1 Recent e mail exchange between NS&I & Curve (2 September 2021 to 6 Octo ber 2021) Exemptions applicable X Personal information – section 40 (2) of F reedom of Information Act 2000 (FOIA) ***** Commercial interests – section (43 (2) of FOIA xxxxx Law enforcement (the prevention or detection of crime) – section 31 (1a) of FOIA Emails From: xxxxxxxxxxxxxxxxxxxxxx < @curve.com > Sent: 02 September 2021 09:04 To: Henry, Paul < Paul.Henry@nsandi.com > Subject: [External:]Fwd : Money - go - round transactions at NS&I via Creation, Curve, Revolut and Virgin This message is from an EXTERNAL SENDER - be CAUTIOUS , particularly with files and attachments Hi Paul, I wanted to drop you a line following on from the recent email corres pondence with Mr. xxxxxxxx Although he wrote to you directly and Curve were copied in, I wrote back to Mr. xxxxxxxx yesterday to confirm that we have heard his concerns regarding loyalty points and air miles and the steps we take to identify and prevent e xcessive gaming as a breach of our Term s of Service. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx If there is more that we could do to work together and/or share information I would be very happy to do so. I think the point that he made about the MCC does have some merit. I would be interested in your thoughts. Best regards xxxxxx ------------------- --------------------------------------------------------------------------------------------- On Thu, 2 Sept 2021 at 10:05, Henry, Paul < Paul.Henry@nsandi.com > wrote: Hi xxxxxx I hope all is well with you and yours, regarding the correspondence that we rec eived from Mr x back in March and more recently, I’ve set up a working group to look into his allegations. I think it worth mentioning that at present we do not believe the activity that Mr x objects to is neither illegal nor money laundering and that this activity should be the primary concern of the reward card issuers. Nonetheless this activity does breach our Terms & Conditions in as much as deposits with NS&I should come from either a UK Bank or Buildi ng Society account which technically e - money issuers such as Curve and others are not. We also operate the expected controls to identify and detect ML 2 and fraud activity much as you describe and our systems regularly detect and report revolving transaction s such as these. Historically where we have been provided with appropriate source of funds we have not closed the account and where the customer has declared the use of a credit card we have asked them to cease and desist. We are investigating the use of t he proper MCC codes with our payments partne r and will be responding to Mr x shortly with our answers to his concerns. Happy to set up a call if you think it will be mutually beneficial? Best Paul Henry Risk and Compliance Director NS&I I Drummond Gate Pimlico London SW1V 2QX m xxxxxxxxxxx e paul.henry@nsandi.com www.nsandi.com ---------------------------------------------------------------------------------------------------------------- From: xxxxxxxxxxxxxxx < @curve.com > Sent: 02 September 2021 11:15 To: Henry, Paul < Paul.Henry@nsandi.com > Subject: [External:]Re: [External:]Fw d: Money - go - round transactions at NS&I via Creation, Curve, Revolut and Virgin This message is from an EXTERNAL SENDER - be CAUTIOUS , particularly with files and attachments Hi Paul, Thanks for coming back to me, it sounds as if we are in a very similar position. Like you, we hold the view that this is not laundering, but does run contrary to terms of service. Curve passes the MCC information back to the underlying funding cards so the banks are also free to detect excessive collection of points a nd take action against excessive reward point collection if they have the appetite to do so. NS&I are *************** , so it would probably be good for us to speak. I am getting some further data together so perhaps we could catch up next week when I ha ve that to hand? 3 Best Regards xxxxxx ---------------------------------------------------------------------------------------------------------------- On Mon, 13 Sept 2021 at 16:21, Henry, Paul < Paul.Henry@nsandi.com > wrote: Hi xxxxxx I’ve just notice d that you’ve declined our meeting, do you wish to rearrange? Best Paul Henry Risk and Compliance Director NS&I I Drummond Gate Pimlico London SW1V 2QX m xxxxxxxxxxx e paul.henry@nsandi.com www.nsandi.com ---------------------------------------------------------------------------------------------------------------- From: XXXXXXXXXXXXXXXX <@curve.com> Sent: 14 September 2021 10:32 To: Henry, Paul Subject: [External:]Re: [External:]Re: [External:]Fwd: Money - go - round transactions at NS&I via Creation, Curve, Revolut and Virgin This message is from an EXTERNAL SENDER - be CAUTIOUS , particularly with files and att achments Hi Paul, Yes I emailed XXXXXX yesterday am and asked if we could delay for a day or sao just to allow time for some data I have asked for to come through...Can we meet tomorrow? Many thanks xxxxxx 4 ------------------------------------------- --------------------------------------------------------------------- From: Henry, Paul Sent: 15 September 2021 09:03 To: xxxxxxxxxxxxxxxxxx @curve.com Cc: xxxxxxxxxxxxxxxxxxxxxxxxx @nsandi.com> Subject: RE: [External:]Re: [External:]Re: [External:]Fwd: Money - go - round transactions at NS&I via Creation, Curve, Revolut and Virgin Hi xxxxxx Apologies, I was at an off - site yesterday and silent running. I’ll a sk x x xxx to get us a meeting in the diary although today is tight for me. Best Paul Henry Risk and Compliance Director NS&I I Drummond Gate Pimlico London SW1V 2QX m xxxxxxxxxxx e paul.henry@nsandi.com www.nsandi.com ---------------------------------------------------------------------------------------------------------------- From: xxxxxxxxxxxxxxx <@curve.com> Sent: 20 September 2021 10:56 To: Henry, Paul Subject: [External:]Fwd: Curve - ongoing compliance/risk issues This message is from an EXTERNAL SENDER - be CAUTIOUS , particularly with files and attachments Hi, Paul, Again thanks for your t ime on Friday - xxxxxxxxxxxxxxxxxxxxxxxxxxxxx x x . As agreed, and perhaps relevant for your audit committee, I think the following are sensible and proportionate next steps: 1) We regularly write to cash recyclers to warn and then close accounts, and have stepped up our efforts to do that more forcefully going forward; 2) I will share with you relevant data so that NS&I can do the same (let me have your contact so I can put them in touch with our Fin Crime unit?) Our view is that this is a breach of ToS and not AML, ho wever we do want to be good citizens of the payments infrastructure and do our part to prevent this, and would encourage the underpinning cards to offer the points to do the same! Just to confirm, Curve applies its own AML due diligence and 5 behavioral tra nsaction monitoring on top of that executed by the underpinning funding cards, we then also pass back the MCC information to the banks to enable them to see clearly where the spend is occuring. I am happy to continue to share information and swap thought s on this.. Best regards xxxxxx ----------------------------------------------------------------------------------------------------------------------------- --------- From: xxxxxxxxxxxxxxxxx < @curve.com> Sent: 24 September 2021 12:30 To: Henry, Paul Subject: [External:]Re: [External:]Urgent update re NS&I/Curve/Virgin cash recycling This message is from an EXTERNAL SENDER - be CAUTIOUS , particularly with files and attachments Hi Paul, Thanks for forwarding that on. As promised we have written this week to all customers who we believe are recycling and are continuing with the account monitoring. We will close accounts where this continues, as we have done in the past. Can you give me a c ontact name in NS&I that I can provide with transaction information ? This may help you your side. Clearly these customers don't need Curve to do this, and if we close the accounts they may just come directly to you, also we cannot stop the points being a llocated by the cards. ************************************ ***************************************************************************** I am also going to speak to some of the banks to see what action they are taking here. After all, we pas s on all of the MCC information to them so they could stop this from happening. Will let you know how I get on. Best regards xxxxxx ----------------------------------------------------------------------------------------------------------------------------- --------- From: Henry, Paul Sent: 27 September 2021 09:43 To: xxxxxxxxxxxxxxxxxx @curve.com Cc: xxxxxxxxxxxxxxxxxxxxxxx @nsandi.com> Subject: RE: [External:]Re: [External:]Urgent update re NS&I/Curve/Virgin cash recycling Hi xxxxxx Many thanks for the update, could you share the transactio n details with xxxx xxxxxxx please copied above? Best 6 Paul Henry Risk and Compliance Director NS&I I Drummond Gate Pimlico London SW1V 2QX m xxxxxxxxxxx e paul.henry@nsandi.com www.nsandi.com ------------------------------------- --------------------------------------------------------------------------- From: Henry, Paul Sent: 28 September 2021 16:24 To: xxxxxxxxxxxxxxxxx @curve.com Subject: Revolving Transactions Hi xxxxxx Sorry to be a pain, are your people ab le to share the NS&I data with xxxxxxxxxxx as I’m anxious to close out the worst transactions in this space? Best Paul Henry Risk and Compliance Director NS&I I Drummond Gate Pimlico London SW1V 2QX m xxxxxxxxxxx e paul.henry@nsandi.com www.nsandi.com ---------------------------------------------------------------------------------------------------------------- From: xxxxxxxxxxxxxxx <@curve.com> Sent: 29 September 2021 07:59 To: Henry, Paul Subject: [External:]Re: Revolving Transactions This message is from an EXTERNAL SENDER - be CAUTIOUS , particularly with files and attachments Hi Paul, Yes - we are just pulling that now, our DPO had concerns about the data sharing I am just closing out now. 7 ---------------------------------------------------------------------------------------------------------------- From: xxxxxxxxxxxxxxxx < @curve.com> Sent: 30 September 2021 11:10 To: Henry, Paul ; xxxxxxxxxxxx < @nsandi.com> Subject: [External:]Fwd: Transaction Breakdown - NS&I This message is from an EXTERNAL SENDER - be CAUTIOUS , particularly with files and attachments Paul, xxxxxxxx , My Fin Crime team have pulled together the following list of transactions with NS&I that look on our systems like cash recycling. We have assessed this sharing of information from a data privacy perspective and concluded that there are no data privacy issu es as we are sharing transactional information that you already hold. Apologies I could not get this to you sooner but this list had to be manually collated. It should provide you with enough data to ID transactions on your side and make your own assessmen t. As I mentioned, we continue to monitor accounts and where we identify customers operating outside of our Terms of Service we will communicate with customers and close accounts. Please do give me a call if you would like to discuss and I hope this is helpful. Best Regards xxxxxx ---------------------------------------------------------------------------------------------------------------- From: xxxxxxxxxxxxx @nsandi.com> Sent: 30 September 2021 11:35 To: xxxxxxxxxxxxxxxxxx @curve.com; Henry, Pa ul Subject: RE: [External:]Fwd: Transaction Breakdown - NS&I Hi xxxxxx , Many thanks for sending this through, it will be very useful for us. I will come back to you if I have any queries. Regards, xxxxxxxxxxxxxx ---------------------------------------------------------------------------------------------------------------- 8 From: xxxxxxxxxxxxxxx <@curve.com> Sent: 06 October 2021 12:54 To: Henry, Paul ; xxxxxxxxxxx @nsandi.com> Subject: [External:]Re: Transaction Breakdown - NS&I This message is from an EXTERNAL SENDER - be CAUTIOUS , particularly with files and attachments Hi Paul, I'm just checking back in. I hope the data was he lpful to you. This is the ******* , would you like th e next **** or I alternatively I can refresh for next month? You may have now developed a better way to source this from your own data. Please do let me know if there is anything else I can supply that would be helpful. Best regards Xxxxxx ---------------------------------------------------------------------------------------------------------------- From: Henry, Paul Sent: 06 October 2021 13:45 To: xxxxxxxxxxxxxxxxxx @curve.com; xxxxxxxxxxxxx x @nsandi.com> Subject: RE: [External:]Re: Transaction Breakdown - NS&I Hi xxxxxx Good to see the noise in the blogosphere, it would be really helpful if you could share your data for a little while longer? Best Paul Henry Risk and Compliance Director NS&I I Drummond Gate Pimlico London SW1V 2QX m xxxxxxxxxxx e paul.henry@nsandi.com www.nsandi.com ---------------------------------------------------------------------------------------------------------------- 9 From: xxxxxx xxxxxxxx x <@curve.com> Sent: 06 October 2021 13:54 To: Henry, Paul Subject: [External:]Re: [External:]Re: Transaction Breakdown - NS&I This message is from an EXTERNAL SENDER - be CAUTIOUS , particularly with files and attachments Hi Paul, Yes, Interesting looking at the traffic particularly on the points sites. I met with Creation Credit cards yesterday, good meeting and I am sharing data with them too. Im happy to provide you with another data return, would you like the top 50 again but over a different period ie refreshed for next week? We continue to cancel accounts where we see this behaviour but as we said that won't really help you as customers will just go elsewhere. We also last week refreshed our Terms of Service, and emailed all of our custome rs. In this update we added NS&I to the Merchants for which we have limits and fees, which should also help. How did audit committee go? Best regards xxxxxx --------------------------------------------------------------------------------------------- ------------------- From: Henry, Paul Sent: 06 October 2021 14:04 To: xxxxxxxxxxxxxxxxx @curve.com Subject: RE: [External:]Re: [External:]Re: Transaction Breakdown - NS&I xxxxxx Yes please to the data refresh and I believe you also offered in absolute numbers to share how many accounts you are closing who persistently manufacture spend via our accounts. Without sharing sensitive information the Chair of ARC is still somewhat conce rned about the ability of customers to circumvent our T’s & C’s xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx by utilising aggregator cards and dependent on outcomes wishes us to keep all options o n the table staring with xxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxx our T’s & C ’s in order to identify and stop miscreants . If the situation falls back to low level background noise and we are able to stop the most grievous offenders I’m hoping that suffices. Best Paul Henry Risk and Compliance Director NS&I I Drummond Gate Pimlico London SW1V 2QX m xxxxxxxxxxx e paul.henry@nsandi.com www.nsandi.com

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FOI 2021.10.07.pdf

Heneghan, Brian