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Appendix T

Guidelines for Fraud Risks and Liabilities

1. Cardholders. A Navy Cash cardholder, either an individual or a merchant, who suspects 

there has been unauthorized activity on their Navy Cash card or account, should stop using the 

card and report the incident to the Disbursing Office and / or the Navy Cash Customer Service 

Center (CSC) (1-866-3NAVY CASH (1-866-362-8922)). Specific guidelines for reporting and 

handling problems with suspected fraudulent activity depend on the type of transaction involved. 

Information about cardholder rights, responsibilities, and liabilities can be found in the Navy 

Cash Card and Navy Cash Visitor Card Cardholder Agreement at Appendix U. 

Table T-1 groups problems with Navy Cash transactions in four categories: debit transactions 

on shore, funds transfers at the Navy Cash Kiosk, closed-loop transactions, and home bank or 

credit union account transfers. The actions a cardholder should take for suspected fraudulent 

activity with each category of transactions are discussed in turn. Table T-2 summarizes these 

cardholder actions. 

PROBLEMS WITH DEBIT TRANSACTIONS 

ON SHORE PROBLEMS WITH FUNDS TRANSFERS AT KIOSK 

 1. ATM withdrawal – PIN required 

 2. PIN-based purchase – PIN required 

 3. Signature-based purchase – PIN not 

required 

 4. Open loop to home account – PIN required 

 5. Open to closed loop – PIN required 

 6. Closed to open loop – PIN required 

 7. Closed loop to home account – PIN required 

PROBLEMS WITH CLOSED-LOOP TRANSACTIONS PROBLEMS WITH HOME ACCOUNT TRANSFERS 

 8. POS purchase – PIN required 

 9. Vending purchase – PIN not required 

 10. Closed-loop-to-closed-loop transfer – 

PIN required 

 11. Home account to closed loop – PIN required 

 12. Home account to open loop – PIN required 

Table T-1. Summary of Navy Cash Transactions

a. Cardholder Actions 

(1) Problems with Debit Transactions on Shore. Withdrawals at Automated Teller 

Machines (ATMs) ashore and both PIN-based and signature-base purchases at stores, 

restaurants, gas stations, and other retail locations ashore are transacted as Mastercard® debit 

transactions from the Mastercard debit open-loop account. 

(a) Actions. A cardholder who suspects someone made, or may make, an 

unauthorized ATM withdrawal or a PIN-based or signature-based purchase ashore using their

Navy Cash card open-loop account without permission must notify the Treasury Agent AT 

ONCE, either by requesting their Disbursing Office contact the CSC immediately or by calling 

the CSC directly. The CSC will open a case in the ticketing system and forward the case to the 

Treasury Agent’s transactions processor. Similarly, a cardholder who believes their Navy Cash 

card has been lost or stolen must notify the Treasury Agent AT ONCE, either by requesting their 

Disbursing Office contact the CSC immediately or by calling the CSC directly so they can assign 
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a case tracking number. In both cases, a telephone call is the preferred way to notify the CSC, 

but email notification is also acceptable. 

If the Disbursing Office or cardholder elects to notify the CSC via email, they must restrict 

the Personally Identifiable Information (PII) they provide in the email. They should simply state 

either that they believe the card has been lost or stolen or that someone has transferred, or may 

transfer, money from the account without permission. They should include only the name, email

address, and last four digits of the SSN to help the CSC in identifying the correct Navy Cash 

cardholder account and in responding to their email. They should also “cc” the Disbursing 

Officer on the email they send to the CSC. A cardholder’s full SSN, Mastercard number, or PIN 

should never be included in an email to the CSC. 

Phone: 1 866 3NAVY CASH (also printed on the back of the Navy Cash card) 

 1 (866) 362-8922 

email: navycash@frb.org 

Fax: 1 (813) 533-5711 

(b) Dispute Form. To dispute a fraudulent or erroneous transaction, an individual 

must fill out, sign, and date a dispute form. There are two separate dispute forms, the Fraud 

Transaction Dispute Form and the Non-Fraud Transaction Dispute Form. The Disbursing Officer 

can provide a cardholder the appropriate form. The form must then be faxed or mailed to 

Treasury Agent’s customer service facility in Tampa, Florida. Copies of the two dispute forms 

are included at Appendix I. 

Address: FRB-TCC 

Attention: Disputes 

 3913 Riga Blvd 

 Tampa, FL 33619 

Fax: 1 (813) 533-5711 

(2) Problems with Funds Transfers at the Kiosk on the Ship. Funds transfer requests 

at the kiosk from the open-loop account to a home bank or credit union account or to the closedloop account on the Navy Cash card or from the closed loop to the open loop or from the closed 

loop to a home bank or credit union account also involve the Navy Cash card open-loop or 

closed-loop accounts and require a PIN. 

(a) Actions. A cardholder who suspects someone transferred, or may transfer, 

money from his / her Navy Cash card open-loop or closed-loop accounts without permission must 

notify the Customer Service Center (CSC) AT ONCE, either by requesting their Disbursing 

Office contact the CSC immediately or by calling the CSC directly so they can assign a open a 

case in the ticketing system. A telephone call is the preferred way to notify the CSC, but email

notification is also acceptable (see paragraph 1.a.(1) above). 

(3) Problems with Closed-Loop Account Transactions on the Ship. The closed loop 

on the Navy Cash card replaces cash for purchases on the ship. Funds in the closed-loop account 

are considered cash. Any loss of funds is similar to the loss of cash and may not be recoverable. 

(a) Actions. A cardholder who suspects fraudulent activity on closed-loop 

purchases or closed-loop-to-closed-loop transfers should notify the Disbursing Office and the 

ship’s Master at Arms immediately. Any loss of funds would need to be pursued via Navy 

investigative and judicial processes. The Commanding Officer (CO) may appoint an 

investigating officer / board to conduct a formal investigation or request a criminal investigation 

if one is warranted. If it becomes necessary to request account information, transaction history, 
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or any Personally Identifiable Information (PII) concerning a cardholder’s Navy Cash account to 

support a formal or criminal investigation, refer to the guidance below in paragraph 4, Requests 

for Cardholder Information. 

(4) Home Account Transfers at the Kiosk on the Ship. Funds transfer requests at the 

kiosk from the home bank or credit union account to the closed or the open loop are debited from 

the cardholder’s bank or credit union account. 

(a) Actions. Cardholders who suspect fraudulent activity on home account 

transfer requests should notify Disbursing and contact their bank or credit union directly to 

dispute any unauthorized transactions. For all calls received by the CSC from the cardholder or 

by the Navy Cash Central Support Unit (CSU) from Disbursing regarding disputes for these 

types of transactions, the caller will be referred to the individual cardholder’s bank or credit 

union for resolution. 

Transaction Types Cardholder Actions

PROBLEMS WITH DEBIT TRANSACTIONS ON SHORE

 1. ATM withdrawal 

 2. PIN-based purchase 

 3. Signature-based purchase 

• Call CSC immediately so a case can be opened 

1-866-3NAVY CASH (1-866-362-8922) 

(also printed on back of Navy Cash card). 

• Fill out, sign, and date appropriate dispute form 

(available at Disbursing) and fax or mail to: 

 Address: FRB-TCC 

Attention: Disputes 

 3913 Riga Blvd 

 Tampa, FL 33619 

Fax: 1-813-533-5711 

PROBLEMS WITH FUNDS TRANSFERS AT KIOSK ON SHIP

 4. Open loop to home account 

 5. Open loop to closed loop 

 6. Closed loop to open loop 

 7. Closed loop to home account 

• Call CSC immediately so a case can be opened

1-866-3NAVY CASH (1-866-362-8922). 

PROBLEMS WITH CLOSED-LOOP TRANSACTIONS ON SHIP

 8. POS purchase 

 9. Vending purchase 

 10. Closed loop-to-closed loop 

transfer 

• Notify Master at Arms and Disbursing immediately. 

• Funds in closed-loop account are considered cash and 

may not be recoverable if lost, so disputes must be 

pursued via Navy investigative / judicial processes. 

PROBLEMS WITH HOME ACCOUNT TRANSFERS AT KIOSK ON SHIP

 11. Home account to closed loop 

 12. Home account to open loop 

• Contact bank or credit union directly to dispute any 

unauthorized transactions. 

Table T-2. Summary of Cardholder Actions
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b. Safeguard Navy Cash Card and PIN. Remember, a cardholder is responsible for all 

debits they authorize using the card. Therefore, a cardholder must take precautions to safeguard 

the card and PIN at all times. A cardholder must not give his / her card or PIN, or make the card 

or PIN available, to any other person. If a cardholder permits other persons to use his / her card, 

the cardholder is responsible for any transactions they authorize from the cardholder’s closedloop or open-loop account. 

2. Lost or Damaged POS or CAD 

a. The Point Of Sale (POS) and Card Access Device (CAD) are used to process closedloop purchase transactions at retail locations and vending machines on the ship. Any loss of 

funds is similar to the loss of cash and may not be recoverable if lost. In each instance of loss of 

funds due to a damaged or lost device, the liability will be determined on a case basis by the 

Fiscal Service and NAVSUP. 

b. Merchant Actions. The POS and CAD devices can be used to store the value of sales 

transactions and should be protected like a cash box, particularly when the POS is operated in the 

off-line mode. When being transported off the ship or over water, these devices should be carried 

in a waterproof container equipped with a flotation device (see paragraph 8.7, Collections from 

Portable Point of Sale Devices). In the unlikely event that a POS is lost, damaged, or destroyed 

before the sales transaction data recorded in it are downloaded to the server, the CSU may be 

able to reconstruct the sales transactions from copies of the electronic records or manual logs of 

sales receipts kept by each merchant in accordance with this SOP. 

(1) The Navy Cash closed-loop balance is essentially maintained in two places, 

physically on the chip and electronically in the database ashore. If sales transaction are not 

captured on the Navy Cash server on the ship, e.g., the POS is lost overboard before the 

transactions are downloaded to the server, then no transactions can be posted to the shore 

database, and the Navy Cash database ashore has no way of knowing the value to transfer to that 

particular merchant’s account or the correct closed-loop balances on cardholders’ cards. The 

balance on the closed loop on the card (the correct value) will be different from the closed-loop 

balance that is maintained in the shore database. 

(2) The information required to reconstruct the sales transactions would need to be 

provided by whoever collected the transactions. It could come from the ROM reports, if it was 

the Ship’s Store POS that was lost or damaged, or from a sales receipts log or copies of receipts 

given to customers, e.g., in the Wardroom, Chiefs Mess, or MWR. The amounts that were 

deducted from cardholders’ cards and the customers’ names or card numbers would be provided 

to the CSU. The CSU would then adjust each cardholder’s closed-loop balance in the shore 

database. This should synchronize the closed-loop balance on the shore with the closed-loop 

balance on the cardholders’ Navy Cash cards and enable the payment to the merchant account. 

The accuracy will only be as good as the information provided to the CSU. 

3. Disbursing Office. If unauthorized activity on a Navy Cash card or account is suspected 

in the Disbursing Office, the guidelines described above for cardholders for debit transactions on 

shore, funds transfers at the kiosk, closed-loop transactions, and home bank or credit union 

account transfers apply. 

a. However, Navy Cash also involves public money. Under Federal Law, 31 U.S.C. 

3302, public money must be held either in the Treasury, by a Treasury-designated Financial 

Agent, or by a disbursing official. The Navy Cash funds pool holds a pool of funds that backs the 

electronic stored value that has been issued. The money in this pool falls into one of two 

categories. The first represents stored value which has been received by the Navy through the 

Ship’s Store, vending machines, other retail operations, and Food Service. These funds constitute 
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receipts of the United States. The second represents stored value which “belongs” to individual 

Sailors. This money, while belonging to the Sailors, is under the control of the Government. 

Both categories of funds are public money. 

b. Article 0814, U.S. Navy Regulations (1990), requires COs to recommend or convene 

an investigation under the provisions of the Manual of the Judge Advocate General (JAGMAN) 

into the circumstances of all losses or excesses of public funds or property in the custody of 

persons under their command, unless properly excused by higher authority. 

c. According to the Department of Defense Financial Management Regulation (DoD

FMR), Volume 5, Chapter 6, Irregularities in Disbursing Officer Accounts, any loss of funds 

where there is evidence of fraud within the Disbursing Office is considered a major loss, 

regardless of dollar amount. Any major loss requires a written report from the Disbursing Officer 

to the CO within 24 hours, who must in turn submit a written report through the chain of 

command within 24 hours via email or by mail to the Relief of Liability Section, Disbursing / 

Debt Management Policy Division, Defense Finance and Accounting Service Indianapolis 

(DFAS-NPD/IN). The CO must appoint an investigating officer / board to conduct a formal 

investigation (the type of loss determines the type of investigation required) and request a 

criminal investigation if one is warranted. Responsibilities and procedures are detailed in DoD 

FMR Volume 5, Chapter 6. 

d. In accordance with the JAGMAN, section 0249, Loss or Excess of Government 

Funds or Property, a consultation with an appropriate assist team and a prompt audit to verify the 

existence and amount of a loss of funds should normally precede the decision to convene a 

JAGMAN investigation. Criminal law enforcement investigations are required if there is any 

indication that the loss of funds was caused by fraud, embezzlement, theft, or other criminal act. 

In accordance with section 0201 of the JAGMAN, any such investigation should be coordinated 

with the Naval Criminal Investigative Service (NCIS).

4. Restitution. A court martial has no power to adjudge civil remedies. For example, a 

court martial may not adjudge the payment of damages, collect private debts, order the return of 

property, or order a criminal forfeiture of seized property. 

a. When the U.S. Government, e.g., the Treasury’s Navy Cash funds pool (see 

paragraph 2.a), has suffered any loss of money through unlawful acts, e.g., larceny, fraud, etc., 

for which persons, other than accountable officers as defined in DoD FMR Volume 5, Chapter 2, 

section 0203, have been convicted by court-martial or competent authority has determined that 

the loss occurred through fraud, forgery, or other unlawful acts, the amount of such loss 

constitutes an indebtedness to the U.S. Government. That indebtedness will be set off against the 

final pay and allowances due such persons at the time of dismissal, discharge, or release from 

active duty, if necessary without the member’s consent, to make the Treasury’s Navy Cash funds 

pool whole. Immediate recovery action against current pay may be instituted without the 

member’s consent if such recovery is authorized by statute (see DoD FMR Volume 7A, Chapter 

50) or on the basis of a voluntary offer from the member, i.e., with the member’s consent, to 

make restitution of all or part of any indebtedness to the Government to make the Treasury’s 

Navy Cash funds pool whole. The voluntary offer constitutes assumption of pecuniary 

responsibility for the loss and, as such, is sufficient to authorize checkage of current pay. (See 

JAGMAN, section 0167, Setoff of Indebtedness of a Person Against Pay.) 

b. For accountable individuals, the ideal method for resolving a loss of funds is recovery 

from the beneficiary of the loss, e.g., recovery of missing cash from the finder, or, in cases where 

the accountable individual is denied relief of liability, collection from the accountable individual 

(see DoD FMR Volume 7A, Chapter 50) to make the Treasury’s Navy Cash funds pool whole. 
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When losses cannot be recovered (including those instances where relief of liability has been 

denied and recoupment cannot be made from the accountable individual) or relief of liability is 

granted to the accountable individual, appropriated funds shall be made available to remove the 

deficiency from the Disbursing Officer’s Statement of Accountability, SF 1219, i.e., the Navy 

shall identify the appropriation and funding necessary to resolve the loss (see DoD FMR Volume 

5, Chapter 6) and to make the Treasury’s Navy Cash funds pool whole. 

c. When an individual cardholder has suffered any loss of money, Article 139, Uniform 

Code of Military Justice (UCMJ), can be a valuable tool for COs (see JAGMAN, Chapter IV, 

Article 139 Claims—Redress of Damage to Property). Article 139 provides an opportunity to 

force the wrongdoer to compensate victims for property damage or destruction. A wrongful 

taking is essentially theft. Claims for property that was taken through larceny, forgery, 

embezzlement, misappropriation, fraud, or similar theft offenses are normally payable. 

Command emphasis is required to ensure these investigations are completed quickly. Article 139 

claims operate independently of any criminal action, and should not be delayed pending the 

outcome of adverse criminal or administrative initiatives. The claim must be submitted to the CO 

within 90 days of the incident. However, the CO can extend this time period if there is good 

reason for the delay. In addition, since respondents are often pending separation, it is crucial that 

Article 139 claims be filed and processed as quickly as possible to ensure valid claims are paid 

before the respondent is separated and no longer subject to military pay withholding (see DoD 

FMR Volume 7A, Chapter 50). Once the offender is no longer receiving military pay, the 

claimant may have no effective remedy for his loss. 

5. Requests for Cardholder Information. 

a. Navy Cash Account Statements. Individual Navy Cash cardholders do not need to 

submit a written request to obtain their own account information. Cardholder can access their

account information on the Navy Cash Cardholder Website at any time (www.navycash.com). 

To log in to the website, cardholders need a username and password. The first time cardholders 

access the website, they use their 16-digit Mastercard® card number and PIN. They are then 

asked to set up a username and password and set up answers to two security questions. Once a

cardholder has logged in to the website, they can view account information, list both ship and 

shore transactions, and print an account statement for the current month and the last six months. 

b. Requested by Cardholder or Individual with a Current Power of Attorney. If a Navy 

Cash cardholder, or an individual who provides the Treasury Agent with an appropriate and 

current power of attorney form, submits a request for account information, transaction history, or 

any PII concerning her / his own Navy Cash account, the Treasury Agent may provide such 

information. This information may NOT be provided to anyone other than the cardholder, or an 

individual who provides the Treasury Agent with an appropriate and current power of attorney 

form, without prior written approval from the U.S. Treasury. To authorize disclosure of account 

information, transaction history, or any PII concerning his / her own Navy Cash account 

information, e.g., to a military or civilian law enforcement agency, a cardholder, or an individual 

who provides a current power of attorney form, must fill out, sign, and date an FS Form 5752, 

Authorization to Disclose Information Related to Stored Value Account (see enclosure (1)). 

c. Requested by Other Than Cardholder Without a Subpoena. 

(1) If someone other than the Navy Cash cardholder submits a request for account 

information, transaction history, or any PII concerning Navy Cash accounts, e.g. NAVSUP, 

NCIS investigators, other state or police agencies, the Treasury Agent may NOT provide such 

information. This information may NOT be provided to anyone other than the cardholder without 

prior written approval from the U.S. Treasury. When approval is received, the Treasury Agent
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will provide such information to the U.S. Treasury or an approved agent of the Treasury for 

further distribution. 

(2) The U.S. Treasury may grant release of account information, transaction 

history, or other PII concerning Navy Cash accounts to DoD law enforcement agencies for a civil 

or criminal law enforcement activity, if the activity is authorized by law and if requested in 

writing by the head of the agency specifying the particular information desired and the law 

enforcement activity for which the information is sought. 

(3) In a single exception to this procedure, the U.S. Treasury has granted approval 

for the Treasury Agents to provide account information, transaction history, or PII to a 

Disbursing Officer who is acting as an agent of the U.S. Treasury in collecting and clearing 

negative balances. This approval has been granted under exemption (b)(1) of the Privacy Act, 

and that information can be provided routinely without written approval from the U.S. Treasury. 

d. Requested by a Subpoena. If account information, transaction history, or any PII 

concerning a Navy Cash account is requested by a valid subpoena, such information may only be 

provided after the Treasury Agent receives confirmation of the validity of the subpoena from 

internal legal counsel. Upon confirmation of the validity of the subpoena, The Treasury Agent

will notify the U.S. Treasury of the information requested in the subpoena. 
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Enclosure (1)