FINZOOPAY SOLUTIONS LLP

1. PURPOSE

This Policy establishes a risk-based framework for setting, monitoring and controlling transaction limits and applying preventive, detective and corrective controls to reduce fraud, financial, operational and compliance risks.

2. OBJECTIVES

• Define appropriate transaction and exposure limits.
• Control unusual, high-risk or excessive transaction activity.
• Reduce fraud, misuse and operational losses.
• Provide escalation and approval mechanisms for exceptions.
• Support transaction monitoring and customer protection.

3. SCOPE

This Policy applies to relevant payment, voucher, gift-card, wallet, account, refund, settlement and other transaction activities processed or facilitated by the Company, subject to the applicable product and partner arrangements.

4. RISK-BASED LIMIT FRAMEWORK

Limits shall be determined considering product type, transaction characteristics, customer or user profile, merchant or partner risk, historical activity, fraud indicators, operational capacity and applicable requirements.

5. TYPES OF LIMITS

• Per-transaction limit
• Daily cumulative limit
• Monthly or periodic limit
• Velocity / frequency limit
• Account or customer exposure limit
• Merchant / partner exposure limit
• Refund / reversal limit
• Gift card / voucher issuance or redemption limit
• Settlement or operational exposure limit

6. LIMIT SETTING

Limits shall be approved through authorised governance processes and documented in relevant product or operational configurations. System-enforced limits should be used wherever practical.

7. DYNAMIC RISK CONTROLS

Where appropriate, limits may be adjusted or additional verification may be applied based on risk signals such as unusual velocity, transaction amount, device or account anomalies, repeated failures, geographic anomalies or fraud indicators.

8. TRANSACTION VELOCITY

The Company may monitor transaction frequency and patterns over defined time periods to identify excessive or abnormal activity.

9. HIGH-VALUE TRANSACTIONS

High-value transactions may be subject to enhanced verification, additional approval, transaction monitoring or temporary review depending on product design and risk assessment.

10. SUSPICIOUS TRANSACTIONS

Transactions presenting significant risk indicators may be declined, delayed, held for review, subjected to enhanced verification or escalated in accordance with applicable procedures.

11. FRAUD CONTROLS

Transaction-limit controls shall operate alongside the Company's Fraud Prevention & Transaction Monitoring and Cyber Incident Response policies.

12. CUSTOMER PROTECTION

Controls shall be designed to reduce unauthorised transactions, account takeover, voucher abuse, refund fraud and other customer-impacting risks while avoiding unnecessary disruption to legitimate activity.

13. EXCEPTIONAL LIMITS

Any temporary or exceptional increase in a limit shall be documented, justified, approved by authorised personnel and subject to an appropriate validity period.

14. LIMIT OVERRIDE

System or manual overrides shall be restricted to authorised personnel and logged where technically feasible. Overrides shall be reviewed for unusual or inappropriate use.

15. PARTNER / MERCHANT LIMITS

Where transaction limits are imposed by banks, payment processors, merchants, networks or other partners, the Company shall follow the applicable contractual or system limits.

16. MONITORING

Transaction-limit breaches, near-breaches, unusual patterns and repeated control triggers should be monitored and reviewed based on risk.

17. ALERT MANAGEMENT

Alerts generated by transaction-limit or risk controls shall be prioritised, investigated and closed or escalated according to defined procedures.

18. HOLD / REVIEW

Where permitted and appropriate, transactions may be temporarily held for verification or investigation. Release or rejection shall be based on available evidence and authorised procedures.

19. RECONCILIATION

Relevant transaction, refund, reversal and settlement records shall be reconciled to identify inconsistencies, duplicate processing or control failures.

20. DATA & AUDIT TRAILS

Limit configurations, material changes, overrides, alerts, investigations and decisions should be logged and retained according to applicable record-keeping requirements.

21. RISK REVIEW

Transaction limits and related controls shall be reviewed periodically using transaction volumes, fraud trends, loss events, customer complaints, operational capacity and material changes in the business.

22. LIMIT BREACH MANAGEMENT

Confirmed breaches shall be investigated. Depending on severity, the Company may restrict further transactions, investigate the account or partner, reverse or refund transactions where appropriate, and implement corrective actions.

23. MANAGEMENT REPORTING

• Transaction volume and value by risk category
• Limit breaches and override activity
• High-value transaction reviews
• Fraud-related transaction blocks
• Unusual velocity alerts
• Refund/reversal exceptions
• Material losses and recoveries
• Open risk-control remediation

24. RESPONSIBILITY MATRIX

25. POLICY EXCEPTIONS

Exceptions shall be documented, risk-assessed and approved by authorised management. Mandatory legal, regulatory, network or contractual limits shall not be overridden.

26. REVIEW & AMENDMENT

This Policy shall be reviewed at least annually and following material fraud events, major product changes, significant limit breaches, changes in transaction flows or applicable requirements.

27. APPROVAL