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FRAUDFORWARD
#120

A fraude segue o dinheiro: o que Washington e Las Vegas me fizeram pensar

28 min

E aí, combatentes da fraude? Sejam bem-vindos de volta ao Fraud Forward!

Acabei de chegar em casa vindo de Las Vegas às quatro da manhã de sexta-feira, depois de começar a semana em Washington, DC. Vou ficar em casa por exatamente mais duas noites antes de fazer as malas e partir novamente. Hoje não temos convidado. Somos apenas eu, meu microfone e um caderno cheio de assuntos para conversar.

Comecei a semana no HHS e depois voei de Washington, DC, para Las Vegas para participar do ACAMS The Assembly. Dois ambientes completamente diferentes. Ainda assim, continuei anotando variações sobre os mesmos temas: cultura, dados, responsabilização, colaboração, agilidade e tecnologia.

E então, uma frase dita em Washington acabou por definir toda a semana para mim. A fraude segue o dinheiro. É assim que este episódio começa e é assim que termina. Para onde vai o dinheiro, a fraude vai atrás. Quando o dinheiro muda, a fraude muda. Quando a forma como movimentamos o dinheiro se torna mais rápida, a fraude também se torna mais rápida. Quando criamos um novo produto, alguém descobre como explorá-lo. Quando corrigimos uma vulnerabilidade, encontram outra.

É assim que os fluxos impulsionados por fraudes funcionam na prática. E, se você prestar atenção para onde o dinheiro está indo, terá uma visão muito mais clara de para onde a fraude está se encaminhando.

O que você vai ouvir neste episódio:

  • Por que os fluxos impulsionados por fraudes conectam as fraudes em pagamentos em tempo real, os riscos de fraude com stablecoins e as fraudes com cheques na era digital em um único fio condutor
  • Paralelos entre programas governamentais de combate à fraude e o setor bancário que reformulam a forma como pensamos sobre a responsabilização em auditorias e as medidas corretivas
  • Por que a gestão responsável da prevenção de fraudes e a máxima de que um dólar economizado vale mais do que um dólar recuperado devem mudar a forma como nos comunicamos com a liderança
  • Como a cultura do programa de prevenção a fraudes funciona como um controle e por que o desalinhamento dos incentivos relacionados a fraudes compromete silenciosamente tudo o mais que construímos
  • O que os insights da ACAMS Assembly 2026 sobre fraudes em pagamentos em tempo real e riscos de crimes financeiros envolvendo stablecoins significam para o risco de fraude além dos limites organizacionais
  • Por que adotar tecnologia antifraude antes de definir o problema ainda é um dos erros mais caros em programas de prevenção a fraudes e como deveria ser, de fato, a mensuração dos resultados da IA no combate a fraudes
  • Como um ponto único de falha em um programa antifraude representa um risco de fraude oculto em uma discussão sobre dimensionamento de equipe
  • Por que a colaboração antifraude colocada em prática não se parece em nada com a colaboração antifraude discutida

Você deveria ouvir este episódio se:

  • Lidera um programa de combate à fraude e já teve a sensação de estar a ter a mesma conversa em salas completamente diferentes
  • Estão tentando descobrir como medir o valor da prevenção a fraudes e comunicar melhor seus resultados à liderança
  • Valorizam a cultura do programa de prevenção a fraudes e querem entender por que ela funciona como um controle, e não como um conceito abstrato
  • Já comprou alguma tecnologia antes de entender o problema que estava tentando resolver
  • Estão a lidar com o risco de perda de conhecimento sobre fraude porque uma pessoa da sua equipa sabe tudo e não têm a certeza do que acontecerá quando ela sair
Notas do episódio

Fluxos impulsionados por fraudes: o fio que liga Washington a Vegas

O fraudador não se importa com o nome que damos ao produto. O que lhe interessa são as oportunidades. Onde está o dinheiro? Como posso ter acesso a ele? Com que rapidez posso movimentá-lo? Onde estão as brechas? Essa é a avaliação de risco do fraudador. Às vezes, acho que a avaliação dele pode estar um pouco mais atualizada do que a nossa.

Duas conferências completamente diferentes. No fundo, a mesma conversa. Temos dados. Estamos a utilizá-los? Identificamos problemas. Estamos a resolvê-los? Sabemos que a colaboração é importante. Estamos a partilhar informações com rapidez suficiente para fazer a diferença? Sabíamos que problema estávamos a tentar resolver antes de comprarmos a tecnologia?

Responsabilização dos programas antifraude e lacunas na integração de dados sobre fraudes

Pense em quantas vezes investigamos algo e só depois descobrimos que, antes da perda, já havia informações dispersas por toda a instituição. A agência sabia de algo. Um alerta havia sido acionado. Outra conta havia sido sinalizada. Os dados existiam. Simplesmente não conseguimos conectá-los a tempo. Essas são lacunas na integração de dados sobre fraudes e constituem um dos problemas mais recorrentes que observo em programas com dificuldades.

Identificar o problema é apenas metade da questão. A outra metade consiste em tomar medidas corretivas, definir responsabilidades e garantir o acompanhamento. Quantas vezes uma vulnerabilidade já foi identificada, discutida e reconhecida, para depois voltar a ser explorada três meses mais tarde porque ninguém assumiu a responsabilidade pela correção? Em que momento deixamos de chamar a isso um problema de fraude e passamos a considerá-lo um problema de responsabilização no âmbito do programa de combate à fraude?

Gestão responsável da prevenção a fraudes e narrativa do programa antifraude

Um dólar poupado vale mais do que um dólar recuperado. Não consigo tirar isso da cabeça. Entendemos o conceito. Evitar a perda é melhor do que recuperar o valor perdido. Mas é difícil comunicar o valor da prevenção de fraudes. É fácil demonstrar uma perda de US$ 500.000. É muito mais difícil demonstrar que essa perda de US$ 500.000 nunca ocorreu. Não podemos contar apenas a história do que perdemos. Precisamos melhorar a forma como contamos a história do que evitamos.

Cultura do programa de prevenção a fraudes e desalinhamento dos incentivos relacionados a fraudes

Se eu avaliar um investigador pelo número de alertas que encerra, ele torna-se muito bom a encerrar alertas. Isso não é o mesmo que tornar-se bom a prevenir fraudes. Se o desempenho da empresa for avaliado com base no crescimento e o da equipa de fraude com base nas perdas, essas duas equipas podem rapidamente tornar-se adversárias. A cultura pode ser um mecanismo de controlo. Mas também pode comprometer todos os mecanismos de controlo implementados.

Fraude em pagamentos em tempo real, riscos de fraude com stablecoins e riscos de fraude além dos limites organizacionais

A maior diferença entre Washington e Las Vegas foi a velocidade. O que acontece quando o dinheiro se movimenta mais depressa do que é possível acompanhá-lo? Os riscos de crimes financeiros associados às stablecoins tornaram isso especialmente evidente. As instituições financeiras não podem olhar para as stablecoins e dizer que, por não oferecerem esse produto, o problema não lhes diz respeito. Os seus clientes podem interagir com elas. O destinatário também. Outra instituição na cadeia da transação também. O risco de fraude para além das fronteiras da organização é um problema atual, não futuro.

Tecnologia antifraude antes da definição do problema e mensuração dos resultados da IA no combate à fraude

Comece pelo resultado que pretende alcançar. Não compre uma solução antes de fazer isso. O que estamos a tentar corrigir? O que está a acontecer? Porque é que o controlo existente está a falhar? Só depois se deve falar de tecnologia. Durante uma conversa sobre IA na ACAMS, escrevi «resultados» em letras enormes no meu caderno. O que é que a IA fez realmente? Poupámos dinheiro? Evitámos alguma coisa? É isso que significa medir os resultados da IA no combate à fraude, e não poder dizer que estamos a utilizar IA.

Ponto único de falha no programa antifraude e retenção do conhecimento sobre fraudes

Temos aquele investigador que sabe tudo sobre um determinado esquema. Então, ele sai da empresa. Quanto conhecimento vai embora com ele? Isso não é apenas uma questão de pessoal. É um ponto único de falha no programa de combate a fraudes. A retenção do conhecimento sobre fraudes é um problema de concepção do programa. Se o seu programa de combate a fraudes depende de uma única pessoa se lembrar de como algo funciona, você não tem um processo. Você tem uma pessoa. E isso é uma vulnerabilidade.

Principais conclusões
  • Fluxos impulsionados por fraudes significam que a fraude acompanha o dinheiro em todas as direções. Fraudes em pagamentos em tempo real, riscos de fraude com stablecoins e fraudes com cheques na era digital fazem parte do mesmo espectro.
  • As lacunas na integração de dados sobre fraudes são um dos problemas mais recorrentes em programas de combate a fraudes com dificuldades. Os dados quase sempre já existiam antes da perda.
  • Um dólar economizado vale mais do que um dólar recuperado. A gestão da prevenção a fraudes e a comunicação sobre o programa antifraude exigem que sejamos muito mais eficazes em comunicar o que evitamos, e não apenas o que perdemos.
  • A cultura do programa de prevenção a fraudes é um mecanismo de controle. O desalinhamento dos incentivos relacionados à fraude é uma das formas mais comuns de esses programas falharem silenciosamente de dentro para fora.
  • O risco de fraude para além dos limites da organização não é uma preocupação futura. Os riscos de crimes financeiros envolvendo stablecoins e as fraudes em pagamentos em tempo real significam que a fraude não se limita às fronteiras da sua organização.
  • Um ponto único de falha no programa antifraude é uma vulnerabilidade na concepção do programa. Se o seu programa depende de uma única pessoa, você tem uma pessoa, não um processo.
Conclusão final

Não tenho uma resposta profunda depois desta semana. Sinceramente, tenho mais perguntas do que antes de ir, e esse é um dos motivos pelos quais gosto de participar desses eventos. Washington teve esse efeito em mim. A ACAMS também. Passei de conversas no HHS, em Washington, sobre verbas federais, auditoria e desperdício para conversas em Las Vegas sobre stablecoins, pagamentos em tempo real e IA. E continuei ouvindo ecos da mesma conversa.

A frase à qual continuo voltando é a mesma que abriu a semana e que ainda me parece a mais adequada para encerrá-la. A fraude segue o dinheiro. Nosso trabalho é garantir que estamos atentos ao próximo destino do dinheiro. Mantenham-se vigilantes, mantenham-se informados e continuem fazendo avançar o combate à fraude.

Conecte-se com Hailey Windham, CFCS | LinkedIn
Apresentadora do podcast Fraud Forward
Líder da comunidade bancária na Sardine
Especialista certificada em crimes financeiros (CFCS)
Credit Union Rockstar de 2023, CU Magazine
Prêmio de Melhoria Contínua, SAFE Federal Credit Union, 2023
Uma das 20 melhores profissionais com menos de 40 anos, The Sumter Item, 2022

Episode transcript
Smiling blonde woman in a black blazer with arms crossed, standing in a room with a "LIVE ON AIR" neon sign.
Hailey Windham
00:05
What's up, fraud fighters, and welcome back to Fraud Forward. I feel like I haven't actually sat still in about 2 weeks. I got home from Las Vegas at 4:00 in the morning uh on Friday morning after starting the week in Washington DC. And I'm home for just a few days before I turn around and leave again. So, today there is no guest. It's just me, my microphone, and a notebook full of things I wrote down over the last week that I have been dying to talk about. Some I've already shared a little bit on the LinkedIn. Uh but I kind of want to dive in a little bit deeper uh in this episode. So, and again, um you know, some of the the thoughts and comments are directly related to banking, some of them aren't, which is exactly why I think they're worth talking about. So, I started the week in Washington at HHS for the AERO program um integrity forum and then I flewed from DC to Vegas for ACAMS um the assembly. And let me tell you, if that doesn't already let you know that those are two very different rooms, they were. At Arrow we were talking about, you know, public funds, federal programs, grants, audits, oversight, program integrity, fraud, waste, and abuse. Then I get to ACAMS and we're talking about financial institutions, AML, fraud, payment, stable coins, real-time money movement, AI, information sharing, different money, different systems, different oversight. Yet I kept writing down versions of the same thing. Culture, data, accountability, collaboration, speed, technology. Um, and then one sentence from Washington ended up framing the entire week for me, and it's that fraud follows money. Well, yeah, that goes without saying, of course it does. Um, it sounds almost too simple. Uh, yet the more I thought about it, the more I realized how much of what we are dealing with in financial crimes comes back to that one statement, where the money goes, fraud follows. When the money changes, fraud changes. When the way we move money gets faster, fraud gets faster. When we create a new project uh product, somebody figures out how to exploit it. When we close one vulnerability, they look for another one. So, and I'm going to come back to that. Uh first, let me tell you where I'm going next. Uh because October is apparently the month where I decided I don't need to sleep. Um so, on October 6th, I'll be in Pennsylvania with ACF speaking about fraud risk assessments.
Smiling blonde woman in a black blazer with arms crossed, standing in a room with a "LIVE ON AIR" neon sign.
Hailey Windham
02:36
Then October 12th and 13th, I'm heading to Ohio for NASCUS Fraud School with Critical Ops, where I will also be talking about fraud risk assessments and giving a sneak peek into the benchmark report data. Uh, if you've followed me for any amount of time, you know, this is a topic that I care a lot about. A fraud risk assessment should not be something you complete, put it in a folder, and pull back out next year so somebody can say you did it. This is not a checkbox item. This is something that should tell you something about your program. It should tell you, you know, where you're exposed, where controls aren't keeping up, what's what's changed in your environment and where you need to put your attention. Funny enough, after the conversations I've had this past week, I have even more I want to say about that. Then October 18th through the 21st, I'm going back to Vegas for Money 2020. Chen Zamir and I are going to be together live and in person recording podcasts. Um, if you've listened to the recent episode where Chen interviewed me for Fraud Forward and I interviewed him for the Saturday Fraud Strategist, you already know what happens when you put the two of us behind the microphones. Um, and we've done all of that remotely, but now we're actually going to be sitting across from each other. Um, we also have a special announcement that'll be coming that week, but I'm not telling you what it is. I know that is so annoying, isn't it? You're just going to have to wait. Uh, so Fraud Forward is basically going mobile for the full month of October. There will be microphones, there will be conference floors, there will probably be questionable airport food and at least one moment where I ask myself, why have I scheduled my life this way? Most importantly, there are going to be a lot of conversations with fraud fighters. I want to bring as much of that back here as I possibly can because one of the biggest things this past week reinforced for me is how valuable it can be to get outside of our little corner of financial crime and Washington was probably the best example of that. So I'll start with explaining why Arrow was so interesting to me. This wasn't a banking fraud conference. You know, I wasn't sitting in a room full of fraud investigators talking about check fraud, account takeover, and scams. The conversation was much broader. Public money, federal grants, oversight, auditing, you know, program integrity, fraud, waste, and abuse. One of the first things I wrote down, which I've already mentioned, was that fraud follows money. My brain immediately went to banking, right? Because fraudsters don't care what we call the product.
Smiling blonde woman in a black blazer with arms crossed, standing in a room with a "LIVE ON AIR" neon sign.
Hailey Windham
05:02
They don't care which product or which department owns it. They don't care whether we are talking about a government program, a checking account, a wire, an instant payment, or a stable coin. They care about opportunity. Where is the money? How do I get access to it? How quickly can I move it? What controls stand between me and the money? Where are the gaps? That's the fraudster's risk assessment. Sometimes I think theirs might be a little bit more current than ours are. So, one of the early conversations at Arrow was about audits and the amount of time that can pass before an audit occurs. I wrote in my notebook that a law allows 9 months before the audit. And I remember, you know, thinking, do you know what a fraudster could do in 9 months? Forget 9 months. Do you know what they could do in 9 minutes? That is where the government conversation suddenly felt very, you know, familiar to me. The longer the gap between an event occurring and someone identifying the problem, the more exposure you can create. We see that in banking constantly. Think about how often we investigate something and discover afterward that pieces of information existed across the institution before the loss. You know, maybe the branch knew something. Uh maybe another account had already been flagged. Maybe there was a device connection. Maybe the customer had already called it in. Maybe an alert fired and was dispositioned. Maybe another department saw something completely unrelated that suddenly becomes very relevant once you're looking backward. The data existed, we just didn't connect it at the time. One phrase that I wrote down from Arrow uh was systemic and structured approach. That matters. If the only way you identify something is because one really good investigator happens to recognize the pattern, that's great investigative work, but it's not necessarily a great control. What happens when that investigator leaves? What happens when the volume doubles? What happens when the scheme changes slightly? You have to figure out how to take what your best people know and make it repeatable. So, are we finding problems or or fixing them? There was another conversation at Arrow that I I don't know. I guess it really just felt like it mattered a little more to me. Uh, and it made me really appreciate the people in the room because someone described audit as a finding versus a relationship with the recipient. I loved that distinction if I'm being honest and don't think that I'm suddenly going to become an auditor. Don't don't don't worry that that's not happening. Um, but I loved it because I immediately thought about fraud investigations. If I find the fraud, document what happened, calculate the loss, and close the case, did I succeed? From an investigative standpoint, yes.
Smiling blonde woman in a black blazer with arms crossed, standing in a room with a "LIVE ON AIR" neon sign.
Hailey Windham
07:50
But from a fraud program standpoint, maybe not because what happened next? And that was all over my notes from Washington. Corrective action. You know, what are the findings? What caused them? What are we doing about them? Who owns the fix? Does the fix actually work? Think about how many times this happens inside a financial institution. Fraud identifies a vulnerability. We send an email, there's a meeting, everybody agrees, yep, that's a problem. Then everybody goes back to work. Three months later, somebody exploits the exact same vulnerability. Now we're sitting in another meeting discussing the same issue. At what point do we stop calling that a fraud problem and start calling it an accountability problem? Finding the weaknesses is only half of it. There has to be ownership on the other side. That was one thing that I really liked about the corrective action discussion. Somebody has to own what happens next. There has to be follow through. There has to be a way to determine whether what we changed actually fixed the problem. Otherwise, we're just documenting vulnerabilities for the next fraudster. Culture also came up over and over again at Arrow. I have written it throughout my my notebook several times. You know, culture must change uh the culture of spending, cultural shift. There was a discussion around this idea that if the incentive is to spend allocated money, people behave according to that incentive. That immediately made me think about financial institutions. What do we incentivize? If I measure an investigator primarily on how many alerts they close, I shouldn't be shocked when they become really good at closing alerts. That doesn't necessarily mean we're becoming really good at preventing fraud. If the business is measured on growth and fraud is measured on losses, then those two teams can very quickly become, you know, adversaries instead of partners. If the front line believes escalating something to fraud means creating more work for themselves, what behavior have we created? If somebody identifies a weakness and raising their hands means that they become responsible for fixing the entire problem, how excited are they going to be to raise their hand the next time? We tend to talk about culture as this softer thing that sits somewhere outside of the fraud program. I'm not sure it does. Culture can be a control. It can also defeat every control you build.
Smiling blonde woman in a black blazer with arms crossed, standing in a room with a "LIVE ON AIR" neon sign.
Hailey Windham
10:12
That connects to something else from Washington that I wrote down. Hire good people who believe in what they're doing. That sounds simple, too. Yet, fraud programs depend enormously on people who are willing to ask questions. People willing to say this doesn't make sense. People willing to challenge a process that's been around for 15 years. You know, people willing to lead or tell leadership something isn't working. You cannot technology your way out of a culture where nobody is willing to do that. And I think I said that on the episode with Chen and I love that. The other thing was listening to some of the people in the room who again at one point, I'll be honest with you, I felt like I was more of an American consumer in the room than a fraud person just because of the caliber of people who were on the panels. I thoroughly enjoyed listening to them and their governmental backgrounds who, you know, are handling the most grants given, you know, than any other program in the world. And I'm sitting there just in awe of these people who actually care, right? And one of the things they talked about was stewardship versus spending. So again, that conversation around stewardship, one line in my notes that was a dollar saved is worth more than a dollar recovered. And I can't get that out of my head. We understand that concept in fraud. Preventing the loss is is better than trying to recover it, right? Yet, when we're trying to prove the value of fraud programs, prevention becomes difficult to quantify. It's easy to show someone a $500,000 fraud loss. It's much harder to show them that the $500,000 loss never happened. That is a challenge. I think fraud leaders need to get better at it. We can't only tell the story of what we lost. We need to get better at telling the story of what we prevented, where controls changed outcomes, what investigator interventions saved, and where our investments are actually producing value. Especially when we're asking leadership for resources. If you're asking for another investigator, another tool, or another million dollars in fraud technology, leadership is going to ask, "What are we getting it for?" And that's a fair question. We should be able to answer it. And there's a lot more where that came from as far as community banks and credit unions go when the benchmark report releases. And I can't wait because there's a lot of things that are are making sense between the two that are consistent with saying we have the data. We're not doing a good enough job telling the story. Okay, so moving on. Uh the other thing that we talked about was technology. I think it was probably one of my favorite things because they mentioned start with the outcome you're trying to get to. Do not buy a solution before doing that. Fraud fighters, please. Can we put that on a wall somewhere or a sticker? I know we are all obsessed with stickers at this point.
Smiling blonde woman in a black blazer with arms crossed, standing in a room with a "LIVE ON AIR" neon sign.
Hailey Windham
13:04
Because we do this backwards all the time. A new technology comes along, AI, behavioral biometrics, device intelligence, consortium data, graph, machine learning, whatever it is, we watch the demo and we think, "Oh, we need that." Okay, why? What are we trying to fix? I work for a fraud technology company. I am obviously not going to sit here and tell you that technology doesn't matter. It matters tremendously. What I'm saying is that you need to understand what the hell you're trying to fix before you start buying things to fix it. What is happening? Where is it happening? Why is the existing control failing? What data do we have? What outcomes do we want? How will we know whether the solution worked? Then let's talk technology. I had literally just talked about this on Fraud Forward before I went to Washington. The solution isn't always new tech. Sometimes you need to back up and understand the problem first. Another note I wrote down was test small data sets against policies. And I really like that approach. We get caught in the analysis paralysis. We think transformation has to mean ripping everything out and starting over. Sometimes you can take one problem, one data set, or one process and test something. Did it work? Great. Learn from it. Move forward. You don't always have to boil the ocean. Then, of course, we got into AI. Fraud fighters, if you're anything like me, your list of things to read keeps growing. Your time to read them, though, probably not so much. That's why I write the Monday Fraud Fix. It's the newsletter companion to Fraud Forward. So, every Monday I'm sharing fraud trends that made me pause, what I'm reading, conversations happening in our community, and the fraud fighters that I think you should know. I also bring my take, you know, what it means for the people doing this work, and the questions we need to be asking. Every now and again, I might leave you a little Scooby snack to start your week. You know, I just can't help myself. You can find the Monday fraud fix on Substack or tap the link in the episode show notes and subscribe. I'll see you in your inbox, fraud fighters. So AI came up in Washington. AI came up at ACAMS. AI comes up basically everywhere I go now. One of the discussions at Arrow was about using new tools to enforce old laws and using models to identify things that humans cannot reasonably identify across massive amounts of data. There is enormous potential there. I also wrote something else down in my notebook and it is how do we make this permanent? Um which I think that might be the most important question. We are really good at pilots. We are really good at innovation projects. We are really good at finding one person inside of an organization who's excited about something and letting them build it. But what happens when that person leaves? What happens when leadership changes?
Smiling blonde woman in a black blazer with arms crossed, standing in a room with a "LIVE ON AIR" neon sign.
Hailey Windham
15:46
What happens when priorities shift? How do you institutionalize the thing that worked? That applies to AI. It applies to fraud controls. It applies to collaboration. It applies to basically everything we're talking about. If your fraud program depends on one person remembering how something works, you don't have a process. You have a person. That is a vulnerability. AI doesn't fix that. In fact, AI can make it worse if we automate something nobody actually understands. If you automate a bad process, you now have a faster bad process. If your data is bad, AI doesn't magically make the underlying data trustworthy. If nobody owns the decision, AI doesn't create accountability. If departments aren't sharing information, guess what? AI doesn't fix the culture. The fundamentals still matter. Okay. So then I got on a plane and I went to Vegas. This is where the week got really interesting. So I leave Washington after talking about government programs, audit, stewardship, fraud, waste, and abuse. I fly to Vegas. Now I'm at ACAMS talking about banks and payments, AML, stable coins, AI, and financial crime. Yet I kept hearing echoes of the same exact conversation. The biggest difference speed. So at a camps there's a lot of conversation around real time information sharing and real-time money movement. That changes everything. You know for years fraud teams have been taught follow the money. Okay. But what happens when the money moves faster than you can follow it? That's the problem that we're having today. Money can move through multiple institutions, platforms, and potentially different forms of value before somebody even knows the original transaction was fraudulent. The old model of discovering the fraud, investigating it, calling another institution and trying to recover the money starts breaking down when the money is moving in seconds. That means our controls have to move differently. Our intelligence has to move differently and our partners partnerships have to work differently. So stable coins made this especially interesting. So they came up a lot at ACAMS. One of the questions I wrote in my notebook was are stable coins actually money? There was the discussion around stable coins as digital representation of money and their ability to make payments move faster and cheaper. There was also discussion about their role in fraud and financial crime. I don't think the fraudster cares what we decide to call them. They care whether they can move uh value. That's it. Can I move it? Can I convert it? Can I exploit a gap between systems? Can I move faster than the people trying to stop me? That's why financial institutions cannot look at something like stable coins and say, "We don't offer that, so it's not our problem." Your customer might interact with it. Your business customer might. The recipient of the funds might interact with it. Another institution in the transaction chain might. Fraud doesn't stop at your organizational boundary. So then we think about the the whole picture, right? Uh nobody has the whole picture which again just leads into this whole other theme that came up repeatedly and that's partnerships and it could be the biggest connection between Washington and Vegas that I saw.
Smiling blonde woman in a black blazer with arms crossed, standing in a room with a "LIVE ON AIR" neon sign.
Hailey Windham
18:50
Nobody has the entire picture. One financial institution sees the sending account another sees the receiving account. A fintech may see the device. A payment provider sees something else. Law enforcement also may see you know multiple victims. The customer knows the social engineering story. A government agency may see another part of the activity entirely. Everybody has a piece of this puzzle. The fraudster is often the only person who understands the whole puzzle and that's a really big advantage. So the other thing that I wrote down from Arrow was the uh cooperative approach at ACAMS. I'm having and hearing conversations about public private partnerships, information sharing, and the need to collaborate. Same problem, right? Different room. We say collaboration constantly in this industry. The question is whether we actually operationalize it. Do your investigators know who to call at another institution? Can information move fast enough to matter? Are we sharing intelligence before something becomes a $5 million problem? Are we waiting until after the fraud to compare notes? The criminals are collaborating and most of the time they're doing it better than we are. Um there's another thing, right, that comes up. Um it's another uh aspect that I think probably perfectly sums up financial crime in 2026. Uh you know, we're sitting in Las Vegas talking about AI, stable coins, digital assets, and real-time payments. Um, then somebody starts talking about paper checks. Of course, we're building the future of money while simultaneously trying to stop someone from stealing a piece of paper out of a mailbox, washing it, and depositing it. That is the reality of fraud. We don't get to choose one area. Checks don't didn't disappear when cards came along. Cards didn't disappear when digital banking came along. ACH didn't disappear when instant payments came along. The fraud teams gets to deal with all of it. Um, so when we say fraud teams need to keep up, think about what we're actually asking them to keep up with. Old fraud, new fraud, old payment rails, new payment rails, new technology, legacy systems, new regulations, old controls, customer expectations, and criminals who do not have to wait for a budget cycle before they change tactics. That's a lot, don't you think? It is also why I keep coming back to fraud risk assessments. I think I'm just going to say it till I'm blue in the face. You cannot manage that environment based entirely on what happened last year. So, by the time I left Vegas and was, you know, reading back through my notes from Washington and Vegas, I started to realize there was a lot of the same conversation. These were completely different environments, but we're struggling with, you know, the same things. We have a ton of data. Are we using it? We can find problems, but are we fixing them? We know collaboration matters. Are we sharing information in a way that's useful and fast enough to make a difference? Same thing with implementing technology. Did we know what problem we were trying to solve before we implemented one? Uh that last one is probably going to continue uh to be a soapbox for me. I I work for a technology company. I see what good technology can do. This isn't me saying that we we don't need better tools. I'm saying I don't want us to buy technology to compensate for the fact that we haven't taken the time to understand the problem. And that's one of the things that again came up in Washington and then I heard the different versions of it again in Vegas. The same thing is true with AI. There were some really interesting conversations about what AI can do with data. How it can identify things we can't reasonably identify manually and how it can help us move faster. Great. I want all of that. I also wrote in huge letters in my notebook results. I want you to see it. Results.
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Hailey Windham
23:10
Uh what did it actually do? Did we save money? Did we prevent something? Did we make the process better? Did we, you know, find something we weren't uh finding before? That's that's what I care about, not whether we can say we're using AI. I also wrote down um an arrow that I talked about a second ago that I think is probably going to really stay with me for a while and it's how do we make this permanent? You find something that works, great, but now what? Does it become part of how the organization operates or does it disappear when the person championing it leaves? That happens in banking all the time. We have that one investigator who knows everything about a particular fraud scheme, that one person who knows who to call at another institution, the other person who knows the weird work around the core. Then we have someone who we can look at something and immediately tell you that it doesn't make sense and then they leave. How much knowledge walks out of the door with them? That isn't just a staffing issue. That's a that's a broad risk. And I think that's probably where I'm landing after all this week. After this week, I I don't have some profound answer for you. I honestly I'm sorry. I have more questions than than I did before I went, which frankly is one of the reasons I like going to these things. I I don't want to leave a conference with 10 quotes for LinkedIn and a bunch of vendor swag because honestly, I love my swag. But, you know, whatever. We'll we'll we'll leave that where it is. Um, but I want to leave questioning something. Washington did that for me. ACAMS did that for me. That that was one of the things I I talked to, you know, my team at Sardine about. They were like, "Hailey, do you want to go to ACAMS?" And I said, "Yeah, but selfishly, it's because I want to attend the um the sessions. I I want to learn. I want to make sure that when I go to these things, it's not just for the hype of the conference, right? It's to actually take back something tangible that I can give back to you guys on what I learned, how we can move it into a practical conversation that that we take back to our organizations and we say, "This is this is what they discussed. These are things that we weren't thinking about and things that we need to to consider going forward. So now I'm going to spend probably the next few weeks talking to even more people about fraud risk assessments, controls, payments, and where all of this is going. Uh I mentioned it earlier, but I'll tell you again. I'm going to be in Pennsylvania on October 6th, Ohio for NASCUS Fraud School October 12th and 13th. And then Chen and I will be back in Vegas for Money 2020 October 18th through the 21st. And I'm really excited about it.
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Hailey Windham
25:53
Last time I went to Vegas, I got married again to my husband of 15 years. Uh I don't know what's going to happen this time, but it's going to be fun. Um and yes, again, I do have we do have a surprise coming at Money 2020, and I'm still not telling you yet because I like to leave a cliffhanger. I like to leave you wanting more, and that's the way to do it. Um, so again, you'll just have to stick around or come back for that one, right? Okay. So, for now, I'm going to enjoy being back home again for just uh two more sleeps and then um again, I'm going to have to probably unpack a suitcase, repack a suitcase, wash some clothes, you know, um and pack snacks. I don't know about you guys, but I have decided that I am the worst traveler in the world because when I get to a new city, I I get so inspired by all these wonderful people on LinkedIn who go, I go for a run. I do not. I'm I'm a hermit. I get in my hotel room and then I go, "Oh my god, I'm so hungry. I'm so hungry and I don't want to go out by myself. This is a strange new place and I haven't been there before." You would you guys would be surprised. I am more of a hermit than you realize. You think I'm this extrovert and I am at conferences and I am on my podcast because it's my one time that this middle child who's been starved for attention her whole life gets to talk and no one tells her to be quiet because I can't hear you. And I mean you tune in every week so I'm assuming you like my tangents. But anyways, I digress. What I was trying to say was but I've decided that I have to start packing snacks or else I'm going to starve when I go to these places. So, if you see me at a conference, ask me if I've eaten anything. And if I haven't, maybe we can go get something together so I don't have to go by myself. Okay, that was my that was me asking for help. I hope you guys realize that. You know how hard that is to ask for help? Now, I did it. Okay, anyways, I hope you enjoyed that. Um, that was my last little tangent. I promise. Um, the one sentence I This is how I'm going to end the end our episode today. Um, the one sentence that I'm going to circle back to from the beginning. Um of the week and it still feels right. Uh the right place to end today's episode is that fraud follows money. Our job is to make sure we're paying attention to where the money is going next. Stay vigilant, stay informed, keep moving fraud forward.
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Hailey Windham
28:15
Thanks for listening to Fraud Forward. Remember, every conversation, every connection, and every insight moves our industry one step closer to stronger fraud defenses. If today's episode sparked an idea, share it with your team or tag me on LinkedIn. I love hearing how you're moving fraud forward in your own organization. Until next time, stay curious, stay resilient, keep moving fraud forward.