member of the management team or via a dedicated email address: preston@Yeeld.com
- If an employee wishes to speak to a Director or higher grade in confidence, they should raise this with the CEO
Concerns may be reported verbally or in writing. Where a concern is raised verbally, the following steps are to be taken by the employee raising the concern to ensure that the concern raised is acknowledged by the recipient as received in the manner intended by the employee. These steps are to ensure that the recipient is clear that what is intended as a concern about suspected fraud is not construed by the recipient as a passing or casual comment.
The employee raising the concern sends a written communication to the recipient. The written communication confirms:
- the fact that a concern about suspected fraud was raised (details of the suspected fraud need not be included, just the fact that a concern is raised)
- that a written acknowledgement from the recipient to the employee is required.
- The recipient responds with a written communication acknowledging receipt of the concern.
Once a report of suspected fraud is made to a supervisor/manager, that person is required to pass that information promptly to the HR Manager/CEO.

No internal investigation of suspected fraud should take place until the HR team has been informed, which will, in turn, determine who best to inform, i.e. the CEO. The HR team must investigate all instances of suspected fraud reported to them. The HR team (except in any case involving his or her business function, in that case the report will be directed to CCO) will take the lead when fraud investigations are being conducted. This will involve data collection, analysis and intervention, including the review of internal controls. In circumstances where the investigation requires the use of technical expertise, which the HR team may not possess, external specialists (subject to the approval of the CEO may be appointed to lead and contribute to the investigation.)
The HR team will conduct an initial investigation to gather factual information and reach a preliminary view as to whether further action is required.
The HR team will report the findings, conclusions and any recommendations to the CEO and to other interested parties such as the Board etc.
Employees who are under investigation shall be entitled to have an employee or another appropriate individual present during the course of any interview that is conducted in connection with the alleged fraud or related dishonest activity, with a view to defending their case. Each case will be considered individually in accordance with the expert advice available, and priority will be given to minimise losses (both monetary and otherwise) to the Firm.
Where the report provides reasonable grounds for suspecting an employee or employees of fraud or dishonest activity, the CEO, in consultation with HR Manager, the CCO, COO and other relevant senior managers, will decide if any actions are necessary to deal with the situation and/or prevent further loss. This may require the suspension with or without pay of the employee(s) (which will take place in accordance with Disciplinary Procedures) and/or a decision as to whether further investigation is required.
Where further investigation is required, the CEO and the HR Manager, in consultation with the CCO, COO and other relevant senior managers, will determine the format and nature of the investigation.
If necessary, the CEO will notify the Firm’s insurance brokers at an early stage to ensure that insurance matters are dealt with promptly and properly.

As part of its commitment to fraud prevention and regulatory compliance, YEELD maintains a comprehensive Fraud Register to document and track all instances of suspected or confirmed fraud. The Fraud Register serves as a centralised repository for recording relevant details and information related to fraud incidents, including but not limited to:
- Incident Details: Each entry in the Fraud Register includes a detailed description of the fraud incident, including the date, time, location, and nature of the fraudulent activity.
- Affected Parties: The Fraud Register identifies the individuals, accounts, or entities directly impacted by the fraud incident, as well as any third parties or external stakeholders involved.
- Fraudulent Activity: The Fraud Register outlines the specific fraudulent activities or schemes perpetrated, such as account takeovers, unauthorised transactions, identity theft, or payment fraud.
- Evidence and Documentation: Relevant evidence, documentation, or supporting materials pertaining to the fraud incident are attached to the Fraud Register entry, including transaction records, communication logs, and investigative findings.
- Investigation Details: Any actions taken to investigate the fraud incident, including internal reviews, forensic examinations, or external inquiries, are documented in the Fraud Register.
- Resolution and Remediation: The Fraud Register tracks the outcome of each fraud incident, including any remedial actions taken to address the issue, such as account freezes, refunds, or legal proceedings against perpetrators.
- Reporting and Escalation: Details of any regulatory or legal reporting obligations arising from the fraud incident, as well as notifications to relevant stakeholders, are recorded in the Fraud Register.
- Lessons Learned: Each entry in the Fraud Register includes an analysis of lessons learned from the fraud incident, including root causes, contributing factors, and opportunities for process improvements or enhanced controls.
Maintaining an accurate and up-to-date Fraud Register is essential for enhancing transparency, accountability, and regulatory compliance within YEELD. All employees are responsible for promptly reporting suspected or confirmed fraud incidents to the HR Manager, who will ensure that the details are accurately reported to MLRO and documented in the Fraud Register and appropriate actions are taken to address the issue. MLRO will document any transaction fraud/customer fraud in the fraud register.

YEELD will cooperate, where necessary, with all anti-fraud bodies that have been invested with powers by the UK Government to investigate and prevent fraud. YEELD will also keep the relevant bodies appropriately informed of any major instances of fraud that have been perpetrated against the Firm.
National Crime Agency
- The National Crime Agency (NCA) is a national law enforcement agency that helps to coordinate the fight against fraud in the UK.
- The NCA has a wide remit involving tackling serious and organised crime, strengthening the UK’s borders, fighting fraud and cybercrime, and protecting children and young people from sexual abuse and exploitation.
- The NCA is responsible for strategic development and threat analysis relating to fraud, a role previously allocated to the National Fraud Authority, which closed on 31 March 2014.
Serious Fraud Office
- The Serious Fraud Office (SFO) is an independent government department operating under the superintendence of the Attorney General. Its purpose is to protect society by investigating and, if appropriate, prosecuting those who commit serious or complex fraud, bribery and corruption and pursuing them and others for the proceeds of their crime.

YEELD acknowledges that transparent and timely reporting and management information processes are integral to its fraud prevention efforts and regulatory compliance obligations.
The following outlines the Firm’s reporting and fraud-related Management Information to key stakeholders:
- Board Reporting: The MLRO provides regular reports to the Board of directors on fraud incidents, trends, and mitigation strategies. Reports include summaries of significant fraud incidents, analysis of fraud risk exposure, and updates on the effectiveness of fraud prevention measures. Key performance indicators (KPIs) and metrics related to fraud detection rates, investigation outcomes, and regulatory compliance are presented to the Board to facilitate informed decision-making and oversight.
- Regulatory Reporting: YEELD complies with regulatory reporting obligations related to fraud incidents as required by the Financial Conduct Authority (FCA). Reports to regulators include notifications of significant fraud incidents, details of remedial actions taken, and updates on compliance with regulatory requirements. The MLRO ensures that regulatory reporting is conducted in accordance with prescribed timelines, formats, and disclosure requirements to maintain transparency and accountability with regulatory authorities.
- Internal Management Information: The HR Manager maintains a comprehensive Management Information (MI) to track and monitor fraud-related information for internal management purposes. The MI generates regular management reports and dashboards that provide insights into fraud trends, patterns, and emerging threats. These reports include an analysis of fraud incidents, investigation outcomes, key risk indicators, and performance metrics related to fraud prevention efforts. Management reports are used to inform strategic decision-making, assess the effectiveness of fraud prevention measures, and allocate resources to mitigate fraud risks effectively.
- Escalation Protocols: In addition to regular reporting, the MLRO follows established escalation protocols to notify the Board and regulators of significant fraud incidents or emerging threats that require immediate attention. Timely escalation ensures that key stakeholders are informed promptly of material developments and can take appropriate action to address fraud risks and protect the interests of the Firm and its stakeholders.
By adhering to these reporting requirements, YEELD demonstrates its commitment to transparency, accountability, and proactive risk management in combating fraud. Reporting to the Board and regulators, as well as internal management information, enables YEELD to maintain effective oversight of fraud prevention efforts, identify emerging risks, and implement timely interventions to safeguard the organisation and its stakeholders against fraudulent activities.

Fraud Policy