Risk Management & Fraud Prevention Policy

    This Risk Management & Fraud Prevention Policy (“Policy”) sets out the principles, procedures, and controls adopted by Codoser.com (“Codoser,” “we,” “our,” “us”) to identify, assess, mitigate, and respond to risks and fraudulent activities across the platform.

Codoser operates a global digital marketplace, making it a target for potential financial fraud, cyber threats, policy violations, and legal risks. This Policy is designed to protect users, maintain trust, and comply with applicable Indian and international regulatory frameworks.

 

1. Scope of the Policy

1.1 This Policy applies to:

  • All users (authors, buyers, affiliates)
  • All transactions and activities on the platform
  • All employees, contractors, and third parties with system access
    1.2 It covers risk management processes, fraud prevention strategies, and response mechanisms.

 

2. Policy Objectives

2.1 The key objectives of this Policy are to:

  • Identify and assess potential risks (financial, legal, operational, cybersecurity)
  • Prevent and detect fraudulent activities
  • Establish clear mitigation strategies and escalation paths
  • Ensure legal and regulatory compliance
  • Protect users and maintain platform integrity

 

3. Regulatory Framework

3.1 Codoser aligns its risk management and fraud prevention measures with:

  • Financial Action Task Force (FATF) recommendations
  • ISO 31000: Risk Management principles
  • GDPR (EU), CCPA (US), and India’s IT Act and DPDP Act, 2023
  • RBI and SEBI guidelines for financial intermediaries
    3.2 Where multiple regulations apply, the stricter standard prevails.

 

4. Risk Management Governance

4.1 A dedicated Risk & Compliance Committee oversees risk management activities.
4.2 The committee includes members from legal, security, finance, and operations teams.
4.3 Responsibilities include periodic risk assessments, policy updates, and escalation oversight.

 

5. Risk Classification

5.1 Codoser classifies risks into the following categories:

  • Strategic Risks — affecting business objectives
  • Operational Risks — arising from internal processes or systems
  • Financial Risks — payment fraud, chargebacks, tax non-compliance
  • Cybersecurity Risks — hacking, phishing, data breaches
  • Regulatory Risks — non-compliance with laws and regulations
  • Reputational Risks — negative public perception due to incidents
    5.2 Each category is addressed through targeted mitigation strategies.

 

6. Risk Assessment Methodology

6.1 Codoser conducts structured risk assessments, including:

  • Identifying potential threats and vulnerabilities
  • Evaluating likelihood and impact
  • Assigning risk ratings (Low, Medium, High, Critical)
  • Documenting mitigation measures and owners
    6.2 Assessments are conducted at least annually and after major platform changes.

 

7. Continuous Risk Monitoring

7.1 Risk monitoring is an ongoing activity involving:

  • Automated transaction scanning
  • Policy violation tracking
  • User behavior analytics
  • Security system alerts
    7.2 Findings are logged and reviewed by the Risk & Compliance team.

 

8. Fraud Prevention Principles

8.1 Fraud prevention at Codoser is based on the principles of:

  • Prevention through strong controls and deterrents
  • Detection through monitoring and analytics
  • Response through rapid escalation and enforcement
    8.2 Both automated and manual measures are employed.

 

9. Fraud Risk Areas

9.1 Fraudulent activities may involve:

  • Stolen credit cards or payment methods
  • Identity theft or fake accounts
  • Unauthorized account access
  • Money laundering or illegal fund transfers
  • Chargeback abuse by buyers
  • Affiliate fraud (self-referrals, cookie stuffing)
  • Author fraud (duplicate products, IP theft, manipulation of reviews)
    9.2 Each risk area is monitored with tailored controls.

 

10. User Verification Controls

10.1 Fraud prevention begins with robust KYC verification of authors, buyers, and affiliates.
10.2 Identity checks reduce the likelihood of fake accounts and unauthorized transactions.
10.3 Additional verification is required for high-risk activities or jurisdictions.

 

11. Transaction Monitoring

11.1 All platform transactions are monitored in real time for suspicious patterns, including:

  • Unusual payment volumes
  • Geographic anomalies
  • Rapid successive transactions
  • High refund or chargeback rates
    11.2 Alerts are generated for manual review where thresholds are exceeded.

 

12. Payment Fraud Controls

12.1 Payment fraud prevention measures include:

  • Integration with fraud detection tools and scoring engines
  • 3D Secure and CVV verification for card payments
  • Velocity checks on payment attempts
  • Blocking of high-risk BINs or IPs
    12.2 Transactions failing fraud checks may be held or rejected.

 

13. Account Takeover Prevention

13.1 Measures to prevent account takeovers include:

  • MFA for sensitive actions
  • Session and device fingerprinting
  • Login anomaly detection
  • Immediate session termination on password change
    13.2 Users are notified of suspicious login attempts.

 

14. Author Fraud Detection

14.1 Author activities are monitored for fraudulent behavior, such as:

  • Uploading pirated or duplicated products
  • Generating fake sales to inflate rankings
  • Manipulating reviews or ratings
  • Violating license terms deliberately
    14.2 Fraudulent authors may face removal, earnings reversal, and legal action.

 

15. Buyer Fraud Detection

15.1 Buyers are monitored for behaviors such as:

  • Frequent chargebacks
  • Suspicious bulk purchases
  • Sharing products illegally after purchase
  • Using stolen cards or accounts
    15.2 Buyers found engaging in fraud may face permanent bans and legal consequences.

 

16. Affiliate Fraud Prevention

16.1 Affiliate activities are audited for practices including:

  • Self-referrals to earn commissions
  • Fake traffic or click farming
  • Cookie stuffing or misleading promotions
  • Encouraging piracy
    16.2 Detected affiliate fraud results in commission forfeiture and program termination.

 

17. Cybersecurity Threats

17.1 Codoser continuously monitors for cybersecurity threats that may lead to fraud, including phishing, malware injections, or data breaches.
17.2 Security incidents trigger fraud risk reviews to assess downstream impact on transactions.

 

18. Regulatory Compliance Risks

18.1 Non-compliance with tax, KYC/AML, or financial reporting obligations is treated as a critical risk.
18.2 Regular audits and reporting mechanisms are in place to ensure compliance.

 

19. Reputational Risk Management

19.1 Public trust is crucial. Fraud incidents or data breaches are handled transparently to maintain reputation.
19.2 Codoser may issue public statements and collaborate with media or regulators as needed.

 

20. Internal Fraud Controls

20.1 Employees and contractors are subject to background checks, confidentiality agreements, and access controls.
20.2 Insider activity is monitored to detect unusual patterns or unauthorized actions.

 

21. Technology and Tools

21.1 Codoser employs advanced tools such as:

  • Machine learning fraud detection engines
  • IP reputation databases
  • Device fingerprinting
  • Behavioral analytics
    21.2 Tools are continuously updated to adapt to emerging threats.

 

22. Data Analytics in Risk Management

22.1 Codoser leverages data analytics to identify trends and anomalies.
22.2 Predictive models help detect fraud early by analyzing historical patterns.

 

23. User Education and Awareness

23.1 Users are educated on security best practices through onboarding guides, alerts, and support content.
23.2 Awareness reduces the success rate of phishing and social engineering.

 

24. Multi-Layered Controls

24.1 Fraud prevention relies on multiple layers of defense, including:

  • Identity verification
  • Transaction monitoring
  • Behavioral analytics
  • Manual review by experts
    24.2 No single control is relied upon exclusively.

 

25. Manual Review & Escalation

25.1 High-risk transactions or flagged activities undergo manual review by trained fraud analysts.
25.2 Escalated cases are investigated with access to logs, KYC records, and transaction histories.

 

26. Case Management System

26.1 A centralized fraud case management system tracks all investigations, evidence, and outcomes.
26.2 Cases are categorized, prioritized, and assigned to analysts.

 

27. Fraud Incident Response

27.1 Confirmed fraud incidents trigger response actions such as:

  • Account suspension or termination
  • Transaction reversal
  • Funds freezing
  • Regulatory reporting
    27.2 Response timelines depend on incident severity.

 

28. Collaboration with Authorities

28.1 Codoser collaborates with law enforcement, financial regulators, and cybersecurity agencies to report and investigate fraud.
28.2 Information sharing follows legal procedures and data protection requirements.

 

29. Cross-Border Fraud Management

29.1 As an international marketplace, Codoser monitors for cross-border fraud patterns, such as:

  • Transactions from high-risk jurisdictions
  • Use of VPNs or anonymizers
  • International money movement irregularities
    29.2 Such cases receive enhanced scrutiny.

 

30. Integration with Other Policies

30.1 This Policy integrates with:

  • KYC / AML Policy
  • Data Security Policy
  • Payment, Fees & Tax Policy
  • Author, Buyer & Affiliate Policies
    30.2 Together, these policies form a comprehensive risk and fraud management framework.

 

31. Risk Scoring and User Profiling

31.1 Codoser employs risk scoring systems to evaluate users based on factors such as transaction volume, geographic location, device fingerprinting, and historical behavior.
31.2 High-risk users may face additional verification or transaction limits.
31.3 Risk scores are dynamic and updated automatically based on ongoing activity.

 

32. Account Freezing and Funds Hold

32.1 If fraudulent activity or serious risk is detected, Codoser may freeze user accounts or hold funds temporarily while investigations are conducted.
32.2 Frozen accounts are restricted from withdrawals, new transactions, or product access.
32.3 Users will be notified of the freeze unless prohibited by law or regulatory orders.

 

33. Refund and Chargeback Risk Controls

33.1 Codoser tracks refund and chargeback ratios for each user.
33.2 Excessive refund or chargeback activity triggers enhanced review and potential restrictions.
33.3 Authors may be held responsible for chargebacks if they result from misrepresentation or policy violations.

 

34. Affiliate Risk Controls

34.1 Affiliate activities are regularly analyzed for fraudulent referral patterns, abnormal conversion rates, and IP overlaps.
34.2 Affiliates flagged for high-risk activity may have commissions delayed, frozen, or revoked.
34.3 Affiliates engaging in fraud are permanently banned and reported.

 

35. Author Risk Controls

35.1 Author accounts are monitored for:

  • Abnormal sales spikes
  • Duplicate or plagiarized content
  • Manipulation of reviews
  • IP or license violations
    35.2 High-risk authors may face temporary product unlisting, payout holds, or permanent suspension.

 

36. Buyer Risk Controls

36.1 Buyer behavior is analyzed for suspicious activity such as:

  • Bulk purchases with subsequent mass refund requests
  • Use of stolen cards or mismatched billing details
  • Purchase from restricted locations via VPN
    36.2 Buyers involved in fraud may be blacklisted permanently.

 

37. Internal Fraud Monitoring

37.1 Internal staff activities are monitored for unusual actions, unauthorized access, or policy breaches.
37.2 Role-based access and activity logging mitigate insider fraud risks.
37.3 Whistleblower channels exist for reporting internal misconduct anonymously.

 

38. Audit Trails and Evidence Preservation

38.1 All fraud-related investigations maintain detailed audit trails, including logs, communications, KYC data, and evidence.
38.2 Evidence is preserved securely for regulatory audits, legal proceedings, or internal reviews.

 

39. Communication During Investigations

39.1 Users under investigation are informed of relevant actions unless restricted by legal requirements.
39.2 Communication is professional, transparent, and documented to maintain accountability.

 

40. Cooperation with Payment Gateways and Banks

40.1 Codoser works closely with payment processors, card schemes, and banks to investigate suspicious financial transactions.
40.2 Chargeback data, fraud alerts, and AML signals are exchanged securely as part of fraud mitigation.

 

41. AML/KYC Synergy

41.1 Fraud prevention measures are closely integrated with AML/KYC processes to detect money laundering, terrorist financing, or identity theft.
41.2 Users flagged in KYC systems receive enhanced fraud monitoring.

 

42. Escalation Procedures

42.1 Confirmed or suspected high-impact fraud incidents are escalated to:

  • Senior management
  • Legal & Compliance teams
  • Relevant regulators or authorities (when required)
    42.2 Escalations follow structured protocols with clear accountability.

 

43. Regulatory Reporting of Fraud

43.1 Significant fraud incidents may be reported to regulatory authorities such as:

  • Financial Intelligence Units (FIUs)
  • CERT-In (India)
  • Data Protection Authorities (for privacy-related incidents)
    43.2 Reporting timelines follow legal obligations depending on jurisdiction.

 

44. User Appeals and Review

44.1 Users who believe their accounts were wrongly flagged for fraud may appeal decisions.
44.2 Appeals must include supporting documentation or evidence.
44.3 Appeals are reviewed by a separate senior team to ensure impartiality.

 

45. Training and Capacity Building

45.1 All employees, moderators, and compliance personnel undergo regular fraud prevention training.
45.2 Training covers latest fraud schemes, regulatory changes, detection techniques, and user interaction protocols.

 

46. Continuous Improvement of Fraud Controls

46.1 Fraud prevention systems are continuously evaluated through metrics such as:

  • Fraud detection rate
  • False positive rate
  • Incident resolution time
  • Recovery of lost funds
    46.2 Feedback loops help improve algorithms and manual review procedures.

 

47. Incident Post-Mortems

47.1 After major fraud incidents, Codoser conducts post-mortem analyses to identify root causes and improve controls.
47.2 Lessons learned are documented and applied to system updates.

 

48. Business Continuity for Fraud Scenarios

48.1 Business continuity plans cover large-scale fraud scenarios, including widespread phishing attacks or coordinated fraudulent campaigns.
48.2 Contingency measures ensure platform stability while investigations are ongoing.

 

49. Cross-Border Law Enforcement Cooperation

49.1 For international fraud cases, Codoser cooperates with Interpol, national cybercrime units, and financial regulators.
49.2 Mutual Legal Assistance Treaties (MLATs) are followed for lawful information exchange.

 

50. Transparency to Users

50.1 Codoser communicates key fraud prevention practices through FAQs, policies, and notifications.
50.2 Transparency deters malicious actors and builds trust among legitimate users.

 

51. Technology Updates

51.1 Fraud detection technology is updated frequently to counter evolving threats.
51.2 Legacy systems are phased out proactively to maintain a robust defense posture.

 

52. Policy Alignment and Consistency

52.1 This Policy is aligned with other internal policies, ensuring consistency in enforcement and risk coverage across all operational domains.

 

53. Non-Waiver

53.1 Failure by Codoser to enforce any provision of this Policy shall not be construed as a waiver of its rights to enforce the same or other provisions in the future.

 

54. Severability

54.1 If any clause of this Policy is found to be unenforceable by law, the remainder of the Policy shall continue in full force and effect.
54.2 Unenforceable provisions will be replaced with legally valid terms closest in intent.

 

55. Policy Review and Updates

55.1 This Policy is reviewed periodically to reflect:

  • Regulatory changes
  • Emerging fraud schemes
  • Technological advancements
    55.2 Reviews occur at least annually or after significant incidents.

 

56. Legal Liability

56.1 Users found engaging in fraud or risk-related misconduct are legally liable for any losses, damages, or penalties incurred by Codoser or other users.
56.2 Codoser reserves the right to recover losses through legal action.

 

57. Jurisdiction and Governing Law

57.1 This Policy is governed by Indian laws, including the Information Technology Act, DPDP Act, and relevant international AML/fraud frameworks.
57.2 Jurisdiction follows the Terms of Use and applicable legal treaties for cross-border cases.

 

58. Policy Modifications

58.1 Codoser may modify or update this Policy at any time to address new risks or regulatory changes.
58.2 Updates are published on the platform, and continued use implies acceptance.

 

59. Integration with Platform Governance

59.1 Fraud prevention and risk management are integrated into all core business operations, including onboarding, payments, data security, and customer support.
59.2 This holistic approach ensures end-to-end protection.

 

60. User Acknowledgment

60.1 By using Codoser, users acknowledge that they have read, understood, and agreed to this Risk Management & Fraud Prevention Policy.
60.2 Compliance is mandatory for all authors, buyers, affiliates, employees, and third parties interacting with the platform.

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