Zil Money is a financial technology company, not a bank or an FDIC member. Zil Money offers banking services through partnership with FDIC member banks Silicon Valley Bank and Texas National Bank.






This “Transaction Dispute and Unauthorized Transfers Management Policy and Procedures” (hereinafter referred to as the “Manual”) is implemented by Zil Money Corporation (hereinafter referred to as “Zil Money”). The manual provides a comprehensive guide on how we efficiently and effectively manage transaction disputes and unauthorized transfers, while prioritizing compliance with all applicable legal requirements, industry standards, and international best practices in the payment processing industry.


(a) Purpose:

At Zil Money, we recognize the critical significance of safeguarding our registered customers’ interests and ensuring transparency in our operations. The primary purpose of this manual is to provide a testament to our dedication in resolving transaction disputes promptly and mitigating unauthorized transfers to uphold the integrity of our services.


(b) Scope:

This manual encompasses detailed procedures that address various types of transaction disputes and unauthorized transfers. We aim to provide an exceptional customer experience by adhering to strict timelines and adopting a customer-focused approach in our resolution process.


(c) Alignment with Regulatory Requirements and Industry Standard Best Practices:

Throughout the development of this manual, we have collaborated diligently with our banking partners, and service partners, and taken into account our commitment to compliance with the relevant regulatory requirements and adherence to industry best practices.


(d) Continuous Improvement:

Zil Money is dedicated to continual improvement and refinement of our procedures to enhance customer satisfaction and maintain our reputation as a reliable and compliant fintech platform. We understand that the landscape of payment processing is dynamic, and we are committed to evolving our practices to adapt to emerging challenges and advancements in the industry.



This section outlines Zil Money’s procedures for effectively managing transaction disputes to ensure a seamless experience for our valued customers.


(a) Types of Transaction Disputes:

Transaction disputes can arise from various situations, such as unauthorized charges, incorrect billing, or failed payments. Zil Money recognizes the importance of promptly addressing these disputes to provide swift resolution and maintain customer satisfaction. Our comprehensive approach includes categorizing and understanding the different types of transaction disputes, enabling us to tailor our responses based on the specific issue at hand.


(b) Reporting and Tracking Procedures:

To streamline the dispute resolution process, Zil Money has established efficient reporting and tracking procedures. Our customers can conveniently report disputes through multiple channels, including online platforms and customer support. Once a dispute is reported, we meticulously track its progress, ensuring no case is overlooked and all parties are informed of the resolution status.


(c) Timelines for Dispute Resolution:

We understand the urgency of resolving transaction disputes promptly. Zil Money adheres to strict timelines for each stage of the dispute resolution process. Our dedicated team is committed to expediting the investigation and resolution to minimize any inconvenience caused to our customers. The defined timelines enable us to provide timely updates and ensure transparent communication throughout the resolution process.


(d) Escalation Matrix:

In rare cases where disputes require further attention, Zil Money has a structured escalation matrix in place. This matrix outlines the escalation path, ensuring that complex cases are promptly elevated to the appropriate levels of management. The escalation process is designed to prioritize customer concerns and facilitate expedited resolutions.




This section outlines Zil Money’s comprehensive approach to effectively managing unauthorized transfers to safeguard the financial interests of our valued customers.


(a) Detection and Investigation:

Zil Money maintains a vigilant system for detecting unauthorized transfers promptly. We employ sophisticated fraud detection mechanisms and real-time monitoring to identify any suspicious activities. Upon detecting an unauthorized transfer, our dedicated investigation team promptly initiates a thorough inquiry to ascertain the root cause and prevent further unauthorized transactions.


Our investigation process involves gathering and analyzing relevant transaction data, verifying customer details, and coordinating with financial institutions and authorities, where necessary. This meticulous approach ensures that unauthorized transfers are detected early and resolved expeditiously.


(b) Containment and Recovery Strategies:

In the event of an unauthorized transfer, Zil Money promptly takes containment measures to minimize potential financial losses for our customers. We employ robust containment strategies to prevent unauthorized transfers from spreading to other accounts or causing further disruptions.


Simultaneously, our team diligently works on the recovery of lost funds, where feasible and permissible under the applicable regulations. Zil Money maintains close communication with affected customers throughout the recovery process, ensuring transparency and providing updates on the status of the recovery efforts.



This section outlines Zil Money’s rigorous processes for customer verification and authorization, ensuring the security and legitimacy of all transactions.


(a) Account Verification Process:

Zil Money implements a strict account verification process to confirm the identity and ownership of our customers. When users sign up for our services, they undergo a thorough verification procedure. This process includes validating personal information, verifying business details (if applicable), and authenticating ownership of the provided bank account.


(b) Payment Modality Verification:

For each payment modality offered by Zil Money, customers undergo a specific verification process. Whether it’s ACH, wire transfers, virtual Visa cards, or other payment methods, we follow industry best practices to ensure the security and authenticity of each transaction. The verification process is tailored to the requirements of each payment modality, assuring a seamless and secure experience for our customers.


(c) Authorization Forms and Consent:

Obtaining proper authorization from our customers is paramount to maintain the integrity of our services. Zil Money requires customers to complete authorization forms, clearly indicating their consent for specific transactions. These forms are securely stored and accessible only to authorized personnel. We maintain transparent communication with our customers throughout the authorization process, ensuring they understand the terms and conditions associated with their transactions.



This section outlines the specific procedures involved in the ACH payment modality at Zil Money.


(a) Bank Account Connection and Verification:

To utilize the ACH payment modality, customers are required to connect their bank accounts with our system. Zil Money implements a rigorous verification process to ensure the security and legitimacy of each connected bank account. This process involves verifying the ownership and authenticity of the provided bank account through trusted methods such as Yodlee or the micro deposit method.


(b) ACH Authorization Form:

Upon successful bank account verification, customers are required to complete the ACH authorization form. This form serves as explicit consent for ACH transactions and confirms the customer’s agreement to the terms and conditions associated with this payment modality. A signed copy of the form is generated for record-keeping purposes.


(c) Automated and Manual Verification:

Zil Money employs a dual verification approach for ACH transactions to ensure compliance with regulations set by NACHA. All ACH transactions undergo both automated and manual verification processes. Automated verification utilizes advanced fraud detection mechanisms, while manual verification involves meticulous scrutiny by our dedicated team. This comprehensive verification process minimizes the risk of unauthorized transactions and ensures that only authorized users can conduct ACH transactions.


Zil Money’s ACH payment modality procedures reflect our commitment to maintaining the highest standards of security and efficiency for our customers’ financial transactions. By adhering to stringent verification protocols and obtaining explicit authorization, we safeguard our customers’ interests and uphold the integrity of our payment processing services.



This section outlines the specific procedures involved in credit card payments at Zil Money, ensuring secure and reliable transactions.


(a) Restricted Access and Verification Levels:

Credit card payment rails at Zil Money are subject to restricted access and verification levels. Customers are required to provide specific documents to verify their identity and ownership of the credit card. These measures ensure the security and legitimacy of credit card transactions.


(b) Required Documents for Credit Card Payments:

To facilitate credit card payments, customers must submit essential documents, including an image of the credit card with the name and last four digits visible, as well as an invoice for the payment. These documents are crucial for the credit card payment process.


(c) Credit Card Authorization Form:

For each credit card transaction, customers are required to complete a credit card authorization form. This form serves as explicit consent for the credit card transaction and confirms the customer’s agreement to the associated terms and conditions. A certificate of completion is generated for record-keeping purposes.


(d) Manual Verification and Approval:

Every credit card transaction undergoes manual verification and approval by our diligent team. The team cross-checks all provided details and documents to ensure the legitimacy of the transaction. The approval or rejection decision is based on this thorough verification process, ensuring the utmost security and accuracy in credit card payments.


Zil Money’s credit card payment procedures prioritize customer security and satisfaction. By adhering to strict verification protocols and obtaining explicit authorization, the company ensures the safety of credit card transactions, offering a seamless experience for its customers.



This section outlines Zil Money’s meticulous approach to record keeping and documentation, in compliance with relevant legal and regulatory requirements, and adhering to industry standard international best practices.


(a) Documentation of Verification and Authorization:

Zil Money maintains comprehensive documentation of customer verification and authorization processes. This includes records of account verification, payment modality verification, and authorization forms. These documents are securely stored and easily accessible for reference and auditing purposes.


(b) Dispute Log and Monthly Submission:

To streamline dispute resolution, Zil Money maintains a detailed dispute log for each reported dispute. The log includes relevant information about the dispute, investigation progress, and resolution status. Additionally, the company adheres to the requirements of service partners by promptly submitting dispute logs on a monthly basis. This proactive approach helps ensure transparency and efficiency in dispute resolution processes.


(c) Record Retention for Compliance:

Zil Money follows strict record retention practices to meet regulatory compliance requirements. Relevant records, including customer verification documents, authorization forms, and dispute logs, are retained for the prescribed period as mandated by applicable laws and regulations. The company ensures that all records are securely stored and accessible only to authorized personnel.



This section outlines Zil Money’s approach to managing third-party compliance responsibilities.


(a) Agreements with Third Parties for Dispute Processing:

Zil Money enters into agreements with third-party service providers for dispute processing to ensure efficient and reliable resolution of transaction disputes. These agreements outline the roles, responsibilities, and compliance requirements of each party involved in the dispute resolution process. Zil Money conducts thorough due diligence on its third-party partners to ensure they meet the highest standards of security and compliance.


(b) Oversight and Monitoring:

Zil Money maintains rigorous oversight and monitoring of its third-party partners. The company regularly assesses the performance and effectiveness of third-party dispute processing services to ensure the timely and accurate resolution of disputes. Additionally, Zil Money conducts periodic audits and reviews to verify the compliance of its partners with the agreed-upon terms and legal obligations.


Effective management of third-party compliance responsibilities is crucial to Zil Money’s commitment to providing secure and efficient payment processing services. By establishing clear agreements and conducting ongoing oversight, the company ensures that its partners meet the same high standards of compliance and customer-centric approach upheld by Zil Money.



This section outlines Zil Money’s comprehensive approach to staff training and awareness, ensuring employees are well-equipped to handle transaction disputes and unauthorized transfers in compliance with relevant laws, rules, and regulations, and industry standard international best practices.


(a) Training on Dispute and Unauthorized Transfer Handling:

Zil Money prioritizes the training of its staff to effectively handle transaction disputes and unauthorized transfers. New employees undergo thorough onboarding training that includes detailed procedures on dispute resolution and unauthorized transfer management. This training covers the identification of different types of disputes, investigation techniques, and the escalation process. Furthermore, employees are educated on regulatory compliance requirements to ensure they adhere to the highest standards of security and accuracy.


(b) Periodic Training Updates:

Zil Money recognizes the dynamic nature of the payment processing industry and the evolving landscape of transaction disputes and unauthorized transfers. To ensure that staff remains up-to-date with the latest practices and regulations, periodic training updates are conducted. These updates reinforce the importance of adhering to industry best practices and provide insights into emerging trends and strategies for efficient dispute resolution.


Ensuring staff members are well-trained and aware of their responsibilities is essential to Zil Money’s commitment to providing exceptional service to customers while maintaining a secure and compliant environment. By investing in continuous training and awareness initiatives, Zil Money upholds its dedication to the highest standards of performance and customer satisfaction.