FCA-regulated firms must show their fraud and AML controls would stand up to the regulator, the Ombudsman, or a court. We design, build, and tune your detection rules — and prove, rule by rule, that they hold up — in a regulator-ready pack. Built on years writing these rules inside a global bank. We start where it bites hardest: fraud and AML.
Rule defensibility
See which fraud rules you could not defend to the FCA, the Ombudsman, or a court.
Coverage gaps
Find the typologies your rules miss — APP scams, AML, card, and mule fraud.
Reproducible evidence
Consistent, traceable output — the same result every time, not a black box.
Live Assessment
Fraud Rule Defensibility Scorecard
Rule rationale
Documented and mapped to obligation
APP scam coverage
Gap flagged — 3 typologies uncovered
Owner & review
Owner named — review overdue
A defensible rule carries a documented chain from typology to threshold to accountable owner.
Why firms trust the work
All four domains
Rule-writing depth across APP scams, AML transaction monitoring, card fraud, and application/mule fraud — not one narrow lane.
Built inside banks
Detection rules written and tuned at scale in live UK banking and payment environments, under regulatory scrutiny — not theory.
Mapped to UK obligations
Every rule tied to what it implements — PSR APP reimbursement, the MLRs, FCA SYSC financial-crime, and Consumer Duty.
Reproducible by design
The same inputs produce the same documented, traceable verdict — evidence a regulator, an ombudsman, or a court will accept.
Specialist technical capability · regulated finance
From writing your fraud and AML detection rules to proving they hold up under scrutiny — end to end. Deep technical specialists who have sat inside the bank, not lawyers and not a software vendor. We lead with financial crime; the same rigour extends to AI decisions and cyber.
Financial Crime · Flagship
LiveDesign, tune, and assure your fraud and AML detection rules — documented, tested, monitored, owned, and mapped to the regulation each implements, across APP scams, transaction monitoring, card, and application/mule fraud.
AI & Automated Decisions
LiveRigorous, documented control over the AI and automated decisions that affect customers, money, or operations — clear ownership, review, escalation, and deployment oversight management can stand behind.
Cybersecurity & Resilience
LiveEvidence-forward, repeatable assurance for the controls that move money and protect customers — the same defensibility approach, applied to cyber and operational-resilience controls: documented, owned, tested, and mapped to the regulation each implements.
Three points where fraud rules are tested
Each of these moments is now tied to money — and each one turns on whether the rule was documented, tested, and defensible.
Moment 01
Since mandatory APP-fraud reimbursement, a weak or undocumented detection rule is no longer just a control gap — it is a cost you carry.
We diagnose your fraud and AML rules against a defensibility scorecard and surface coverage gaps across recognised UK fraud typologies, before they are tested.
Pre-review exposure
Moment 02
The FCA, the Financial Ombudsman, or a court can ask you to show that a fraud rule was adequate, tested, owned, and mapped to the regulation it implements.
We establish whether each rule has documented rationale, monitoring, and change control — and where the evidence is missing.
Evidence chain
System decision log
Available
Override record
Incomplete
Expert witness analysis
Not commissioned
Moment 03
Defensibility only holds if the rationale is documented, the rule is owned, and the output is reproducible — same inputs, identical traceable result.
We make that structure visible and challenge-ready — every assessment documented and repeatable — and hand you a regulator-ready pack.
Accountability trace
Business owner
Decision recorded
Governance owner
Review documented
Decision owner
Sign-off traceable
Business output
Defensible?
What we do
Ingress
Lineage
Model
Decision
Review
Data stream
Source integrity and lineage confirmed
Control lane
Exception rules and overrides inspected
Evidence lane
Decision record prepared for challenge
Decision Gate
Review finding
The flow only clears when lineage, control evidence, and accountable release conditions align.
The illustration reads as a resolution sequence: signals enter, controls are tested, evidence accumulates, and the decision gate clears only when the chain is defensible.
Governance
Customers, regulators, and auditors may ask you to explain any automated decision your business made. Good governance means each question has a clear answer before it is asked.
Named owners
Every decision point has a documented, accountable person.
Traceable decisions
The path from data input to business outcome is reviewable.
Evidence-ready
Records exist in the form that regulators and auditors can use.
Decision challenged
Credit decision #REF-4471 — Declined
Referred by compliance team · Tracing accountability chain
Accountable owner
Approval pathway
Data source
Decision rationale
Override record
Tracing 0 of 5 governance controls…
How it works
The process is straightforward. Each step replaces uncertainty with a clear picture of where your risk sits and what to do about it.
We identify the system, the decision path, the accountable audience, and the timing pressure.
Scope map
Evidence, system behaviour, governance controls, and decision logic are reviewed without ownership conflict.
Signal isolation
Findings are presented in plain language, with enough technical depth to satisfy regulators, legal advisers, or auditors.
Decision brief
Selected cases
AI is simply a form of automated system. Whether called a model, rule, or tool — if it produces outputs people rely on, it creates risk. Regulatory and legal obligations apply in the same way, regardless of the label.
Wondering how your own fraud rules would hold up?
Run the free defensibility check →What we see in practice
Get in touch
Start with the free, self-serve defensibility check — an estate scorecard plus a single-rule mini-check. No data heavy lifting. Or book a confidential briefing and Virticus will identify the right posture quickly.