PERSPECTIVE / RICHARD PAXTON

Fighting fraud requires a better operating response.

A suspicious payment is flagged, an analyst waits on another team, and the customer calls a different department. Detection matters, but so does everything that happens next.

A suspicious payment is flagged. The alert reaches a queue. An analyst needs information from another team. The customer calls a different department. By the time the picture comes together, the opportunity to intervene may have narrowed considerably.

This is why I see fraud prevention as an operating-model issue as well as a technology issue. Detection matters, but so does everything that happens next.

The OCC’s Spring 2026 risk assessment identifies sophisticated cyber threats, fraud, and scams as continuing concerns. Financial institutions need defenses that can keep adapting, supported by a response process people can execute under pressure.

Follow the event across the organization

Through EPIF, our Enterprise Process Intelligence Framework, we examine a fraud event from the first signal through investigation, customer communication, recovery, and closure. The objective is to understand where the response loses time or information.

Fraud, cybersecurity, payments, customer service, and financial-crime teams have different responsibilities. Those distinctions are necessary. Problems arise when ownership becomes unclear at the points where their work meets.

Consider a suspected account takeover. Who can restrict access? Who can hold a payment within the applicable rules? Who contacts the customer, through which verified channel? What information must be preserved? When does the event need a broader incident response?

Documenting those decisions often reveals opportunities that another detection tool would not address.

Remove delay without weakening control

EPIF’s intervention sequence gives the work a practical order. Remove duplicate evidence collection. Simplify escalation paths. Standardize incident categories and the minimum information needed to act. Connect relevant information across systems with appropriate access controls.

Automation can route cases, assemble known information, and initiate approved actions within defined limits. AI may help connect related events or summarize an investigation. Decisions affecting customer access, payment release, or reporting need authority and controls suited to their consequences.

The future-state design should also account for third parties. A bank may depend on a processor or service provider at a critical point in the response. Contact details and contractual commitments are useful, but an exercised response is better evidence that the arrangement works.

Measure the tradeoffs

An alert count says little about protection. More alerts can mean better coverage, more noise, or both.

Useful measures include time to a protective action, investigation quality, recovery performance, repeat incidents, and customer disruption. Loss trends need to be considered alongside changes in transaction volume, customer mix, and attack patterns.

False positives matter too. Repeatedly blocking legitimate activity can damage relationships and create avoidable work. Faster intervention and proportionate treatment should be assessed together.

I would start with one recurring fraud scenario and test the response end to end. Find the delays, clarify authority, and measure whether the changes improve the outcome. A defense becomes stronger when the people operating it can act on the information they receive.

Where to start

Use EPIF to examine a high-loss or high-friction fraud scenario and identify where a better response would have the greatest impact.

How EPIF decides what to change first
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Related

Documented result: a custom fraud platform in eight weeks
Documented result: 67% fewer unproductive alerts
Retail and commercial banking

Sources: Office of the Comptroller of the Currency, Semiannual Risk Perspective, Spring 2026.

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