Impact on Clients and Market Integrity

In assessing each signal, ISFCA considers both the actual consequences of the misconduct and its potential to undermine confidence in the financial system.

• direct financial losses, compromise of data, or restriction of access to funds;
• use of false branding associated with banks, regulators, and other trusted organisations;
• risk of the scheme spreading to new user groups and platforms.

Recurrence of the Scheme and Cross-Border Scale

ISFCA assesses whether an incident is isolated or indicative of a broader pattern of misconduct.

• overlap in domains, wallets, advertisements, narratives, and messaging templates;
• use of multiple jurisdictions, digital assets, and intermediaries to obscure traces;
• indicators of a serial campaign aimed at attracting users at scale.

Quality of Internal Controls and Organisational Response

An important factor is how quickly the organisation identified the risk and which control mechanisms did or did not operate effectively.

• existence of escalation procedures, blocking scenarios, and secure client communication practices;
• the ability of compliance, risk, and security teams to identify and document indicators of fraudulent activity;
• the readiness to preserve evidence and engage with relevant stakeholders on a strict need-to-know basis.

ISFCA does not replace law enforcement authorities, but facilitates the initiation of reviews, the collection and structuring of evidence, and the establishment of a foundation for subsequent decisions and asset recovery.

Coordination and Public Risk Alerts

Where a risk affects a broad range of users or organisations, ISFCA issues public alerts and coordinates the exchange of threat indicators in order to reduce the window for repeated exploitation of the scheme.

• timely alerts for users and organisations regarding fraudulent websites, contacts, and payment details;
• analytical briefs on fraud typologies and common indicators;
• practical guidance on strengthening controls, verifying requests, and reducing operational risk.