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How to prevent invoice fraud in accounts payable: six key controls


Invoice fraud enters accounts payable at six points: purchase orders, supplier details, invoice intake, approvals and payment, off-process requests and refunds. The strongest controls are a second approver for bank-detail changes, callbacks on a number already on file, duplicate checks, segregation of duties, and paying from the system, not a file or paper check.
- Types of invoice fraud and where each one enters accounts payable
- How to prevent invoice fraud at each point it enters accounts payable
- Invoice fraud red flags: a checklist for AP teams
- What to look for in AP software to prevent invoice fraud
- Prevent invoice fraud by closing every entry point
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Invoice fraud is when a business is tricked into paying a fake, altered, or duplicate invoice, or into sending a genuine payment to the wrong bank account. You prevent it by putting a control at each point an invoice or payment request enters accounts payable (AP). Spotting fake invoices covers only one of those points.
The FBI’s Internet Crime Complaint Center (IC3) received 24,768 business email compromise (BEC) complaints in 2025, with reported losses of more than $3 billion. And in the AFP’s 2026 Payments Fraud and Control Survey, 76% of US organizations said they were hit by attempted or actual payments fraud in 2025. Those are only the cases that get reported, so the real cost is higher.
Because diverted payments are so hard to get back once they leave your account, prevention matters more than recovery. This guide maps out six points where invoice fraud enters AP, the control that closes each one, and how a finance system enforces it. At the end, there’s a red-flag checklist for your AP team and the questions you should ask AP software vendors.
Four-eyes approval on every bank detail change
Types of invoice fraud and where each one enters accounts payable
Invoice fraud is any scheme that gets a business to pay money it doesn’t owe, or to pay what it does owe into an account a fraudster controls. You’ll also see it called accounts payable fraud or vendor fraud, and when the scam targets bank details, vendor impersonation or payment diversion fraud. Whatever term you use, it’s the same problem.
Where the fraud starts decides which control stops it. External fraud arrives through a spoofed email or a hacked vendor mailbox, so verification closes it. Internal fraud starts inside the business, often with a vendor’s help, so separating duties closes it. The table below shows the most common types and where each one enters AP.
| Type | What happens | Where it enters AP |
|---|---|---|
| Vendor impersonation (payment diversion) | An email posing as a vendor asks you to change their bank details | Vendor details |
| Fictitious vendor | A fake company is set up as a vendor, often by an insider | Vendor details |
| Fake or false invoice | An invoice for goods or services that were never supplied | Invoice intake |
| Altered invoice | A genuine invoice with changed bank details, often from a hacked vendor mailbox | Invoice intake |
| Duplicate invoice | The same invoice paid twice. Often not malicious: a vendor chases payment and resends it, sometimes with a new number | Invoice intake |
| Inflated pricing or kickbacks | An insider and a vendor agree on prices above the contract | Purchase request and PO |
| Split invoices | One bill split in two to stay under an approval limit | Approval and payment run |
| Check fraud | A check to a vendor is stolen, altered, or counterfeited | Approval and payment run |
| CEO fraud | An email posing as an executive demands an urgent payment | Requests outside the process |
| Overpayment refund scam | A “vendor” asks for a refund to a new account | After payment |
Employee expense claims carry their own risks, which our business expense fraud guide covers.
How to prevent invoice fraud at each point it enters accounts payable
Each fraud entry point below tracks the same pattern.
- How the fraud works
- The control that closes it
- How a system enforces it
Purchase request and PO: invoices for things nobody ordered
How it works: a vendor bills for goods nobody ordered and counts on the invoice looking routine. Or an insider agrees on a price above contract with a vendor and shares the difference.
The control:
- No payment allowed without an approved purchase request or purchase order (PO)
- Match every invoice to its PO and receiving report before approval
- Check unit prices against the contract, not last month’s invoice
How a system enforces it: purchase requests route for approval before a PO is raised, and two- and three-way matching runs on every invoice linked to a PO. Payhawk matches more than $100 million of vendor invoices against POs and receiving documents each month. For the wider framework, see our guide to accounts payable internal controls.
As Tim Green, Head of Finance Transformation at Aventum Group, puts it:
The PO features have given us a lot more visibility and control. Now, with the approval workflows in PO, we can embed the controls in-house and give our procurement manager complete control.
Vendor details: fictitious vendors and vendor impersonation
The vendor master file is the most valuable target in AP. One edit to a bank account redirects every future payment to that vendor.
How it works: fictitious vendor fraud is when someone, often on the inside, sets up a fake company as a vendor so its invoices pass as normal. Vendor impersonation is when a fraudster posing as a real vendor says “our bank details have changed,” so the next payment lands in the fraudster’s account.
The control:
- Verify every new vendor before the first payment. Collect a signed Form W-9, check the business registration with the secretary of state in its home state, and confirm the address and the name on the bank account
- If you file Forms 1099, use the IRS TIN Matching program to confirm that the vendor’s name and taxpayer identification number (TIN) match IRS records
- Never act on a bank-detail change using contact details from the request. The FBI advises businesses to “establish more than one communication channel to verify significant transactions,” so call the number already on file
- Limit who can edit vendor bank details to named roles
- Require a second approver for every bank-detail change
- Alert on every change and warn before the first payment to a new account
How a system enforces it:
- A vendor bank detail change log records who changed what, when, and any note they added. Unpaid bills then show a notice that the payment details have changed, so you choose whether to apply the update
- Four-eyes approval, once enabled, holds a vendor bank-detail change, including adding new vendors, until another person approves it, and payments to that vendor pause in the meantime
- A first-payment warning appears before you pay bank details that have never been paid, on a new vendor or after a change
Invoice intake: fake, altered, and duplicate invoices
How it works: fake invoice fraud is an invoice for something never delivered. This is usually from an unfamiliar sender. An altered invoice is a real one but with new bank details, and it’s usually sent after a vendor’s mailbox is already compromised. A duplicate invoice is the same bill submitted twice, sometimes with a new number. Often there’s no fraud behind it: a vendor chases an unpaid invoice and sends it again. Either way, it’s AP’s job not to pay it twice.
The control:
- Bank details printed on an invoice never override the verified vendor record
- Check for duplicates on vendor, amount, date, and invoice number together, not on invoice number alone
- Send invoices with no PO and no vendor history to manual review
How a system enforces it: duplicate detection flags repeat invoices by amount, vendor, date, and document number. Invoices sent to the Payhawk Mailbox are checked for duplicates on arrival, and duplicates are removed before anyone reviews them. Matching then ties each invoice to its PO and receiving report.
As Shuhul Koul, Financial Controller at Arc and Naya, puts it:
Before, we just paid whatever came in. […] Payhawk builds in those checks, and that’s a game-changer.
Approval and payment run: segregation of duties, split invoices, and insider risk
How it works: an approver sees only an amount and signs it off. A bill is split in two to stay under an approval limit. One person changes a vendor’s bank details, confirms the payment, and authorizes it. A payment file is edited between export and upload to the bank, or a paper check is stolen and altered in the mail.
The control:
- Always route approvals by amount and show approvers the PO and vendor history alongside the invoice
- Separate confirming payment details from authorizing the payment (segregation of duties), so a second person always signs off (the four-eyes principle)
- Pay through the system, not from an exported file, so nobody can edit the payment file between export and upload to the bank
The second control has a name: segregation of duties (SoD). In payments, it means no single person can set up, approve, and pay the same transaction. In a small team where a step can’t be split, add a compensating control, such as an independent review of the payment run or of bank-detail changes.
Checks need their own control. In the AFP survey, 58% of organizations reported check fraud in 2025, making checks the most targeted payment method. Moving vendors from paper checks to electronic payments removes most of that exposure. For any checks you still issue, use your bank’s Positive Pay service, which matches each check presented against the list you issued.
How a system enforces it: approval workflows route bills by amount threshold. In Payhawk, segregation of duties for bill payments is on by default: the person who confirms payment details can’t authorize that payment.
Teams confirm and authorize vendor payments in the platform, and the authorizer can approve the final step in the web app or on their phone. US vendor payments go out as ACH transfers initiated from Payhawk, so there’s no payment file to edit and no paper check to intercept.
Requests outside the process: CEO fraud, business email compromise, and urgent payment emails
How it works: CEO fraud is where an email posing as a senior executive asks for an urgent transfer, often asking the recipient to keep it quiet. A different version can have a “vendor” asking to be paid today to a new account. Both are forms of business email compromise, and they’re common: in the AFP survey, 74% of organizations were targeted by BEC in 2025, and spoofed emails that appear to come from a trusted source were the most common type, received by 85%.
Business email compromise (BEC) can also go a step further. The fraudster gets into a real mailbox, so the request comes from a genuine address, often in the middle of an existing thread. Inside a finance or vendor mailbox, they can also intercept invoices and resend them with new bank details, or approve a request by replying to it.
The control:
- Nothing is paid unless the vendor is set up in the system and the invoice is approved
- Treat urgency and secrecy as reasons to slow down
- Verify by phone on a number you already hold, never by replying to the email
- Never approve a payment or a bank-detail change by email, even from a colleague’s real address. Approvals happen in the system, where each person signs in with their own login
How a system enforces it: the workflow is the control, so when every payable has to go through approved vendors and the approval chain, an urgent email can’t fast-track a transfer; it joins the queue like any other payment request. Because approvals and bank-detail changes happen in Payhawk rather than in an inbox, a hijacked mailbox can’t approve a payment on its own: the attacker would also need a Payhawk login protected by two-factor authentication.
After payment: refund scams and reconciliation
How it works: an overpayment refund scam is when a “vendor” claims you’ve paid twice and asks for the difference back to a new account. Fraud that slipped through earlier can stay hidden until someone compares the records.
The control:
- Treat any refund to a new account as a bank-detail change, with the same callback and approval
- Reconcile vendor statements against the ledger every month
- Review payments to new vendors at month-end
How a system enforces it: payments sync to the ledger for invoice reconciliation, and every action sits in a full audit trail you can check against vendor statements.
Lock down system access
Every control above depends on who can log in and what they can change. Require two-factor authentication (2FA), give each person a role that reaches only the steps they own, and keep an audit trail with before-and-after values on every change.
Payhawk logs every vendor change with who made it and when, shows old and new bank details on every change that needs approval, and emails admins when vendor bank details change.
Fraudsters who can’t get past the controls try to change them instead: editing a payment workflow to remove an approval step or switch a control off, inviting or promoting a second admin so one person can satisfy four-eyes approval, or using a bulk import to quietly change vendor bank details or give employees admin rights.
Payhawk extends four-eyes approval to these changes too. Any edit to the approve, review, confirm details, and authorize steps of a payment workflow, any invitation or promotion into a privileged role, and any import that changes vendor bank details or assigns a privileged role will need a second person to approve it.
Invoice fraud red flags: a checklist for AP teams
Below are some key signs that an invoice or payment request needs a second check before it’s paid.
| Red flag | Why it matters |
|---|---|
| Invoice bank details differ from the vendor record | Classic sign of an altered invoice |
| Bank-detail change requested by email | The core move in vendor impersonation |
| Pressure to pay today, or “keep it confidential” | Urgency is how CEO fraud skips checks |
| New vendor with a large first invoice | Fictitious vendors often bill big, early |
| Invoice number out of sequence or already used | Points to a duplicate or a fake |
| Amounts just under an approval limit, or several from one vendor in a short period | Classic split-invoice pattern |
| No PO, or a PO raised after the invoice | Someone might never have approved the purchase |
| Sender domain one character off the real one | A lookalike domain impersonating a vendor |
| Vendor address or bank account matches an employee’s | Possible insider fraud |
| Layout, logo, or tax ID (EIN) differs from earlier invoices or the vendor’s W-9 | Possible fake or altered invoice |
| Domestic vendor asks to be paid to an overseas or personal account | A common diversion route |
A red flag is a reason to verify through a known channel; it’s not proof of fraud. If money has already gone, call your bank immediately to ask for a recall, and report it to the FBI at ic3.gov.
What to look for in AP software to prevent invoice fraud
The controls above only work if they run in one place, rather than across inboxes, spreadsheets, and bank portals. That’s harder than it sounds: in research Payhawk ran with Raconteur, 63% of CFOs and 70% of CIOs said centralizing control and visibility was “extremely challenging.”
The right AP software takes most of that work off your team. Use these questions to test how well a vendor prevents invoice fraud:
| Question | Why it matters | What a strong answer looks like |
|---|---|---|
| Does it flag bank details that don’t match the vendor record? | Stops payments to a fraudster’s account | A warning on any bill whose bank details differ from the verified vendor record, plus a warning before the first payment to new bank details |
| Who can edit vendor bank details, and does a change need a second approver? | Closes the main vendor impersonation route | Named roles only, and a second approval before any change takes effect |
| Are bank-detail changes alerted and logged? | Lets you trace every change | A log of who, when, and why |
| Is separation between confirming and authorizing enforced by the system? | Policy alone depends on memory | Enforced in the workflow, on by default |
| Which fields does duplicate detection check? | Number-only checks miss renumbered duplicates | Vendor, amount, date, and document number |
| Does it match invoices to POs and receiving reports? | Catches invoices for things nobody ordered | Two- and three-way matching with discrepancies flagged |
| Are payments executed in the platform or exported as a file? | Exported files and paper checks can be altered | Electronic payments executed in the platform |
| Is 2FA required, and are roles granular? | Controls rely on access | 2FA at login and role-based permissions |
| Can you export the audit trail for an auditor? | Evidence for audit and investigation | A full, exportable trail of actions and changes |
A platform like Payhawk covers these inside one workflow, from purchase request to payment. See how controls work together in our invoice fraud prevention overview, or explore our accounts payable software.
Prevent invoice fraud by closing every entry point
Invoice fraud enters accounts payable at six points, so one control can only cover part of the risk. The biggest opportunities sit in the gaps between steps: off-process requests, bank-detail changes, and refunds.
Controls work best when the system enforces them, so they hold up on the busiest payment day without anyone having to remember.
If you’d like to see these controls in your AP process, book a demo.
With over 15 years of experience in SaaS and digital communications, Paul specializes in translating complex financial concepts into clear, engaging narratives. At Payhawk, he combines creativity and analytical insight to help finance teams thrive through data-driven storytelling.
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