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Welcome
Martin McColl
29" April 2010
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Agenda
introductions
Declared Cash / ONCH
Regulatory Compliance
Overview of P& BA
Communications
Transaction Corrections
Branch Discrepancies
Dispute procedure
Visit P & BA teams
Cash / Bureau — Carol King
Cheques ~ Tracy Mather
A& I. — Michala Millington
Camelot — Paul Smith
Debit Cards ~ Sue Oxley
Review effectiveness of day
Gs)
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¢ Introductions
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Declared Cash / ONCH
ANDREW KEIGHLEY — RETAIL CASH TEAM
° Overview of process
. McColl branch ONCH declarations
. Hints & Tips
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Regulatory
Compliance
Marie Perry
Policy & Standards Manager
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Statutes and regulations
Financial Services and Markets Act
Money Laundering Regulations
Proceeds of Crime Act
Payment Services Directive
Consumer Credit Directive
Data Protection Act
Telecommunications Act
Postal Services Act
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What our team does
Interpret what the regulations mean for POL
Maintain relationships with Regulators and Bank of Ireland
Provide advice on regulatory issues at product development stage
Provide approval for all internal communications and training in relation to
Financial Services
Manage the Training and Development framework for driving compliant
sales in the network
Manage anti money laundering processes for the business
Provide assurance to clients, e.g. NS&l and DVLA
Assure business processes
Management reporting to measure compliance in the network
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Anti money laundering controls
POL is the principle operator for Bureau de Change and accountable to
HM Revenue and Customs
The Money Laundering regulations require us to have robust controls to
prevent money being laundered through our branches, including:
+» Train our colleagues to understand anti money laundering processes
« Have processes in place to report suspicious activity
+ Have robust identification and ‘know your customer’ controls in place
+ Assess the risk of money laundering through the business and have
proportionate controls to prevent it happening
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Proceeds of Crime Act
The Proceeds of Crime Act makes it an offence to:
41. Acquire, possess, conceal, transfer or use the proceeds of crime
2. Fail to disclose knowledge or suspicion that money laundering is taking
place
3. ‘Tip off’ an individual that they may be the subject of a suspicious activity
report, or disclose any information that may jeopardise a criminal
investigation
Maximum penalties are 14 years imprisonment and/or and unlimited fine
(point 1) and five years imprisonment and/or an unlimited fine (points 2
and 3)
These are personal liabilities for each individual working in our branches.
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Counter Processes
identification requirements for Bureau de Change
» Ifa transaction is £5000 or more
+ If two or more transactions are linked and total £500 or more
+ If the customer wants to enter into a business relationship with POL
+ If the customer/transaction is suspicious (regardiess of the values of transaction)
Reporting suspicious activity
+ All transactions across all Financial products
+ Is the transaction reasonable in context of the transaction type?
+ Is it reasonable for what you know about the customer?
+ Does the transaction make good commercial sense?
+ Where has the money come from and what's it being used for?
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Financial Services
Sell products in a non-advised capacity
Providing accurate and balanced information to allow the customer to
make an informed decision
Displaying and providing promotional material that is in date
No hand made/locally produced material to be displayed
After sales service — secondary ID checks
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P&BA Structure
+ Hand out
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Communication Links
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P &BATC issuing
feams
P&BA Relationship Martin MeColl Ops
Maneger Managers
Martin McColl
Branches
Role ~ to prodix
invoice for paym
act as a link
as ane:
for the p
Martin McColl Area
Managers Parner duty
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Transaction Corrections
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-Data received from Horizon and Clients is matched to identify any
transaction differences.
-Open items (differences) are investigated, some will be resolved.
-Where the Horizon stream is incorrect, Transaction Corrections are
produced and sent electronically to the branch.
-Transaction correction received by the branch ~ usually next day.
-Transaction correction accepted by the multiple and Assigned to
Nominee.
-Transaction corrected and difference resoived
-TC Pack , P& BA use to highlight problems/issues and discuss with
either Operations or Area Managers as appropriate
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Transaction correction disputes Ge)
-Multiple ensures that they have read narrative on TC and examined corresponding
evidence thoroughly
-Multiple to gather evidence to support the dispute
-Multiple contact the issuer of the transaction correction to formally dispute
-lssuer may advise Multiple to Assign to Nominee, whilst investigated, depending on
Branch Trading date
-issuer responds to the multiple with one of the following:
~ Agree dispute & issue a reversal transaction correction.
~ Disagree dispute & transaction correction stands.
- Request more evidence from Branch
- Multiple Partner duty will block Transaction Corrections only with agreement of the
Operations/Area Manager
-Multiple Partners may can appeal to Andy Winn in writing with all the evidence
available,
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Multi
le Partner Blocking Criteria for Transaction
Corrections and Branch Discrepancies
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PABA requir
Value of TC or BD is more
than £1k debit or crecit
Value of TC or BD is more
Multiple Account duty to
Helpline if appropriate
Information provided by the
partner that allows the P &BAI
confirm that a compensating
item is due e.g. H number to
how they have contacted theI
Value requested for biocking does
not equal the v
Until compensating amount isI TC, Value will not be receiving a
issued/assigned to nominee
ie of the BD or
8D
than £1k debit or credit and
Ipariner requests more time toI
understand cause of TC or
Upeate from partner
regarding progress of their
investigation e.g. product
date of error that may help
resolve
Value has been blocked for 1
fnonth pending investigation - anal
further information has not been
[One month - untii next invoiceI _providied / received by P& BA
compensating entry
Manager
issue of TC is being disputed
lwith duty holder or forratly in
writing to the Relationship
Information provided by the
Multiple Account duty to
investigate further ie Team
member name , contact
number H number , Product
partner that allows the P&BA
completed
Value has been formally disputed
Until formai dispute process I and decision made that itis to.
stand
£1k
Value of TC/ BD is less than
Acompensating amount is
lUntil compensating amount is
visible in POLFS
Value requested for blocking does
not equal the vaiue of the BD er
issued/assigned to nominee
Te.
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Weekly TC Report - EXAMPLE
User name [Multiple Partner [Branch Code [Branch Name] Description Description 1 Te Date [Type I TC Number I Amount
AOMINGATCAI Wuiliple Patner I 7400 ‘fay Town I Assign Nominee _IRedeam Rem Discrepshor [22.08.2008] IX [eio0020084I £20.00
AOMINBATCAI Muitipie Patner I 74900 ‘Any Town I Assign Nominee I Unpaid Cheque TOPOLFS I21.05.2008I Ix Ieto0006032I £40.00,
AOMINBATCHI Multiple Partner I 74900 ‘Any Town I Assign Nominee I REM SURPLUS WRITE CN 23.05.2008] IX Ieto00s2062I -£600,
(ADMINGATOHI Multiple Partner I 740% ‘Any Town I Assign Nominee I Ungaid Cheque TCPOLFS [22.05.2008] Tx I6100057051I £200.00
[ADMINBATCHI Multiple Partner I 7400 Any Town I Assign Nominee ‘BL Deposit Te [20.05.2008] 1x [6100025025
(ADMINBATOHI ‘Multipie Pariner_ [7400 Any Town I Assign Nominee I TCRemin Miskeyed [20.05.2008] 1x Iéi00029048I £140.00
ADMINBATCHI Multiple Partner I 74900 ‘Ary Town I Assign Nominee NS8I Gash Deposit _I2005.2008I 1x [6100117039] -£30006)
AOMINBATOAI Wuitipie Pariner I 74900 ‘Any Town I Assign Nominee PBL Deposit TC [22.05.2008] TX [6100062049 81,441.30
Multiple Partner I 860% Toxtown I Special Del Env SOO5I Special Del EnvSocs [22.05.2008] To [6000187037] _ 00%
AOMINBATCAI Wuitipie Partner [10600 I PlayTown I Assign Nominee I Unpaid Gheque TCPCLFS [23.05.2008] 7x Isi0008s030I £79.00
‘Multiple Partner I 106900 I PlayTown I Rem Out Cheque TCI Rem Gut Cheque TC [22.05.2008] TC [6000008969] £17400)
"AOMINBATOAI” Multiple Partner I 106300 I Play Town I Assign Nominee I REM SURPLUS WRITE ON [23.05.2008] 1x [6100086085] -E 28006
"ADMINBATGHI Multiple Pariner I 10600 I PlayTown I Assign Nominee I Post Gifice Fin Services [22.06.2008 1x [6100048033] -£30000)
'ADMINBATOHI Multiple Partner I 17300 I Anywhere FFOI Assign Nominee I Chequeprizes Balancing E [22.05.2008] 1x [6100005056 I£2,834 20
AOMINBATCHI Multiple Partner I 17300 I Anywhere FPO I Assign Nominee I REM SURPLUS WRITE ON [17.05.2008] TX I6100082057I -£50.00
Multiple Partner I 173300 I Anywhere FPO I TC-Rem Shortages I TO-Rem Shortages [22.05.2008] To [6000049726] £2000)
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Branch Discrepancies
BALANCE SNAPSHOT — during month
-Cash derived from horizon ‘v’ Physical cash counted = snapshot
discrepancy
BRANCH TRADING — monthly
-Individual tills balanced — cash discrepancies identified, as above
-Finai till balances and individual discrepancies consolidated =
Branch discrepancy transferred to local suspense. These should be
accepted and Assign to Nominee
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Visit to P&BA Operational Teams
*Cash / Bureau ~ Carol King
*Cheques — Tracy Mather
*A& L— Michala Millington
*Camelot ~ Paul Smith
*Debit Cards — Sue Oxley
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Review of day
“Benefits of visit
simprovement Opportunities
“Actions agreed
“Next Steps
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