Rob Rogers
At the Heart of the Matter: Vendor Authentication, Validation and Verification
Every payment your organization makes begins with a decision made long before the invoice arrives: the decision to trust a vendor. That trust, if poorly established, becomes a liability — a gap in your controls that fraudsters exploit and auditors flag. Vendor verification is how organizations convert trust from assumption into evidence. For CFOs and Controllers, vendor authentication, validation and verification are not a procurement formality. They are foundational disbursement controls — the
Onboarding Controls: Secure Vendor Onboarding
The Onboarding Moment Is a Control Moment Vendor onboarding is the point at which a new payment relationship is established — and it is one of the highest-risk moments in the entire accounts payable lifecycle. It is the moment when vendor identity is either verified or assumed, when banking information is either authenticated or taken on faith, and when the controls either hold or fail. What happens at onboarding sets the risk profile for every payment that follows. Despite this, many organiza
Beyond OFAC: Foreign Screening Obligations
Organizations that process payments in currencies other than U.S. dollars, that are incorporated or operate in the UK or EU, or that have vendors with international ownership structures face layered screening obligations under multiple regulatory regimes. OFAC compliance alone is an incomplete sanctions program for any organization with international exposure. The United Kingdom: The UK Sanctions List (UKSL) The United Kingdom's sanctions regime has operated independently from the EU framewor
Vendor Selection & Due Diligence: Authenticating the Vendor
Before a single invoice is approved, accounts payable must have established that the vendor is who it claims to be, that it is authorized to receive payment, and that its risk profile is commensurate with what is being purchased. The disbursement of funds through accounts payable is not a clerical act. It is the terminal point of a control system whose integrity depends, above all, on one foundational question: is this vendor legitimate? Vendor selection and due diligence are not procurement fu
Vendor Data Validation Explained: Why Accuracy in the Vendor Master Is a Control Imperative
What Vendor Data Validation Is — and What It Is Not Vendor data validation is the systematic process of confirming that the information held in an organization's vendor master file is accurate, complete, current, and trustworthy. It encompasses the verification of banking information, tax identification, business addresses, entity status, and the relationships between related data elements — and it applies not only at the point of vendor onboarding but throughout the life of the vendor relation
Bank Account Change Controls
Few areas within accounts payable (AP) and disbursements create more risk than vendor bank account changes. A single fraudulent or improperly validated banking change can redirect large payments into criminal accounts within minutes. Once funds are transferred, particularly through Automated Clearing House (ACH), wire, or real-time payment environments, recovering the money can become extremely difficult. That is why bank account change controls have become one of the most critical components
Evolution of Disbursement Controls in Finance
From Clerical Safeguard to Strategic Control Function The history of disbursement controls is, at its core, a history of hard-won institutional knowledge — knowledge accumulated through fraud schemes uncovered, funds unrecovered, and audit findings that arrived too late to prevent the loss. To understand where disbursement controls stand today, and why they matter more than ever, it is necessary to understand where they began: as a modest administrative mechanism designed for a far simpler fina
TIN Matching Requirements
TIN Matching Requirements in Disbursement Controls Accurate vendor data is the foundation of compliant disbursement processes, and at the center of that data is the Taxpayer Identification Number (TIN). Ensuring that vendor TINs are correct, validated, and properly matched to legal names is a regulatory expectation with direct financial implications. For accounts payable (AP), finance, and compliance leaders, TIN matching plays a critical role in meeting Internal Revenue Service (IRS) reporti
OFAC & Sanctions Compliance
Ensuring that funds are not sent to prohibited individuals, entities, or jurisdictions is a fundamental requirement of effective disbursement control. Regulatory scrutiny around sanctions compliance has intensified, and organizations are expected to implement robust, defensible processes to prevent violations. At the center of these requirements is the Office of Foreign Assets Control (OFAC), which administers and enforces U.S. economic and trade sanctions. For accounts payable (AP), treasury
AI-Driven Payment Fraud Threats: When the Attack Learns Faster Than the Defense
A New Threat Category — or an Old One Transformed? There is a temptation, when discussing artificial intelligence and fraud, to treat AI-driven threats as a distinct category of attack — something separate from, and in addition to, the BEC schemes, vendor impersonation tactics, account change fraud, and internal risk that the preceding articles in this series addressed. That framing is partly right and importantly wrong. AI has produced at least one genuinely new attack capability that did not