Corporate treasury losses rarely start with broken encryption; they start when an email thread, compromised broker mailbox, or forged insurance certificate bypasses segregation of duties. Equip your Accounts Payable desk with deterministic pre-wire controls.
Reject phone numbers inside change-request emails; verify spoken routing read-back on historical master-file landlines.
Segregate invoice entry from bank routing edits and enforce hardware FIDO2 dual custody (Maker + Approver) on every batch.
Confirm policy endorsements directly with underwriting carriers and remit customs duties straight to CBP or Home Affairs.
Tick any control gap or exception present on a pending non-payroll payment batch across Vendor Master, Dual-Custody Wire, and Broker/COI gates. Runs locally in browser memory.
Map external settlement agents, suppliers, customs brokers, and subcontractors against deterministic pre-release verification procedures.
VEC-01 // CLOSING SETTLEMENT
Bypass pattern: Attackers monitor compromised title-agent or external counsel mailboxes for weeks and inject spoofed "updated closing wire" PDFs 24 hours before settlement.
Deterministic control: Exchange closing instructions at engagement start only; treat any pre-closing routing change as hostile until two-person spoken callback clears.
VEC-02 // AP MASTER FILE
Bypass pattern: Lookalike supplier domains or hijacked vendor threads submit updated ABA, BSB, IBAN, or factoring assignment notices timed to monthly AP payment runs.
Deterministic control: Enforce a 48-hour ERP vendor master freeze, Confirmation of Payee / Positive Pay matching, and FIDO2 dual-custody treasury release.
VEC-03 // 19 CFR 111.29
Bypass pattern: Unbonded customs or freight intermediaries divert duty funds (leaving the importer liable under 19 CFR 111.29) or split purchase orders below CFO thresholds.
Deterministic control: Pay tariffs directly via U.S. CBP Periodic Monthly Statement ACH or AU Home Affairs EFT, and audit consecutive sub-threshold agent invoices.
VEC-04 // SUBCONTRACTOR RISK
Bypass pattern: Subcontractors or rogue brokers forward edited PDF insurance certificates masking cancelled policies or missing Additional Insured coverage.
Deterministic control: Require ACORD 25 delivery straight from the licensed producer domain, verify NAIC/APRA insurer codes, and confirm active status with the carrier desk.
Review seven human-curated procurement and disclosure lessons drawn directly from official FTC Operation AI Comply and SEC Rule 206(4)-1 orders, with strict procedural posture citations. For the full searchable primary-source .gov enforcement docket, visit our sister registry agentfrauds.com.
Reviewed by Marcus Vance, Corporate Controls & Treasury Risk Editor
Reviews Accounts Payable segregation-of-duties frameworks, wire verification SOPs, and regulatory filings.
Last reviewed:
Reviewed every 6 months
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