Early Warning Systems (EWS), Confirmation of Payee (CoP), and Verification of Payee (VoP) are becoming standard features of modern banking globally. Rolled out across the UK and Europe and now Australia, New Zealand, and parts of the US, these initiatives work to reduce payment fraud by verifying bank account details before funds are released.
For finance leaders, this progress is welcome. With the emergence of AI, fraud is rising, payment volumes are increasing, and regulators expect action. But, while these controls reduce certain risks, they don’t solve the problem of payment fraud as a whole.
That distinction matters, especially at CFOs’ level responsible for large transactions and complex payment operations.
What these solutions are designed to do
CoP and VoP are name-matching controls. They compare the name entered by the payer with the name held by the recipient’s bank for a given account number and return a result such as “match,” “close match,” or “no match.” Early Warning Systems sit alongside this, using behavioural analytics to flag payments that appear unusual or high-risk.
In consumer scenarios, these controls are highly effective. They introduce friction at the moment it matters most; before money leaves the account. And in markets ahead of the curve, like the UK, they have contributed to measurable reductions in misdirected payments and authorised push payment fraud.
However, business payments operate under very different conditions.
How business payments strain the limits of bank verification
Any time banks make it harder for scammers to secure a fraudulent payment, it’s a win. However, businesses do not make isolated transactions. They run payment lifecycles that include supplier onboarding, bank detail changes, invoice approvals, ERP updates, batch payments, and international transfers. Fraud typically enters early in this lifecycle long before a payment file reaches the bank.
Bank-level verification only operates at the final step.
By the time CoP or VoP is triggered, the organisation has already accepted the bank detail as legitimate. The system does not assess how the change was requested, whether communication channels were compromised, or whether the data entered into the ERP was manipulated. It simply checks whether names and numbers appear to align at that moment in time.
For CFOs, this means bank verification is not preventative control, but merely a last-minute warning.
The dangerous comfort of partial control
This is where risk quietly increases.
Once bank-level verification is introduced, behaviour can change inside finance teams. Upstream controls might loosen – not because anyone is negligent, but because there is confidence that the bank will “catch it” if something is wrong. Verification is no longer treated as a lifecycle responsibility and is mentally outsourced to the payment screen.
Consider a typical scenario.
A supplier emails your accounts payable team advising that their bank details have changed. The email looks legitimate. The tone is familiar. The signature matches previous correspondence. The new details are updated in the ERP and queued for the next payment run. Nothing feels urgent or suspicious because this happens all the time.
On payment day, the batch is uploaded and the bank returns a “close match” result. The name is similar, but not identical. The system doesn’t say why. It doesn’t say whether the account belongs to the supplier, a newly opened account, or a third party. It simply signals uncertainty.
At this point, the bank’s role (rightfully) ends.
The responsibility shifts entirely back to your organisation.
Your AP team is now required to interpret ambiguity under time pressure. Payments are due. Suppliers are waiting. The alert does not say “fraud,” only “check.” So, the team follows the bank recommended policy and performs a manual callback and calls the supplier back.
They use the phone number on file which was updated in the same email request. Or they reply to the original email asking for confirmation. The fraudster answers. The explanation is plausible: a new banking partner, a recent restructure, an account that “hasn’t propagated through the banks yet.”
The story fits. The pressure to move on is real.
The payment proceeds.
From an operational perspective, everything appears controlled. A bank check occurred. A callback was made. A decision was documented. The system did what it was supposed to do.
But from a governance perspective, nothing was ACTUALLY verified.
The control did not confirm intent. It did not validate the change independently. It did not eliminate uncertainty; in the case of a fraud it simply transferred it to humans operating inside compromised channels.
This is the danger of partial control.
A system that’s right 99% of the time introduces enough structure to create confidence, but not enough certainty to prevent loss. It changes behaviour, relaxing upstream diligence without removing the underlying risk. And when fraud succeeds, it does so through the control, not around it.
For CFOs, this distinction is critical. A warning that still allows ambiguity is not protection. It is exposure, disguised as progress.
Where CFO accountability becomes unavoidable
When payment fraud occurs, responsibility does not sit with the bank’s alert. Banks are explicit in disclaiming liability once a payment is authorised, even when warnings are displayed. At that point, accountability rests squarely with the organisation’s own control framework.
Boards, auditors, insurers, and regulators do not assess fraud outcomes based on whether a warning appeared. They assess whether management implemented controls that were reasonably capable of preventing loss. A system that merely surfaces risk, but allows ambiguity to pass through, may indeed satisfy a procedural checklist, yet still fail its primary purpose: stopping money from leaving the business incorrectly.
This is where CFO accountability becomes unavoidable.
In most organisations, the CISO is responsible for securing the front door: preventing unauthorised access to systems, protecting infrastructure, and defending against intrusion. That responsibility is clear, well understood, and heavily invested in.
But cybercrime is not primarily about access. It is about money.
Over 99% of modern cybercrime is financially motivated. The ultimate objective is not to disrupt systems, but to subtract funds from an organization. Most often done via social engineering scams targeting employees instead of systems. And that makes payment fraud, invoice fraud, and business email compromise fundamentally financial risks. Not just technical ones.
This is the back door, and the CFO is usually the last line of defence.
It is the point where a cyber incident becomes a financial loss. Where a compromised email turns into a fraudulent payment. Where security failure translates into balance-sheet impact. And it is the last opportunity to stop money from leaving the organisation when it shouldn’t.
For CFOs, payment fraud therefore cannot be treated as a transactional issue delegated to banking interfaces or operational teams. It must be governed as an enterprise risk, with controls designed to remove uncertainty before trust is assumed and before data enters your organisation and becomes operational.
The question is no longer whether a payment was checked, or whether a warning was displayed. It is whether the organisation had controls in place that made fraud materially difficult, not just detectable.
Because once money leaves the account, every explanation becomes retrospective.
The case for end-to-end verification
Airtight protection requires verification at the start of the payment lifecycle, when suppliers are onboarded or bank details change and continued assurance as those details move through systems, approvals, and banks.
This is where bank-level solutions reach their limit. They verify data at a single point in time, but they do not validate intent, context, or authenticity across the full set of systems and communication channels where fraud actually occurs. Independent verification, applied upstream and sustained throughout the lifecycle, is what closes that gap.
A common misconception in payment security is that once supplier bank details have been verified, risk has been eliminated. In reality, payment fraud almost never happens at onboarding. It happens later, when bank details change, when data is handed off between systems, or when trust is exploited. Payee data is not static. It is a living asset that moves through people, processes, and platforms over time. A one-off check only secures a moment. Fraud exploits what happens between those moments.
Across the procure-to-pay lifecycle, there are multiple opportunities for manipulation: supplier maintenance, invoice processing, bank detail updates, payment file creation, approval, and final release of funds. Each handoff introduces exposure. When verification is limited to a single step, it leaves gaps that are invisible until money has already left the organisation. End-to-end verification works differently. It assumes change will occur and focuses on monitoring, validating, and controlling that change wherever it appears.
Crucially, effective fraud prevention requires an independent source of verified payment information that internal users cannot quietly alter. Most organisations treat their ERP or AP system as the source of truth, yet those systems are exactly what get manipulated in cases of internal fraud, credential compromise, or social engineering. An external, third-party reference point backed by a centralised audit trail introduces accountability. It records what was verified, when it was verified, and what changed, creating transparency that internal controls alone cannot provide.
Continuous verification is essential because it prevents fraud scenarios that one-time checks (by the banks) cannot detect. In cases of internal fraud, supplier details may be correctly verified during onboarding and altered months later by a malicious insider. In vendor email compromise, trusted email accounts are hijacked and used to submit convincing change requests. In payment file manipulation, details are altered during handoff between teams or systems. In each case, onboarding checks pass and fraud succeeds later. Continuous verification removes guesswork by validating changes against an independent source of truth now risk emerges.
Why this matters now
As Early Warning Systems, Confirmation of Payee, and Verification of Payee become global standards in the banking ecosystem, they risk being misunderstood as complete solutions rather than what they truly are: baseline infrastructure.
For CFOs, the question is no longer whether these controls exist, but whether relying on them alone is a defensible risk position.
These systems improve visibility, but they do not eliminate ambiguity. They surface potential fraud cases without resolving them, shift responsibility back to the organisation at the moment of greatest pressure, and are rarely appropriate for addressing the most common fraud scenarios: compromised suppliers, internal manipulation, and late-stage payment changes.
In parallel, accountability is becoming more explicit. Banks disclaim liability. Regulators expect prevention, not detection. Boards and insurers assess whether controls were designed to materially stop loss, not merely signal it. In that context, partial protection is less a prudent compromise and more of an unacknowledged exposure.
For CFOs, this reframes payment fraud as a leadership issue, not an operational one. Cybercrime is financially motivated, and the final line of defence sits where money leaves the organisation. That responsibility cannot be delegated to point-in-time checks at the bank.
The real question is no longer whether payments are checked, it’s whether certainty exists at every point where trust can be exploited.
That should be the standard CFOs are being held to today.
