Monitoring and customer protection

MRL Group Ltd.
Company No.: 514288588
Address: 2 Menorat Hamaor St., Tel Aviv, Israel
Email: business@finholy.com

1. Introduction

This document defines the governance, monitoring standards, consumer protection principles, transparency obligations, and complaints-handling procedures of MRL Group Ltd. (“the Company”), operator of a digital wallet and payment services platform (“the Service”, “the Wallet”).

The framework ensures:

  • Compliance with applicable regulations in Israel and internationally
  • A robust system of monitoring and reporting
  • Fair, transparent, and safe consumer experience
  • Appropriate support for vulnerable customers
  • Clear procedures for handling complaints and disputes
  • Effective protection of customers’ funds and personal data

This document forms part of the Company’s compliance and operational governance system.

2. Reporting & Monitoring
2.1 Purpose of Monitoring

The Company maintains continuous monitoring for the following objectives:

  • Detection of suspicious or fraudulent activity
  • AML/CTF compliance
  • Fraud prevention
  • Real-time risk management
  • Service stability and reliability
  • Performance measurement and KPI tracking
  • Regulatory compliance reporting


2.2 Types of Reports

Daily Reports

  • Incoming and outgoing transactions
  • Suspicious or unusual activities
  • System downtime or technical failures
  • KYC/verification activity logs
  • Rejected or failed transactions

Weekly Reports

  • Fraud and risk activity summaries
  • Customer support activity and response times
  • Consumer experience metrics
  • User behaviour monitoring

Monthly / Quarterly Reports

  • AML/CTF compliance reports
  • Executive operational reports
  • Customer complaints report
  • Risk assessments
  • Account activity summaries


2.3 Monitoring Tools

The Company uses:

  • Real-time alerting systems
  • Fraud-detection systems (rule-based & machine learning)
  • API monitoring dashboards
  • Audit logs and system event tracking
  • Internal compliance dashboards
  • Ticketing systems for customer support


2.4 Escalation Process

Events triggering an escalation include:

  • Suspicion of fraud or financial crime
  • Repeated transaction failures
  • System malfunction affecting customers
  • Breaches of AML/CTF thresholds
  • Complaints indicating systemic issues

Escalations may be routed to:

  • Compliance Officer
  • AML/CTF Officer
  • CTO / Technical Operations
  • CEO (in serious cases)


3. Consumer Experience (CX)
3.1 Core Principles

The Company commits to delivering a high-quality consumer experience based on:

  • Ease of use
  • Clear user interface
  • Fast and smooth transaction flow
  • Accessibility for all users
  • Transparent and accurate information
  • Availability and reliability of the service


3.2 Service Standards

  • Fast onboarding and identity verification
  • Intuitive UI/UX across mobile and web
  • Clear display of transactions, balances, and statuses
  • Minimal friction in performing actions
  • Clear communication of issues or delays


3.3 CX Performance Indicators (KPIs)

  • Complaint ratio
  • Average response and resolution times
  • Transaction success rate
  • User satisfaction and retention
  • System uptime percentages


4. Fairness & Transparency
4.1 Fair Treatment of Customers

The Company ensures that customers are treated fairly at every stage:

  • No misleading or unclear information
  • Full disclosure regarding the nature of services
  • Clear explanation of required documentation
  • Fair access to services without discrimination


4.2 Transparency Measures

The Company provides:

  • Clear transaction status updates
  • Disclosure of fees (where applicable)
  • Disclosure of reasons for declined transactions (unless prohibited by law)
  • Notification of material changes to the service


4.3 Communication Practices

  • Notices sent through app notifications, email, or website updates
  • All communications written in clear, non-technical language
  • Important updates highlighted prominently for user awareness


5. Support for Vulnerable Customers
5.1 Definition of Vulnerable Customers

Vulnerable customers may include individuals who struggle due to:

  • Physical or cognitive disabilities
  • Mental health conditions
  • Financial distress
  • Limited digital literacy
  • Language barriers
  • Emergency situations


5.2 Tailored Support Measures

The Company ensures:

  • Ability to reach human support when needed
  • More detailed explanations for essential procedures
  • Avoidance of automated decisions that may harm vulnerable users
  • Extra guidance for complex financial activities


5.3 Proactive Identification

Indicators may include:

  • Repeated failed verification attempts
  • Confusion regarding routine actions
  • Frequent customer support requests

When detected, the Company provides enhanced support.


6. Complaints Handling & Dispute Resolution
6.1 Submitting a Complaint

Customers may submit complaints via:
📧 Email: business@finholy.com
🌐 Web-based form (if available)
📱 In-app support chat

6.2 Service Level Agreements (SLAs)

  • Acknowledgment: within 24 hours
  • Initial response: within 3 business days
  • Full resolution: based on complexity


6.3 Types of Complaints

  • Technical malfunctions
  • Delayed transactions
  • Unauthorized or incorrect charges
  • Service quality issues
  • Fraud concerns


6.4 Investigation Process

  • Review of system logs
  • Validation with third-party providers (banks, processors)
  • Internal compliance checks
  • Preparation of a detailed internal report
  • Issuing a written, reasoned decision to the customer


6.5 Escalation Path

  • Senior Support Specialist
  • Compliance Department
  • Legal Department (if needed)
  • External Dispute Resolution (regulator/court), if required


7. Customer Protection
7.1 Protection Principles

  • Safeguarding of funds
  • Strong data protection
  • Prevention of fraud and unauthorized use
  • Clear customer communication
  • Compliance with AML/CTF regulations


7.2 Technical Protection Measures

  • Data encryption at rest and in transit
  • 2-Factor Authentication (2FA)
  • Device identification
  • Transaction risk scoring
  • Real-time fraud monitoring
  • Secure cloud infrastructure


7.3 Protection of Customer Funds

  • Segregated accounts (where applicable)
  • No use of customer funds for Company operations
  • Immediate availability of funds (subject to compliance checks)


7.4 Data Protection

Aligned with:

  • Israel Privacy Protection Law
  • GDPR (where applicable)
  • Company Privacy Policy


8. Governance & Compliance Structure

The Company maintains a strong corporate governance and compliance system including:

  • Chief Compliance Officer (CCO)
  • AML/CTF Officer
  • Chief Information Security Officer (CISO)
  • CTO (Technology Governance)
  • Risk Management Committee
  • External Accountant & Auditor

These roles ensure ongoing compliance with financial, operational, and privacy regulations.

Back