Fraud, Risk and AML/CFT Controls: Layered Decisioning at $1B+ GTV
Layered fraud, AML/CFT and sanctions decisioning built natively into the payments stack, vendor signals, device intelligence, internal velocity rules, SAR-ready audit trails. Fraud loss held <0.1% of GTV; fraud incidents down ~65%.
What this is, in one paragraph.
Treated risk as a product, not a vendor. Combined vendor signals, internal velocity rules and analyst feedback into one decisioning layer with SAR-ready audit trails, held loss rates below benchmark at $1B+ GTV.
“Layered fraud, AML/CFT and sanctions decisioning built natively into the payments stack, vendor signals, device intelligence, internal velocity rules, SAR-ready audit trails. Fraud loss held <0.1% of GTV; fraud incidents down ~65%.”
Sanctions, PEP and AML screening at onboarding. Real-time scoring at authorization. Async monitoring on behavior and velocity. Each layer feeds the policy engine that decides the next.
The job to be done.
Cross-border, wallet and DCB flows expose multiple fraud vectors, chargebacks, account takeover, mule activity, structuring and sanctions exposure, that no single off-the-shelf vendor covers.
What we shipped.
- Real-time decisioning layer combining vendor signals, device intelligence and internal velocity rules
- Case management for analysts with SAR-ready audit trails
- Transaction monitoring scenarios for AML/CFT, sanctions and PEP screening
- Chargeback and dispute automation tied to merchant risk tier
How it's put together.
- Pre-auth, post-auth and async monitoring share one feature store
- Decisions are explainable end-to-end (rule + signal + outcome)
- Analyst feedback writes back to features, every closed case improves the model
Where I sat in the work.
Defined the risk product strategy, selected vendors, built the internal rules platform and partnered with compliance and operations.
What moved.
- Maintained fraud loss rates below industry benchmarks at $1B+ GTV
- Cleared regulator and partner audits including PCI DSS and ISO 27001
- Cut false positives without weakening AML/CFT controls
What we chose against.
- Accepted higher vendor cost early to bootstrap signal coverage, then internalized once volume justified it
- Held a strict false-positive budget that occasionally cost short-term GTV
What I'd take into the next build.
- Risk that is not a product surface becomes ops debt. Build review tools as carefully as merchant flows.
- AML/CFT scenarios decay, they need a feedback loop with analysts, not just a launch.
Relevance to networks, PSPs and cross-border platforms.
Every payments network has the same job here: keep loss below benchmark without strangling acceptance. The product playbook is identical.
Discussing payment infrastructure / product leadership roles?
Reference-available. Download the résumé or get in touch.
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