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Business units often focus on their core responsibilities, bringing specialized expertise to their organization. While this can make day-to-day operations efficient, it can create gaps when responding to fraud incidents. Without coordination, responses can be slow, inconsistent or ineffective, leaving an organization vulnerable.

An effective Fraud Response Plan relies on collaboration and clear communication. Organizations that foster strong collaboration across all business units can act swiftly to contain and resolve fraud incidents together. Define the Scenarios in Scope of the Plan Scenarios should consider the type of fraud, the payment type, the severity of known and potential fraud and the impact of actions taken during the scenario’s execution. The type of fraud helps determine the potential scale of an incident. For example, an account takeover may affect a single client, while a BIN attack could impact a group of clients. A business email compromise (BEC) might result in a few misrouted payments, whereas a spoofing campaign could affect multiple online banking profiles, potentially exposing significant funds if fraudsters gain access.

The payment type influences how quickly response teams must act. Different payment methods have varying recovery options and limitations. Wire transfers, for instance, move faster than bill pay transactions and require immediate attention.

While it may be difficult at the onset of an incident to fully gauge the severity of known or potential fraud, consideration should be given to the number of clients affected and whether fraudulent transactions involve high-dollar amounts or high volume.

Actions taken during a fraud incident can have subsequent impacts. In an account takeover scenario:

• If a client’s online banking profile is suspended to block fraudsters, how can legitimate access be restored promptly?
• If the affected client needs to send an ACH payroll file while their profile is suspended, what steps can your institution take to support them and minimize disruption for both the client and their employees?
• If accounts are blocked, how are legitimate transactions identified and managed? 

Defining these parameters within the scope of the Plan ensures clarity and accelerates response times.

This information should be used to clearly define roles and responsibilities for each scenario, ensuring that all teams understand their part in responding effectively.

Define Roles and Responsibilities for All Business Units

Next, assess the impacted business units and determine both their role and responsibilities required to execute the scenario Plan effectively. For example, a Treasury Officer who regularly interacts with clients is best positioned to gather information and communicate updates. Their role is client contact, while their responsibility is to collect information and serve as a liaison between the client and operational teams managing the fraud incident.

This step is essentially an assessment of who does what, and when, within the scope of each scenario. Different groups may be involved depending on the type of incident. Consider these key questions: 

• Who owns the Plan?
• Who has the authority to activate it?
• Who contacts receiving institutions?
• Who completes and sends Letters of Indemnity?

The Plan itself should remain high-level, while each business unit maintains detailed procedures. Both the Plan and the procedures should reference one another to ensure consistency, awareness and smooth execution during an incident.

Communication, Communication, Communication

When a scenario is activated, it’s critical to define what will be communicated, to whom, how and when. Communication plans—whether general or scenario-specific—should include templates tailored by scenario, audience and method to ensure messages are consistent and recognizable as fraud incident communications. Each message should provide a high-level overview of the issue, actions being taken and by whom, clear action items for recipients if needed and a timeline for updates.

• Internal Communication: Email and internal chat services can both be leveraged. Email works well for broad notifications, but can become unwieldy in large threads. Chat services allow rapid updates among teams closest to the incident, functioning as a “war room” for collaboration and real-time information sharing. Front-line staff handling client communication may benefit from reference guides with high-level talking points. Regardless of method, timely and effective internal communication keeps everyone informed and prevents unnecessary individual outreach that could slow response efforts.
• External Communication: Keeping clients informed is key to minimizing the impact of an active fraud incident and preventing future harm. Common channels include website banners, pop-up communications in online banking portals, direct emails and phone contact. The Plan should clearly define scenario-specific client communications and outline roles and responsibilities. For example, who can post a banner? Who is authorized to send a mass email? Clear accountability ensures messages are timely, accurate and effective. 

Leverage All Available Resources

The Nacha Risk Management Contact Registry is an essential tool—know it, use it and rely on it. When a fraudulent transaction leaves your institution, the next step is to identify the receiving institution and locate its fraud contact in the Registry. Don’t just submit an ACH return request and wait ten banking days—pick up the phone!

Timely communication between institutions greatly improves the chances of recovering funds. The receiving institution may be able to place a hold or block on the account to prevent further movement of fraudulent funds. Even if your institution stops the transaction before it leaves, reaching out to the intended receiving institution can alert them that their account may be facilitating fraud, allowing them to take appropriate action.

EPCOR’s Knowledge Community is a great resource to connect with other financial institutions to share insights on fraud prevention. If you don’t find the contact you need in Nacha’s Registry, their Member Support team is ready to help. You can reach out by phone (800.500.0100), email (memserve@epcor.org) or online chat (epcor.org). 

The ABA Fraud Contact Registry is another valuable resource for identifying fraud contacts at other institutions. Leveraging these tools ensures faster response times and stronger collaboration in combating fraud.

The Plan is a Living Document

A Fraud Response Plan should never sit on a shelf. Review it at least annually to ensure processes are accurate and scenario considerations remain relevant—fraud is always evolving, and so should your Plan. After any fraud incident, revisit the applicable scenario plans: Did new information emerge? Are there opportunities to improve response procedures?

Planning ahead saves time and protects clients. When teams collaborate effectively and everyone understands their role, both recovery and client retention improve dramatically. That difference could mean a small business survives a fraud event rather than closing its doors—and your institution earns trust and loyalty. In high-stress situations, knowing how to support clients is invaluable, and an effective Fraud Response Plan is essential to institutional success.

Catch fraud in its tracks! Check out our Monitoring for Fraud Did You Know video for practical tips on spotting unusual transactions, setting alerts and protecting clients. Share it with colleagues who manage fraud responses to strengthen your team’s readiness. Don’t stop there—explore our Fraud Monitoring toolkit, packed with ready-to-use resources like social media posts, article copy, ad content and more to help safeguard clients and your community. It’s just one of many toolkits your organization can use to boost awareness and stay ahead of emerging risks.