Callback must not depend on individual judgment. Trigger it automatically when any condition below is present.
Threshold design should match transaction risk, not only transaction amount. Reassess quarterly.
| Risk | Typical pattern | Minimum controls |
|---|---|---|
| Low | Recurring approved vendor, no banking changes, standard timeline | Standard approval and documentation check |
| Medium | Off-cycle request or unusual urgency with otherwise known parties | Callback verification and manager acknowledgment |
| High | Bank-detail change, executive wire request, or first-time transfer pattern | Callback verification, dual approval, and finance-lead release authority |
| Critical | Multiple fraud indicators or suspected account compromise | Immediate hold, incident escalation lane, and bank/security coordination |
Apply this path to every payment exception. Do not skip steps under time pressure.
| Decision point | If Yes | If No |
|---|---|---|
| Is this a new payee, bank change, or urgent/off-cycle payment? | Trigger callback verification workflow | Continue standard approval path |
| Was identity confirmed on a known, independent channel? | Proceed to dual-approval check | Escalate and hold payment |
| Do verified details match the request exactly? | Complete documented approval | Escalate to finance/security incident lane |
| Is this above the high-risk threshold? | Require second approver before release | Release per standard documented process |
Prioritize payment interruption, account security, and evidence preservation in that order.
| Step | Action | Owner |
|---|---|---|
| Contain | Contact your bank fraud desk immediately to request hold/recall actions. Document all reference numbers. | Finance lead / AP manager |
| Notify | Escalate to security operations to secure affected accounts, reset credentials, and review mailbox forwarding rules. | IT / Security operations |
| Report | Preserve email headers, logs, and approval artifacts. File an IC3 complaint the same day if possible (ic3.gov). | Finance lead + Legal |
| Role | Primary responsibility |
|---|---|
| AP/AR & Finance ops | Enforce callback policy; reject urgency-based bypasses; preserve logs |
| Finance leadership | Set dual-approval thresholds; review near misses monthly |
| IT / Security ops | Monitor sign-ins and forwarding rules; enforce MFA; coordinate on compromise indicators |
Each review should produce named action owners, due dates, and measurable outcomes.