Research & Insights

Strengthening Cross-Functional Enterprise Payment Fraud Governance

Why Enterprise Payment Fraud Governance Matters Today

Enterprise payment fraud has crossed a threshold. What was once viewed as a tactical, finance-managed risk has evolved into a complex enterprise threat that spans digital infrastructure, supplier ecosystems, workforce behavior, and executive decision-making. As outlined in P&C Global’s white paper, The State of Corporate Payment Fraud 2025, the organizations that are outperforming their peers share one defining attribute: they treat fraud risk as a cross-functional governance priority, anchored in executive ownership, operational rigor, and a disciplined enterprise payment fraud governance framework.

In today’s environment—where Business Email Compromise (BEC) attacks exploit human behavior, deepfakes impersonate trusted leaders, and instant-payment networks reduce reaction time from hours to minutes—governance is no longer an internal formality. It is a strategic capability that directly influences enterprise resilience, investor confidence, and the speed at which companies can respond when a breach occurs.

Understanding the Shift to Enterprise-Level Fraud Governance

Fraud can originate anywhere and therefore must be governed everywhere. This is why modern organizations are strengthening their enterprise payment fraud governance models to unify responsibilities across functions. Leading organizations recognize that neither Finance nor IT can shoulder this risk alone. Payment fraud intersects payment operations, cybersecurity, procurement, legal, HR, and even brand stewardship. Modernizing these processes through secure digital workflows reduces vulnerabilities embedded in legacy systems. As adversaries become more sophisticated, the internal silos that once defined fraud response have become liabilities.

The Five Pillars of Effective Payment Fraud Governance

Together, these pillars form the foundation of a resilient enterprise payment fraud governance strategy.

1. Executive Ownership and Tone at the Top

Effective fraud governance begins with visible, active leadership. Boards and C-suite executives are increasingly taking direct ownership of fraud risk—not as an IT issue, but as an enterprise-wide threat to continuity and trust. Setting the right tone is not symbolic; it is behavioral. When CEOs openly encourage staff to double-verify even their own payment requests, they reinforce that procedures supersede hierarchy. When CFOs, CROs, or COOs formally assume fraud-risk oversight and provide structured reporting to the board, accountability becomes systemic—not discretionary. This top-down commitment sends a clear message throughout the organization: fraud resilience is everyone’s responsibility, and no individual is exempt from enterprise payment governance controls. The companies that embrace this mindset see fewer lapses, faster incident detection, and stronger audit results.

2. Cross-Functional Fraud Committees and Task Forces

As fraud vectors proliferate, governance structures must mirror that complexity. Best-in-class enterprises now deploy cross-functional fraud committees that unite expertise from:

Treasury and Accounts Payable – process deep knowledge and payment execution
IT and Cybersecurity – threat intelligence, authentication controls, access governance
Legal & Compliance – regulatory obligations, law enforcement coordination
Procurement – supplier onboarding, third-party verification risks
HR – training, reporting pathways, escalation behavior

This multidisciplinary model enables companies to identify control gaps that no single function could detect alone. It also accelerates response: if an incident arises, the group can mobilize immediately, stitching together actions across departments—from isolating compromised accounts to alerting banks and notifying regulators. These capabilities are core components of cybersecurity and access governance, enabling stronger enterprise-wide defense. Regulators are reinforcing this direction. Recent guidance in the U.K. explicitly urges organizations to unify compliance, legal, finance, HR, and IT into a cohesive fraud-risk team. The message is clear: fragmented ownership leads to fragmented defense.

3. Modern Policies and Controls—Regularly Tested, Not Assumed Effective

Robust governance is not about documenting controls—it’s about validating them. Leading organizations implement payment policies that are specific, stringent, and designed to eliminate ambiguity. These include:

Mandatory multi-person approval for bank master file changes
Independent call-back verification for high-value or new-vendor payments
“Cooling-off” periods for urgent requests that require second-level review
Secure vendor portals to avoid exchanging banking details via email
Payee name matching and positive pay services to reduce check/ACH fraud

Yet the differentiator is not simply the presence of these controls—it is whether they are tested continuously. Internal audit teams and third-party testers increasingly run simulations: phishing exercises, scenario-based BEC attempts, or mystery audits of vendor-verification adherence. Weaknesses are treated as opportunities for retraining or redesign.

Vendor governance is equally vital. Fraudsters often exploit outdated contact information or loosely managed onboarding processes—risks that are preventable with disciplined supplier management and periodic reviews.

4. Practiced Fraud Incident Response and Recovery Plans

Even with strong controls, incidents can occur. The organizations that recover most effectively are those that rehearse their response before they need it. A mature fraud incident response plan outlines:

Immediate internal and bank notifications
Activation triggers for the cross-functional fraud team
Law enforcement, insurer, and legal notification pathways
A structured 24-hour response protocol
Communications guidelines for executives and external stakeholders

Regular tabletop exercises build muscle memory and reduce confusion during a real event. As recent global cases show, swift, coordinated fraud incident response is often the difference between full loss and partial recovery. Regulators and insurers also assess response preparedness when evaluating liability.

5. Continuous Education and a Culture of Vigilance

Fraud governance does not succeed on controls alone—it succeeds on culture. Leading organizations normalize transparency, encourage escalation, and treat near-misses as collective learning moments rather than employee failures. The most effective programs emphasize:

Ongoing training with real-world examples, not static annual modules
Sharing sanitized fraud attempts across the organization
Empowering frontline staff to challenge irregular requests—even from executives
Gamified internal phishing or fraud-spotting challenges for elevated engagement

This environment mirrors the safety cultures seen in manufacturing and aviation: every employee understands that vigilance is part of their job, and that speaking up protects the enterprise.

Governance as a Strategic Advantage Against Payment Fraud

In a landscape where fraud evolves weekly and instant-payment networks shrink reaction time to minutes, enterprise payment fraud governance is no longer a back-office formality—it is a strategic differentiator. Enterprises that build cross-functional, leadership-owned fraud governance frameworks benefit from:

Faster detection
Higher recovery rates
Stronger insurer and regulator alignment
Reduced operational and reputational risk
A workforce that actively contributes to defense

For finance, risk, and technology leaders, the question is not whether fraud risk will escalate—it is whether governance will evolve quickly enough to keep pace. Strengthening governance today is one of the most effective ways to reduce tomorrow’s losses—while building a more resilient, more trusted enterprise.

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