The Market is Shifting. Is Your Program Ready?
Losses are rising fastest where capabilities are thinnest. Mid-market institutions and ambitious platforms are taking the hardest hits, equipped with historically lean teams to handle an evolving, continuous threat. We see this reality on the ground every day:
- Pervasive Threat Drivers: Surging check fraud, GenAI-fueled account takeovers, and Authorized Push Payment (APP) scams where shifting liabilities mean institutions are carrying exposures that aren't yet priced.
- A Reset in Regulatory Expectations: Recent record-breaking federal penalties haven't just targeted bad models—they’ve punished fundamental operational failures. Poor monitoring calibration, weak training, lack of staffing, and the inability to close out consent orders are drawing intense regulatory fire.
- Recurring Proof Obligations: Modern network rules and regulatory standards—like Nacha’s risk-based monitoring frameworks—demand strict, documented evidence of calibrated controls and regular review.
Our Team
Jeff Moriarty
Sterling Metz
Donna Turner
Shawn Holtzclaw
Rick Hamilton
Patrick Davie
The CXO Partners Differentiator: Senior Executive Delivery
We support our clients in a way others cannot: We merge genuine operational depth in both Fraud and AML. Also, we operate strictly on a senior-only delivery model. When you hire CXO Partners, you get proven operators who have built these programs, survived the exams, and halted the losses themselves.
FRAUD PROGRAM DESIGN & GOVERNANCE
Fraud program design and governance, risk appetite and board reporting, regulatory and examination work, product governance, FRAML operating models, post-merger integration.
AI GOVERNANCE & AML DATA SCIENCE
AML data science and transaction monitoring model re-engineering, model risk and validation, AI and agentic risk governance, economic capital and quantitative risk.
PRODUCT STRATEGY, ARCHITECTURE & FULL-STACK BUILDS
Product strategy and architecture, identity verification and fraud detection design, data and decisioning platforms, working prototypes, and full-stack build.
FRAUD STRATEGY & OPERATIONS LEADERSHIP
Fraud strategy and operations leadership, enterprise fraud metrics and analytics, fraud technology market and vendor landscape, industry analyst credibility.
Transformative Capabilities & Services
FRAML Program Assessment & Benchmark
A structured, rigorous assessment of your entire fraud and financial crime program, scored against a clear maturity model and benchmarked against your true peers by asset size and type. We cover governance, risk appetite, detection, case management, loss accounting, and third-party exposure.
Compliance Program Design & Build
Building or rebuilding exactly what the assessment found missing, including: Target operating models, FRAML convergence design, unified loss taxonomies, control testing, enterprise BI reporting, 314(b) information-sharing operationalization, scam readiness, and modern dispute/Regulation E decisioning frameworks.
Model Risk & AI Governance for Financial Crime
Assessing the models operating underneath your program—verifying that they actually work, that they are mathematically defensible, and that your institution can confidently answer for them. Includes: Transaction monitoring tuning and optimization; fraud model performance review (above/below-the-line testing); independent model validation and SR 11-7 alignment; and vital AI/Agentic risk governance for institutions deploying machine learning.
Technology Strategy & Vendor Evaluation
An independent, objective assessment of your fraud and financial crime stack. We consult with you on what to buy, what to replace, what’s actually working, and what is just expensive shelfware. Includes: Current-state assessment, actual risk-profile requirements definition, vendor landscape briefings, RFP execution, build-versus-buy analysis, and post-implementation efficacy review.
Regulatory Readiness & Examination Response
Proving your program’s efficacy and compliance to whoever is asking—be it an examiner, auditor, the board, or a network rulebook. Includes: Required documented evidence files, mock examinations, MRA and consent order remediation planning/tracking, and exposure reviews against the latest federal fraud enforcement agendas.
Transaction Risk Diligence (Financial Institutions)
Evaluating fraud and financial crime risk in bank or credit union transactions, both before the letter of intent and surviving the post-close integration. Covers: Acquirer readiness (can the acquirer's own program survive merger review?), Target diligence (run-rate, SAR backlogs, reserve adequacy, key-person risk), and post-close integration to ensure the combined institution runs the strongest program, not just the acquirer’s default program.
Investment Diligence — Fraud & Financial Crime Technology
Practitioner diligence on fraud, identity, and financial crime tech assets for the investors looking to acquire them. We find out if the detection actually works, or if it's just a good demo. Includes: Commercial and technical diligence, efficacy validation, architecture roadmap credibility, competitive positioning via structured institutional buyer panels, and regulatory tailwind assessments (is growth real, or just riding a compliance deadline?).
Transaction & Interim Leadership
We can support enterprises in a variety of executive operating roles and functions, if needed. These include: Chief Risk Officer (CRO), Chief Compliance Officer (CCO), Head of Financial Crimes, BSA Officer, CIO, Chief Data Officer, M&A Counsel, and Board Risk Committees.
Insights
Next Steps
Review our team of experts or schedule a brief call. Once you schedule a call, one of our team members will contact you directly to learn more about your needs.