Why good fraud management is a fit you achieve, not a setting you install.

White paper

We have an FMS" and "our FMS is good" are different claims. This paper argues that good fraud management under Circular 1213 is fit plus record: thresholds set against your own portfolio and re-tuned as behavior drifts, and evidence of every change written as part of the work rather than assembled afterwards. It explains why there is no universal threshold table, walks through calibration as a six-step cycle, shows where your records get read by other institutions under Circular 1215, and ends with twelve questions for your risk and compliance teams.

What's in it

• Why "we have an FMS" and "our FMS is good" are different claims
• Why Circular 1213 publishes no threshold table, and what it asks for instead
• What fit looks like across the five parameters, with illustrative pairings of the same signal in different portfolios
• Calibration as a six-step cycle: monitor, detect drift, propose, govern, apply, document
• Where your records get read: detection, temporary hold, and coordinated verification under Circulars 1213 and 1215
• What the law ties to adequate controls under AFASA Section 6
• A twelve-question self-assessment you can run against any FMS
• How SwiftGuard was built for fit plus record, and how blocking works in one field