Quick Overview
- Primary use case: Prevent fraudulent payment execution from executive, vendor, or legal impersonation attempts
- Most important control: Trusted callback verification on a known channel before any exception payment
- Who should own this policy: Finance lead, AP/AR owner, CISO or IT Director, payment approvers, and security operations
- Reviewed: February 2026
Definition
BEC verification is a control process that authenticates a payment request through a second, trusted communication channel before funds are released.
What is Business Email Compromise (BEC) verification?
BEC verification is a defensive operating procedure, not a single tool. It requires finance teams to validate identity and transaction details outside the original request path.
Treat every unexpected payment request, bank-detail change, or off-cycle approval as unverified until confirmed. Never validate identity through the same email thread, text conversation, or voice session that initiated the request.
Why is BEC verification critical for finance teams?
BEC is one of the most financially damaging cyber-enabled fraud patterns because it targets process discipline, authority dynamics, and approval speed.
The FBI IC3 2024 Annual Report lists 21,442 BEC complaints and approximately $2.77 billion in adjusted losses for 2024. IC3’s September 2024 PSA separately reports $55,499,915,582 in exposed BEC losses from October 2013 through December 2023, underscoring the continuing scale of both attempted and successful fraud activity.
Insurance requirements vary by carrier and policy wording, so finance teams should confirm social-engineering control expectations with their broker before an incident occurs.
The 4-Stage Attack Sequence
Modern BEC attacks follow a four-stage sequence: reconnaissance, account/domain abuse, social engineering, and rapid execution.
| Stage | Attacker Objective | Control That Interrupts It |
|---|---|---|
| Reconnaissance | Map payment owners, vendors, approval timing, and escalation habits | Limit public process exposure and segment financial authority |
| Account/domain abuse | Spoof or compromise trusted identity signals | MFA, SPF/DKIM/DMARC, mailbox forwarding-rule monitoring |
| Social engineering | Force policy bypass via urgency, secrecy, or authority pressure | Mandatory callback and dual approval thresholds |
| Execution | Irrevocable execution on instant payment rails (FedNow/RTP) before intervention | Mandatory pause controls before release, plus immediate hold/escalation workflow and bank fraud response |
IC3 advisories in 2024 and 2025 (including May and December 2025 campaign updates) note continued use of AI-generated text and voice impersonation, including smishing and vishing pretexts. Process verification is therefore more reliable than perception-based trust, especially when payment rails can settle instantly and irreversibly.
The Trusted Callback Protocol
A trusted callback means initiating a new communication session using contact information from a system of record, not from the suspicious request.
How-To: Trusted Callback Verification
Pause
Halt transaction execution immediately. Mark the request as pending verification before any approval or release action.
Source
Retrieve contact information from internal directory records, validated vendor master data, signed contracts, or prior verified invoices.
Verify
Call the contact and read back exact account details, amount, purpose, and required timeline. Log date/time, verifying party, and channel in the transaction record.
If the request originates by phone, SMS/text, or voice note, end the session and call back on a known number.
Out-of-Band Challenge for Voice and Video
For executive-wire scenarios, define an offline verbal challenge-response phrase that must be answered correctly during callback verification. AI voice clones can now mimic natural emotional tone and pauses, so “sounding authentic” is not a reliable proof of identity. Do not trust video presence alone. As an additional friction test during suspicious video calls, ask the requester to turn their head side-to-side or briefly pass a hand across part of their face; unexplained visual artifacts should trigger escalation.
Which red flags should trigger mandatory callback every time?
Mandatory callback should not depend on individual judgment alone. Trigger it automatically when any of these conditions appear:
- payment urgency that bypasses normal approval timing
- request for secrecy or limited internal visibility
- new beneficiary details or remittance-account changes
- executive request from an unusual channel or context
- legal/compliance pretext that lacks normal documentation
- voice note, SMS/text, or call requesting immediate release of funds
- invoice or payment-change request that relies on a QR code link as the primary action path
The policy objective is simple: convert subjective suspicion into deterministic process.
Defining Risk-Based Approval Thresholds
Threshold design should match transaction risk, not only transaction amount.
| Risk Class | Typical Pattern | Minimum Control Set |
|---|---|---|
| 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 |
Reassess thresholds quarterly so policy keeps pace with vendor, staffing, and transaction-pattern changes.
What should the verification decision tree include?
Use this deterministic path for every payment exception:
| 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 known channel? | Proceed to dual-approval check | Escalate and hold payment |
| Do verified details match request exactly? | Complete documented approval | Escalate to finance/security incident lane |
| Is this above high-risk threshold? | Require second approver before release | Release per standard documented process |
Preventing BEC During Vendor Onboarding
Prevention at onboarding reduces downstream exception risk.
- Verify legal entity identity and banking details before first payment
- Use a controlled vendor-master update process with segregation of duties
- Require two-person review for first payment setup and any account change
- Record verified callback contact points during onboarding, not during incident pressure
- Revalidate critical vendors periodically and after any merger, ownership, or banking change
What documentation should be retained for auditability?
Verification quality is only defensible when records are complete and consistent. Require the following in each exception transaction record:
- original request artifact (email, message, or call log reference)
- source of trusted callback contact data
- callback date/time and verifying employee
- exact account details read back and confirmed
- approving authorities and approval timestamps
- exception rationale (if standard policy path changed)
Retention requirements should align with finance compliance obligations and internal incident-response requirements.
Who should own each control?
AP/AR and finance operations
- Enforce callback policy for all exception payments
- Reject urgency-based bypass attempts regardless of requestor title
- Preserve complete logs for every verification event
Approvers and finance leadership
- Set dual-approval thresholds by risk class
- Require written exception rationale with accountable owner
- Review near misses and policy exceptions monthly
IT and security operations
- Monitor suspicious sign-ins and mailbox forwarding-rule changes
- Enforce MFA and account hardening for finance-adjacent users
- Coordinate with finance immediately when account compromise indicators appear
What are the first steps in BEC incident response?
Immediate response should prioritize payment interruption, account security, and evidence preservation.
Contain
Contact your bank fraud desk immediately to request hold/recall actions and document reference numbers.
Notify
Escalate to security operations to secure affected accounts, reset credentials, and review forwarding rules.
Report
Preserve headers, logs, and approval artifacts. File an IC3 complaint as soon as possible (preferably same day) and coordinate with law enforcement guidance.
For qualifying transfers, coordinate with your financial institution and law enforcement on any available recovery processes. Maintain reference numbers and contact logs from every escalation action.
90-Day Implementation Plan
Days 0-30
- Publish callback and escalation policy
- Classify high-risk transaction types
- Train finance, executive assistants, and approvers
Days 31-60
- Enable mailbox-rule and sign-in anomaly monitoring
- Run role-specific simulation drills
- Add verification logging to payment workflow
Days 61-90
- Audit compliance and exception patterns
- Tune thresholds and escalation criteria
- Present KPI results and corrective actions to leadership
How should we run training and simulations?
Policy quality depends on repetition under realistic pressure. Use short scenario drills instead of one annual awareness session.
Recommended cadence:
- monthly 15-minute role-specific simulation for AP/AR and approvers
- quarterly cross-functional tabletop with finance, security, and leadership
- post-incident mini-drill within two weeks of any near miss or confirmed event
Simulation scenarios should include executive impersonation, vendor account changes, and voice-based urgent requests.
How do we measure control effectiveness?
Track monthly quality indicators:
- Callback completion rate for in-scope transactions
- Exception requests with full documentation
- Escalation-to-decision median time
- Near-miss detection rate before payment release
- Repeated bypass attempt patterns by request type
A mature program is measured by consistent execution quality, not by absence of alerts.
Common Implementation Mistakes
- Treating callback as optional for senior-requestor scenarios
- Allowing undocumented “one-time” exceptions during time pressure
- Failing to connect security alerts to finance workflows
- Training all teams with generic content instead of role-based drills
- Closing incidents without updating policy language and thresholds
Each of these failures is preventable through deterministic process ownership.
Quarterly Governance Checklist
Quarterly governance keeps the verification program aligned with real transaction behavior and current threat patterns.
Use this review checklist:
- confirm risk thresholds still match payment volume and vendor profile changes
- review all policy exceptions and identify repeated bypass causes
- validate dual-approval coverage for high-risk transfer classes
- audit callback logs for completeness and quality, not just completion counts
- review sign-in and mailbox-rule incidents involving finance-related accounts
- verify onboarding controls for newly added or recently modified vendors
- update training scenarios based on current impersonation patterns
Each review should produce named action owners, due dates, and measurable outcomes. Without that accountability loop, policy documents become static while attacker playbooks continue to evolve.
For teams with limited resources, start by prioritizing controls around vendor bank-detail changes and urgent wire requests. Those two transaction classes commonly concentrate the highest financial impact and usually deliver the fastest risk reduction when verification quality improves.
If leadership can only sponsor one additional improvement after baseline rollout, implement monthly exception-review meetings with finance and security together. Cross-functional review consistently improves escalation speed, policy clarity, and control adoption quality.
Sources (reviewed February 2026)
- FBI IC3 2024 Annual Report
- IC3 PSA (2024): Business Email Compromise: The $55 Billion Scam
- IC3 PSA (2024): Criminals Use Generative AI to Facilitate Financial Fraud
- IC3 PSA (2025): Senior US Officials Impersonated in Malicious Messaging Campaign
- IC3 PSA (2025): Senior U.S. Officials Continue to be Impersonated in Malicious Messaging Campaign
- FedNow Service Innovation Spotlight (Federal Reserve Financial Services)
- RTP Network FAQs (The Clearing House)
- U.S. Secret Service: Business Email Compromise
- CISA: Avoiding Social Engineering and Phishing Attacks
Related Reads
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