Anti-Fraud Policy

Table of Contents:

Purpose and Scope
Policy Statement
Non-Exhaustive Examples of Fraud and Abuse
Detection and Prevention Measures
Response to Suspected Fraud
Enforcement Framework
Royalty Retention, Escrow, and Documentation
Content Actions
Appeals and Review Process
Remedy for System Error
Cooperation and Disclosures
Governing Law; Precedence
Policy Updates
Contact and Support

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1) Purpose and Scope

UMW Recordings Inc. maintains this Anti-Fraud Policy to protect legitimate creators, labels, rights holders, commercial partners, payment systems, and the long-term integrity of its services.

This Policy applies to all users, accounts, releases, catalogs, submissions, payments, royalty activity, onboarding processes, verification workflows, and related services made available by UMW, including white label and platform-related environments where applicable.

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2) Policy Statement

Fraud, abuse, deception, manipulation, and evasion are strictly prohibited. UMW may investigate suspected misconduct, request supporting documentation, delay or restrict services, hold royalties, suspend features, remove content, reject submissions, or terminate accounts where reasonably necessary to protect platform integrity, legal compliance, commercial partners, or third-party rights.

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3) Definitions

For purposes of this Policy:

“Fraud” includes any deceptive, misleading, manipulative, forged, unauthorized, or intentionally evasive conduct affecting account access, identity, payments, content, rights claims, royalties, traffic, reporting, or platform integrity.

“Artificial Engagement” includes fake or manipulated streams, plays, followers, saves, views, likes, user activity, monetization, or other performance metrics generated through bots, click farms, loop streaming, incentivized manipulation, device farms, or comparable methods.

“Verification” includes identity checks, KYC/KYB review, rights confirmation, payment verification, artist verification, beneficial ownership review, and related compliance steps.

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4) Non-Exhaustive Examples of Fraud and Abuse

The following are examples only and are not exhaustive:

A. Artificial Streaming / Engagement Manipulation

Use of bots, click farms, device farms, paid stream schemes, loop streaming, deceptive campaign structures, fake followers, or any method intended to inflate rankings, visibility, monetization, or royalties.

B. Rights Misrepresentation

Submitting content without the required rights, providing false ownership claims, forged licenses, fabricated permissions, inaccurate contributor information, false writer splits, misleading metadata, or deceptive territorial claims.

C. Identity, Payment, or Account Abuse

Use of stolen payment methods, unauthorized payment activity, false identity information, forged identity documents, account takeovers, account sharing intended to evade controls, or use of multiple accounts to bypass restrictions.

D. Evasion and Repeat Abuse

Creating replacement accounts after enforcement, resubmitting blocked content without curing the issue, circumventing verification requests, concealing control relationships between accounts, or providing incomplete, inconsistent, or misleading documentation.

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5) Detection and Prevention Measures

UMW may use manual review, automated signals, risk scoring, anomaly detection, third-party alerts, DSP notices, payment-processor reports, verification workflows, metadata review, behavioral analysis, and other reasonable operational controls to identify fraud risk.

UMW reserves the right to request supporting documentation at any time, including but not limited to:

• identity documents;
• business registration materials;
• contracts, licenses, or authorization letters;
• publishing splits or writer confirmations;
• invoices or receipts supporting lawful acquisition of rights;
• payment verification records; or
• any other documentation reasonably required for compliance or authenticity review.

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6) Response to Suspected Fraud

Where fraud risk is suspected, UMW may impose temporary protective measures, including:

• payout holds;
• feature limitations;
• release delays;
• verification holds;
• restricted access to dashboard functions;
• distribution suspensions;
• provisional content takedowns; or
• enhanced manual review.

Temporary measures will be reviewed within a reasonable timeframe. Standard cases are generally reviewed within up to sixty (60) days, although a longer period may be necessary where complexity, legal requirements, DSP dependency, payment-processor review, unresolved rights conflicts, or elevated platform risk so require.

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7) Enforcement Framework (Severity Levels UM1–UM4)

UMW uses severity levels to support proportional enforcement.

UM1 — Minor / Correctable Issues
Examples: honest metadata errors, incomplete credits, minor inconsistencies, first-time documentation gaps.
Typical response: advisory notice, correction request, release delay, or enhanced review.

UM2 — Moderate Deception / Elevated Risk
Examples: repeated misleading metadata, suspicious promotional vendors, questionable attribution, inconsistent documentation, elevated payment risk.
Typical response: formal warning, enhanced verification, temporary restrictions, payout hold, or content hold.

UM3 — Artificial Engagement / Serious Abuse
Examples: strong artificial-streaming indicators, manipulative campaigns, coordinated fake activity, serious misuse of platform functions, materially misleading rights claims.
Typical response: functionality block, release hold or takedown, royalty freeze, escalated human review, suspension, or partner notification where justified.

UM4 — Deliberate or Repeated Fraud / Evasion
Examples: repeated UM3 conduct, forged documents, organized fraud, repeated payment abuse, repeat evasion, account replacement strategies, or deliberate platform manipulation.
Typical response: account termination, permanent restrictions, royalty retention where contractually or legally permitted, refusal of future service, and disclosure to relevant processors, partners, rights holders, or authorities where appropriate.

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8) Royalty Retention, Set-Off, Documentation, and Evidence Preservation

A. Royalty Retention and Reserve Measures

UMW may temporarily retain royalties, create reserves, delay payouts, or suspend disbursements where reasonably necessary due to fraud review, rights uncertainty, processor risk, third-party claims, DSP notices, or legal/compliance requirements.

B. Documentation Requests

Users must provide requested documentation within the timeframe reasonably specified by UMW. Failure to cooperate may result in continued holds, removal of content, account restrictions, or denial of payouts.

C. Set-Off, DSP Adjustments, Chargebacks, and Negative Balances

UMW may offset amounts owed to UMW against royalties or other sums otherwise payable to the user, including amounts arising from fraud-related clawbacks, DSP adjustments, penalties, refunds, fines, chargebacks, processor fees, or related losses.

If a negative balance results, the user remains responsible for repayment within thirty (30) days of notice, unless a longer period is agreed in writing.

D. Evidence Preservation

UMW may preserve relevant logs, detection reports, case materials, financial records, communications, and associated evidence for up to thirty-six (36) months from case closure, or longer where required by law, legal process, audit obligations, dispute resolution needs, or platform protection requirements.

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9) Content Actions (Blocking, Removal, and Corrections)

UMW may, where reasonably necessary:

• block or delay releases pending verification;
• remove or disable access to content linked to fraud or serious abuse;
• require metadata corrections, ownership corrections, or supporting documentation;
• restrict future submissions;
• notify DSPs, processors, or partners of confirmed or materially supported abuse signals where appropriate; and
• preserve records for enforcement, audit, legal, or dispute purposes.

Copyright-specific complaints and takedown matters may also be handled under the applicable DMCA / Copyright Policy.

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10) Appeals and Review Process

Users may submit a formal appeal within fifteen (15) business days of notification of the relevant action.

UMW aims to:

• acknowledge receipt within two (2) business days;
• provide a substantive update within fifteen (15) business days; and
• resolve standard cases within approximately thirty (30) to forty-five (45) days, subject to case complexity, third-party cooperation, legal requirements, unresolved rights issues, processor reviews, or platform risk.

UM3 and UM4 enforcement actions are subject to human review prior to final enforcement where reasonably feasible.

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11) Remedy for System Error / False Positives

If UMW determines that an enforcement action was made in error, UMW may, where feasible and appropriate:

• restore access and/or distribution;
• return legitimately earned royalties that were incorrectly held, subject to DSP reporting and settlement timing;
• reverse internal restrictions where appropriate; and
• document corrective measures internally to reduce recurrence.

Nothing in this section obligates UMW to restore access or release amounts where third-party reversals, unresolved legal restrictions, processor actions, or rights disputes remain in effect.

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12) Cooperation and Disclosures

UMW may share relevant information with DSPs, payment processors, vendors, rights holders, advisers, regulators, or competent authorities where reasonably necessary to:

• comply with law or legal process;
• prevent or investigate fraud;
• enforce policies or contracts;
• protect users, rights holders, partners, or platform integrity; or
• resolve disputes or compliance matters.

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13) Governing Law and Precedence

This Policy is governed by the laws of the Republic of Ecuador.

Any dispute relating to this Policy shall be resolved in the competent courts of Guayaquil, Ecuador, unless mandatory law requires otherwise.

In the event of conflict, the following order of precedence applies, unless a signed written agreement expressly states otherwise:

1. Terms & Conditions
2. Anti-Fraud Policy
3. Acceptable Use Policy
4. Other published platform guidelines

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14) Policy Updates

UMW may update this Policy from time to time to reflect legal, technical, operational, fraud-risk, or compliance changes. Updates become effective upon posting on the website together with a revised “Last Updated” date, unless a different effective date is expressly stated.

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15) Contact and Support

For anti-fraud questions, compliance documentation, or appeal submissions, please contact:

UMW Recordings Inc.
Email: antifraud@umwrecordingsinc.com
Phone: +593 96 801 6285
Address: Av. Francisco de Orellana, Guayaquil 090512, Ecuador

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