Executive overview
Case study type: Governance architecture implementation
A regulated digital payments platform faced escalating fraud complexity, rising dispute exposure, and increasing scrutiny from partners and oversight bodies.
Although fraud, compliance, and support functions were active, the organisation lacked a formalised response architecture. Escalation thresholds were implicit, documentation standards inconsistent, and executive risk triggers undefined.
The mandate was not operational optimisation. It was governance hardening — implementing a defensible, board-ready fraud response architecture capable of withstanding partner, audit, and regulatory examination.
Context
- Lean fraud team operating with manual alert triage
- Email-based escalation across functions
- No structured case management environment
- Fragmented documentation across multiple systems
- Inconsistent investigation reporting standards
Risk exposure was amplified by:
- Scam-induced purchases (investment and romance typologies)
- Integration partner misuse and distribution channel risk
- Chargeback volatility across reason codes
- Upstream marketing outside direct organisational control
Risk profile
- Ambiguity in fraud-to-compliance escalation
- Inconsistent SAR consideration thresholds
- Limited audit defensibility
- Increased exposure to acquirer scrutiny
- Executive risk visibility constrained by informal escalation pathways
Governance architecture implementation
1. Governance & Role Definition
Implemented a formal fraud response governance structure defining:
- Investigation ownership
- Fraud-to-Compliance escalation pathways
- Executive notification thresholds
- Partner intervention criteria
A structured RACI aligned Fraud, Compliance/MLRO, Support, Legal, Sales, and Executive oversight.
2. Detection & Escalation Framework
Defined a controlled progression model:
Alert → Qualified Incident → Regulatory Consideration → Executive Escalation
Established:
- Incident qualification criteria
- Exposure-based escalation triggers
- Reputational risk thresholds
- Formal documentation standards
3. Structured Investigation Model
Standardised investigation artefacts including:
- Incident overview and typology classification
- Behavioural and session analysis
- KYC and wallet review
- Customer communication review
- Findings and recommended actions
This materially improved defensibility and audit readiness.
4. Partner & Distribution Risk Controls
Introduced upstream governance controls:
- Distribution channel misuse indicators
- Monitoring cadence and review triggers
- Formalised partner-level escalation and suspension criteria
Outcomes
- Clear and documented fraud-to-compliance escalation model
- Defined executive oversight thresholds
- Improved consistency across investigations
- Enhanced partner and acquirer confidence
- Reduced ambiguity in SAR consideration decision-making
- Strengthened regulatory defensibility
Governance impact
The organisation transitioned from an analyst-driven fraud handling model to a structured governance framework with defined thresholds, accountability, and executive visibility.
The model now supports:
- Board-level reporting clarity
- Partner-ready documentation standards
- Scalable growth without proportional increase in governance risk exposure
Key takeaways
- Lean teams require structural clarity more than additional headcount.
- Fraud-to-SAR handover must be explicitly defined and documented.
- Third-party distribution and partnership models amplify upstream risk and require structured governance controls.
- Documentation discipline is a primary control in regulated environments.