Anti-Fraud Policy

WHEREAS:

• Global music distribution requires the protection of legitimate rights holders, digital Platforms, Clients, payment processors, and the integrity of reports;
• An algorithmic or statistical alert is an indicator that must be assessed in context and does not constitute an automatic determination;
• UMW must preserve evidence, provide a meaningful opportunity to respond, and adopt measures proportionate to the specific risk;
• Royalties associated with artificial activity, impersonation, document fraud, or unauthorized use do not become payable merely because they appear in a preliminary metric;
• Every material decision must be linked to an identifiable Case File, human review, and an available reconsideration procedure.

UMW issues this public protocol to explain the indicators, measures, safeguards, and outcomes of its anti-fraud system.

Case protocol: AF-UMW

Governing Principle: An alert may open or prioritize a Case File. It does not, by itself, constitute a finding of fraud.

• Case File Channel: Anti-fraud;
• Application to New Accounts and Orders: Upon acceptance;
• Existing Users: February 4, 2026, for material changes;
• Final Decision: Related evidence and human review.

This Policy explains how UMW investigates specific indicators involving Accounts, releases, streams, payments, documents, and claims. It does not authorize general holds based on an imprecise suspicion and does not convert an automated alert into conclusive evidence.

‍FIRST.— WHAT UMW PROTECTS.

UMW protects:

• legitimate catalogs;
• funds belonging to artists and labels;
• the integrity of reports;
• destination Platforms;
• owners of master recordings and compositions;
• payment methods;
• UMW Core and white-label Clients;
• the reputation of the distribution network.

‍SECOND.— SCOPE.

This Policy applies to:

• Accounts belonging to artists, labels, representatives, and companies;
• administrators and team users;
• audio, cover artwork, Metadata, and documents;
• distribution, Content ID, and UGC monetization;
• UMW Song Assets when an indicator affects a composition;
• payment requests, refunds, and chargebacks;
• white-label and API Clients;
• any person attempting to use a UMW Account or identity.

‍THIRD.— SYSTEMS AND REVIEW.

UMW may use:

• UMW Core validations;
• UMW Scan;
• audio, Metadata, and duplicate comparison;
• DSP and provider reports;
• rights-holder claims;
• access and change logs;
• payment processor alerts;
• documentation submitted by the Client;
• human review.

These tools help prioritize cases. A final termination, finding of intentional fraud, or loss of funds requires human review and related evidence.

‍FOURTH.— ARTIFICIAL STREAMING ACTIVITY.

Relevant indicators include:

• purchasing streams, followers, saves, or user-generated creations;
• using device or Account farms;
• using bots, scripts, or automated playback;
• incentivized traffic without a genuine audience;
• campaigns promising a guaranteed number of streams;
• abnormal concentration reported by a DSP;
• coordinated manipulation of searches, charts, or playlists;
• knowing participation in stream-exchange networks.

Not every instance of rapid growth constitutes fraud.

UMW must evaluate:

• country;
• source;
• campaign;
• history;
• DSP notice;
• the Client’s explanation.

‍FIFTH.— PROMOTION PROVIDERS.

The Client must be able to identify:

• the agency;
• campaign;
• applicable dates;
• budget;
• targeting;
• deliverables.

A statement that the Client did not know how traffic was generated does not automatically make the Client the author of fraud. However, it may demonstrate a lack of reasonable diligence when the Client purchased a manifestly artificial promise.

UMW recommends retaining:

• the agreement;
• invoice;
• advertising dashboard;
• links.

UMW does not recommend Services that sell:

• streams;
• guaranteed playlist placements;
• User Accounts.

‍SIXTH.— CATALOG AND RIGHTS FRAUD.

Serious indicators include:

• uploading another person’s master recording;
• copying a recording and changing its pitch, speed, or name;
• impersonating another artist or label;
• using cover artwork or a photograph without authorization;
• submitting a cover, remix, sample, or beat without the necessary license;
• declaring false splits, rights holders, or agreements;
• claiming a catalog owned by another company;
• resubmitting removed content through another Account;
• using Content ID to claim material that is not exclusive.

‍SEVENTH.— MISLEADING METADATA.

The following conduct is prohibited:

• identifying a well-known artist as a primary artist, featured artist, or collaborator without authorization;
• using names designed to divert searches;
• concealing that content is a remix, cover, live version, or contains explicit material;
• entering false titles, genres, or dates to circumvent controls;
• presenting shared-library audio as original content;
• creating nearly identical versions to saturate Platforms.

‍EIGHTH.— ARTIFICIAL INTELLIGENCE, VOICE, AND IDENTITY.

UMW may review synthetic or modified content when there is a risk involving:

• unauthorized voice cloning;
• deceptive imitation of a real person;
• deepfakes;
• unauthorized datasets or training material;
• false credits;
• spam generated at scale;
• infringement of DSP policies.

The use of artificial intelligence does not, by itself, constitute fraud.

The Client must:

• make any disclosures required by the Platform;
• retain the necessary rights in both the inputs and outputs.

‍NINTH.— IDENTITY, KYC, AND DOCUMENTS.

Fraud indicators include:

• an altered identification document or a document belonging to another person;
• a fictitious address, company, or representative;
• multiple Accounts created to evade measures;
• a payment Account with no reasonable relationship to the Rights Holder;
• impersonation of an artist, label, or UMW employee;
• a fabricated invoice or agreement;
• deliberate concealment of the ultimate beneficial owner when that information must be known.

UMW requests only the information reasonably necessary and provides a secure channel for sensitive documents.

‍TENTH.— PAYMENTS, REFUNDS, AND CHARGEBACKS.

UMW investigates:

• stolen payment cards or payment Accounts;
• unrecognized charges;
• duplicate refunds and chargebacks;
• repeated purchases followed by immediate withdrawal from Services already performed;
• manipulated invoices;
• suspicious changes to the beneficiary;
• unauthorized access to an Account containing a balance.

A good-faith chargeback will not automatically be classified as fraud.

‍ELEVENTH.— CONTENT ID.

The Client must not submit the following to Content ID:

• beats or instrumentals subject to non-exclusive licenses;
• commonly available loops;
• stock music or shared-library music;
• public-domain compositions without a clearly identifiable exclusive master recording;
• audio purchased with incompatible rights;
• material exclusively controlled by another company;
• content intended to generate abusive claims.

UMW may suspend claims and request agreements before keeping a reference active.

‍TWELFTH.— SOURCES OF AN INVESTIGATION.

A case may begin because of:

• a notice from Spotify, Apple Music, YouTube, Amazon Music, TikTok, or another Platform;
• a hold or adjustment appearing in a report;
• a documented claim from a Rights Holder;
• a match detected by UMW Scan;
• an error or pattern observed by a reviewer;
• a bank or payment processor alert;
• access activity;
• an internal report;
• information from a competent authority.

UMW will record the source of the indicator. When an instruction originates from a third party, UMW will not present it as UMW’s own conclusion.

‍THIRTEENTH.— OPENING THE CASE.

The Case File must contain:

• the case number;
• the Account;
• the release, UPC, ISRC, or Transaction;
• the period and Platform;
• the indicator and its source;
• the funds potentially affected;
• the provisional measure;
• the information requested;
• the responsible internal person;
• the next review date.

‍FOURTEENTH.— PROVISIONAL MEASURES.

Depending on the risk, UMW may:

• stop a delivery that has not yet been transmitted;
• change the status to Documents Needed;
• pause an update;
• transmit an urgent removal request;
• suspend Content ID;
• temporarily protect a payment request;
• block a compromised session;
• restrict an API credential.

Whenever possible, the measure will be limited to the related:

• content;
• period;
• technical Account;
• amount.

‍FIFTEENTH.— EXTERNAL HOLD AND INTERNAL RESERVE.

An External Hold occurs when a DSP, provider, bank, or authority withholds payment, blocks funds, or reverses a Transaction. UMW is not required to advance those funds. An Internal Reserve is a UMW decision concerning funds that have already been received or reconciled.

An Internal Reserve must identify:

• the reason;
• scope;
• review date;
• responsible person.

UMW will not describe an Internal Reserve as a DSP instruction when no such instruction exists.

‍SIXTEENTH.— NOTICE TO THE CLIENT.

Unless prohibited by law, necessary to prevent destruction of evidence, or required by a confidential investigation, UMW will communicate:

• the case number;
• the content or Transaction;
• the general reason;
• the measure adopted;
• the requested documents or explanation;
• the applicable period;
• the response channel;
• the possibility of an extension or appeal.

The ordinary initial period for acknowledging receipt and submitting a response is three (3) Business Days. Before expiration, the Client may request additional time to obtain agreements or information from third parties. UMW will grant a reasonable extension when there is no urgent external deadline. Failure to respond allows UMW to decide the case using the available information. Failure to respond does not, by itself, constitute an admission.

‍SEVENTEENTH.— USEFUL EVIDENCE.

‍EIGHTEENTH.— CLASSIFICATION.

Depending on the case, UMW may request:

• an agreement with an artist, label, or licensor;
• a split sheet;
• a production session, stems, or source files;
• a sample, beat, cover, or remix license;
• an invoice and promotion campaign information;
• a communication from the DSP;
• delivery history;
• evidence of identity or authority;
• evidence concerning the payment method;
• screenshots and links;
• a signed chronological explanation.

UMW must not request documents unrelated to the case without explaining why they are necessary.

18.1. NO INFRINGEMENT OR AFFECTED CLIENT.

The indicator resulted from an error, the Client was the victim of unauthorized access or an unauthorized campaign, or there is insufficient evidence.

UMW will:

• correct the status;
• release its own measures.

18.2. CORRECTABLE ERROR.

This classification may apply to:

• incorrect Metadata;
• an incomplete document;
• a first minor incident without demonstrated intent.

UMW will request correction.

18.3. MATERIAL RISK.

This classification may apply to:

• repeated incidents;
• a high-risk promotion provider;
• insufficiently documented rights;
• noncompliance that may result in a penalty.

18.4. SIGNIFICANT EVIDENCE.

This classification may apply to:

• a strong audio match;
• conflicting documents;
• artificial activity confirmed by a source;
• a documented claim.

It may require:

• removal;
• a related reserve.

18.5. INTENTIONAL OR SYSTEMATIC FRAUD.

This classification may apply to:

‍NINETEENTH.— REVIEW PERIODS.

• a pirated catalog;
• false documents;
• an Account network;
• circumvention;
• impersonation;
• payment fraud;
• organized abuse of Content ID.

It may justify:

• immediate termination;
• communication with competent third parties.

UMW endeavors to use the following review periods:

• standard case: decision within fifteen (15) Business Days;
• extended review: up to thirty (30) Business Days;
• case depending on a DSP, Claimant, or expert analysis: up to ninety (90) calendar days;
• update at least every fifteen (15) days when the standard period is exceeded.

‍TWENTIETH.— DECISION.

An Internal Reserve lasting longer than ninety (90) days requires:

• approval from Management, Legal, or Compliance;
• a written explanation;
• a new review date.

External Holds will be reviewed at least every thirty (30) days while the source keeps the case open.

‍TWENTY-FIRST.— FUNDS.

The decision must identify:

• established facts;
• unproven facts;
• principal evidence;
• classification;
• affected content and amount;
• the measure adopted;
• any correction or release;
• the status of an External Instruction;
• the available appeal.

UMW will not publicly make accusations against a Client unless disclosure is required or there is a legitimate and proportionate need.

An investigation does not convert royalties into UMW property.

UMW may:

‍TWENTY-SECOND.— FALSE POSITIVES.

• keep segregated an amount withheld by a source;
• reserve an amount reasonably exposed to reversal;
• reflect a confirmed adjustment;
• offset a liquidated, due, and documented obligation when permitted by the applicable agreement.

UMW may not charge a legitimate track for:

• estimated damages relating to another track;
• future legal fees;
• the company’s general business risk.

‍TWENTY-THIRD.— APPEAL.

When UMW determines that an alert was incorrect, it will:

• remove its Internal Measures;
• correct the status;
• release the legitimate balance;
• transmit reasonable corrections through the affected route;
• record the cause;
• adjust the rule or review process to reduce recurrence when reasonably possible.

UMW does not guarantee that a DSP will reverse its own decision. UMW must, however, provide the information under its control that may reasonably assist.

The Client may appeal within fifteen (15) Business Days after the decision.

The appeal must identify:

• the case;
• the alleged error;
• supporting evidence.

The appeal will be reviewed by:

• a person other than the person who issued the final decision;
• or a more senior review level.

‍TWENTY-FOURTH.— COMPROMISED ACCOUNT.

UMW will:

• acknowledge receipt within two (2) Business Days;
• endeavor to decide the appeal within thirty (30) Business Days;
• provide updates when the decision depends on third parties.

A late appeal may be accepted because of:

• lack of notice;
• force majeure;
• material new evidence;
• a compromised Account;
• a Platform error.

‍TWENTY-FIFTH.— PERSONAL DATA AND AUTOMATED DECISIONS.

When the Client reports unauthorized access, UMW will prioritize:

1. blocking sessions and credentials;
2. protecting beneficiary changes;
3. preserving logs;
4. verifying the Rights Holder;
5. reversing internal changes when possible;
6. separately analyzing the attacker’s conduct.

The victim will not be treated as the author of the conduct solely because the action occurred through the victim’s Account.

Processing is governed by the Privacy Policy. When a decision produces a material effect, UMW will provide general information regarding the factors used, without disclosing rules that would facilitate circumvention.

The affected person may:

• submit evidence;
• request human review.

UMW will not use identification documents, biometric data, or anti-fraud Case Files to train generative models.

Each Case File must identify:

• the purpose;
• categories of personal data;
• source;
• access;
• disclosure;
• retention period;
• final disposition.

Personal data will be limited to the case.

A closed investigation does not authorize UMW to:

• retain complete copies of documents indefinitely;
• reuse the information for marketing.

When information originates from a DSP, processor, Claimant, or another external source, UMW will distinguish the received indicator from its own conclusion.

When accuracy is disputed, the Case File will retain:

• the challenge;
• the outcome of the review.

The DPO may supervise the lawfulness, proportionality, and traceability of personal data processing.

‍TWENTY-SIXTH.— COMMUNICATION WITH PLATFORMS AND AUTHORITIES.

The DPO:

• does not direct the investigation;
• does not classify fraud;
• does not implement the controls the DPO must subsequently supervise.

When an anti-fraud tool uses artificial intelligence to process personal data, UMW will:

• document the processing and relevant decisions in its Record of Processing Activities;
• explain the automated nature of the processing in an understandable manner;
• conduct risk management and an impact assessment when applicable;
• implement security measures;
• audit the system according to its level of risk.

The person retains the rights to information, objection, and review provided under applicable law.

‍TWENTY-SEVENTH.— RELATIONSHIP WITH OTHER POLICIES.

UMW may communicate necessary information to a DSP, provider, bank, Claimant, or authority when there is a contractual or legal basis.

UMW will:

• limit the communication to the case;
• retain a record of the disclosure.

A criminal complaint or regulatory report will be based on facts and legal review. It will not be used as a debt-collection threat.

‍TWENTY-EIGHTH.— CONTACT.

The Acceptable Use Rules define permitted conduct. The Royalties Policy governs statements and payments. The DMCA Policy governs copyright notices.

When there is a conflict concerning the anti-fraud procedure, this document prevails, except where:

• a mandatory right applies;
• an Order provides greater protection.

UMW Anti-Fraud
Anti-fraud
Subject line:
Anti-Fraud Case [number] — [Account or UPC]
Do not send passwords, complete payment card numbers, or sensitive documents without using the secure channel identified by UMW.

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