Bank detail change verification process for invoice fraud
Invoice fraud works by persuading a finance team to pay a genuine-looking invoice into a criminal's account. This guide sets out a short written control for supplier bank-detail changes: hold the payment, call back on a number you already hold, get a second person to approve, and keep a record an assessor or insurer can inspect.
Key practical checks for owners
- ✓Treat every bank-detail change as unverified until you have confirmed it by phone on a number already in your records.
- ✓Separate the person who enters the change from the person who verifies and approves it, using a director if staff are few.
- ✓Record who verified, when, how and which number was called, and keep it with the supplier record.
- ✓If money has gone, call your bank on its official number straight away and preserve the emails and invoices.
What the control has to stop
The typical attack is a request, by email or on a new invoice, to pay a supplier into a different bank account. The message may come from a spoofed address, from the supplier's genuinely compromised mailbox, or from someone posing as a senior colleague. Appearance proves nothing, because logos and wording are easily copied.
The control therefore assumes every change is unverified, including those from long-standing suppliers and those marked urgent. Urgency is itself a warning sign, so the written process should say that pressure to pay quickly is a reason to slow down and hold the payment.
Step one: hold the payment and record the request
When a change request arrives, the person who receives it must not update the supplier master record. They log the request and place any outstanding invoices from that supplier on hold. The held status stops a busy week from turning a pending query into a paid invoice.
- 1Save the original email or document, with full headers where your mail system allows, to the supplier's folder.
- 2Create a change request entry in your finance log with the date, supplier name, requester and the new account details.
- 3Mark open invoices for that supplier as on hold in the accounts system.
- 4Pass the request to the named verifier without acting on it.
Step two: call back on a number you already hold
The verifier phones the supplier on a number taken from your own records, such as a previous genuine invoice, the contract or an earlier payment file. A number in the change request, the email signature or the new invoice does not count, because the attacker controls it.
Speak to a known contact and ask them to confirm the new sort code, account number and account name. If the supplier cannot be reached on trusted details, the payment stays on hold and the matter goes to a director. Do not accept a reply by email as confirmation, since the mailbox may be the compromised channel.
Step three: second-person approval and invoice checks
A second person approves the change before the master record is amended. They should not be the person who received the request or who will release the payment. In a firm with few staff, a director or another colleague acts as the independent checker.
The approver also compares the invoice with a previous genuine one, checking supplier name, amount, reference and payment details. Apply the same checks to new suppliers and to urgent or unusually large payments, not only to changes.
- Named person authorised to verify changes
- Named different person authorised to approve changes
- Rule that new suppliers and high-value payments get the same checks
- Comparison against a previous genuine invoice
- Approval recorded before the master record is changed
Keeping an audit trail that an assessor will accept
An assessor or insurer will ask for proof that the control operated, not just a policy document. Each change should leave a record that shows who did what, when and by which method, and it should be held with the supplier record so it can be found quickly.
Someone independent of payments should also review bank statements periodically for unexpected payees or amounts. That review catches changes that bypassed the process.
- Date and time of the change request and how it arrived
- Copy of the original request or invoice
- Name of the verifier, date and time of the call
- Number called and its source in your records
- Name of the supplier contact who confirmed the details
- Name of the approver and date of approval
- Date the master record was updated
- Monthly bank statement review sign-off
If a payment has already gone to the wrong account
Contact your bank immediately using its official contact details, not those in any email, and ask it to attempt to recall the payment. Keep the emails, invoices and call records, as the bank and the police will want them.
Tell your IT contact or the person responsible for email security, because the supplier's or your own mailbox may be compromised. Pause any other pending changes from that supplier until you have verified them by phone.
Common questions
- Who should verify a supplier bank detail change in a small business?
- Name one person to verify the change by phone and a different person to approve it. If you have very few staff, a director or another colleague can act as the independent checker. The person who enters or pays the invoice should not verify their own request.
- What counts as a trusted phone number for the call-back?
- Use a number already in your records, such as a previous genuine invoice, the signed contract or an earlier payment file. Never use a number from the change request, the email signature or the new invoice. For a new supplier, obtain a number independently and record its source.
- Is an email reply enough to confirm new bank details?
- No. If the supplier's mailbox is compromised, the criminal can reply convincingly. Confirm by speaking to a known contact on a trusted number, and keep the payment on hold until that call has happened and been recorded.
- What should we do if we have already paid a fraudulent invoice?
- Call your bank at once on its official number and ask it to try to recall the payment. Keep the emails, invoices and your verification records, tell your IT contact about possible mailbox compromise, and report the fraud promptly.
- What records will an insurer or assessor expect to see?
- They will expect the original request, who verified it, the date, the number called, who confirmed at the supplier, who approved the change and when the master record was updated. Keeping these together with the supplier record makes them easy to produce.
Official UK sources checked
- Business payment fraud
- Business Email Compromise
- House buyers and businesses warned of payment diversion fraud
- Always confirm bank detail changes using a published phone
- Invoice fraud infosheet - nationalcrimeagency.gov.uk
- Business Email Compromise | NI Cyber Security Centre
- NCA and NatWest launch campaign to protect against Invoice ...
- OFFICIAL
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