Fraud Prevention and Compliance Policy

1. Introduction

This Fraud Prevention and Compliance Policy (“Fraud Prevention Policy” or “Policy”) outlines the rights and obligations of PayCargo, the Payer, and the Vendor in the context of preventing and addressing fraudulent activities on the Platform.  Any capitalized terms that are utilized in this Fraud Prevention Policy that are not defined herein shall have the same meaning and effect as set forth in the PayCargo Platform Terms of Use (“Terms of Use”).

2. Pre-Existing Business Relationship

2.1 Value Proposition: PayCargo’s core value proposition for its Platform is based on the understanding that there is a pre-existing business relationship between Payers and Vendors.

3. Section 3  of the Terms of Use

3.1 False or Misleading Invoices: PayCargo requires that only current, correct, and valid invoices be submitted on the Platform. False or misleading invoices intended to defraud will not be permitted, and Customers engaging in such activities will face account restrictions, suspension, or termination.

3.2 Payment Method Restrictions: This Policy aligns with, and supplements Section 3.4 of the Terms of Use regarding payment method restrictions. Customers are strongly advised to review and adhere to this clause, which is detailed as follows:

“3.4 Payment Method Restrictions. To prevent fraud and to comply with applicable laws, rules and regulations, we may place your payment transaction on hold for review. We may request information from you or third parties, in addition to the User Content you provide in a Registration Application. If you do not cooperate with us during our review process, your payment transaction may be delayed or declined. We reserve the right to limit or refuse your use of a particular Payment Method for any reason in our sole discretion. We may impose limitations on the size, frequency, and timing of payments, on a per transaction or cumulative basis, and we may change these limits at any time in our sole discretion. We may decline in our sole discretion to make payments or otherwise deny your use of the Platform, and we disclaim any obligation to explain the basis for such decision.”

4. Refunds and Disputes

4.1 Invoice or Payment Transaction Approval: Payers’ approval of an invoice signifies the availability of sufficient funds for payment.  While false or misleading invoices are strictly prohibited, inadvertent errors may still occur. The Platform incorporates mechanisms to facilitate communication, refunds, and dispute resolution in such cases.

4.2 Refunds and Disputes: Payers and Vendors are responsible for resolving disputes, and PayCargo disclaims liability for any disputes between them.

4.3 Non-Refundable Fees.  Transaction and processing fees are non-refundable once services are rendered, and the payment is processed on the Platform.

5. Customer Responsibilities

5.1 Vetting Counterparties: It is the responsibility of both the Payer and the Vendor to thoroughly vet their respective counterparties before engaging in any transactions. PayCargo expects Customers to exercise and engage in commercial due diligence to mitigate the risk of fraudulent activities.  PayCargo shall not be responsible for losses that occur as a result of Customer’s failure to engage in commercial due diligence, or to engage in risk mitigation.

5.2 Transaction Verification: PayCargo reserves the right to place payment transactions on hold for review to prevent fraud and comply with applicable laws. Customers are obligated to cooperate during the review process. Non-cooperation may result in delayed or declined transactions.

5.3 Payment Method Restrictions: PayCargo may, in its sole discretion, limit or refuse the use of a particular payment method for any reason. Customers acknowledge that limitations on the size, frequency, and timing of payments may be imposed, subject to change at PayCargo’s sole discretion.

6. PayCargo Responsibilities and Discretionary Actions

6.1 Support on Refunds and Disputes: PayCargo commits to facilitate the process and communication for cancellations, refunds or disputes.

6.2 Support on Preventing and Addressing Fraud: PayCargo commits to identify, communicate, and facilitate actions to prevent the occurrence of suspicious activities that may lead to fraud.

6.3 Suspicious Transactions: PayCargo has the right and discretion to stop payments when transactions are identified as suspicious or fraudulent. This action is taken to protect Customers from potential financial losses associated with fraudulent activities.

6.4 Chargebacks and Recovery: In cases of suspected fraud, or the unauthorized or suspicious approval of invoices, PayCargo is authorized to request the return of transaction funds credited to Vendors. Specific transaction details will be provided to aid Vendors in their collection efforts and insurance claims.

7. Conclusion

This Policy serves as a framework to prevent and address fraudulent activities on the Platform. PayCargo remains committed to maintaining a secure and trustworthy environment for all Customers and expects its Customers to engage in commercial due diligence and risk mitigation, and to cooperate with PayCargo in the event suspicious or fraudulent activities are identified to prevent financial losses.