Closing the Transaction Monitoring Gap

Authorized push payment fraud doesn't show up in transaction monitoring. It can't. The customer authorized the payment, Strong Customer Authentication passed, and the rules engine saw nothing unusual, because nothing unusual happened at the transaction level. The manipulation happened weeks earlier, in the account, before any payment was ever initiated.

This case study looks at why transaction monitoring was never built to catch this class of fraud, and how Continuous Account Intelligence closes the gap: classifying risk on both payer and payee accounts before a transaction ever enters the payment flow. We cover the regulatory exposure under PS23/4 and Nacha's mid-2026 rules, how pre-transaction classification works in practice, and what it changes for fraud teams downstream.

For Fraud and AML teams at financial institutions, the real question is no longer whether transaction monitoring can catch a suspicious payment. It's whether you can classify the risk before the payment ever reaches the rail.

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Transaction Monitoring Misses Authorized Push Payment Fraud

Transaction monitoring was built to evaluate outgoing payments, and it does that job well. What it was never built to do is recognize an account trending toward victim or mule status. Those signals surface upstream, in channels TM never sees.

The transaction montoring blindspot, fraud preparation

PS23/4 and Nacha Reimbursement Rules

Under PS23/4, banks are on the hook for up to £85,000 per APP fraud claim, split 50/50 between sending and receiving institutions. Nacha's mid-2026 rules extend the same pre-transaction accountability to credit-push payments in the US, and the regulatory floor keeps moving upstream.

Continuous Account Intelligence: Classifying Payer and Payee Pre-Transaction

Acoru monitors accounts continuously: logins, profile changes, payee additions, behavioral shifts. It classifies both payer and payee before a transaction is considered. By the time a payment reaches the TM system, risk context already exists on both sides, so high-confidence cases route straight to investigators and low-risk transactions clear without friction.

Acoru classifies payer and payee accounts outside your bank