Leadership1 publisher3 min readPublished
Twin Peaks CTO argues the harder fraud problems start after authentication works
Shahen Minasyan, CTO at Twin Peaks Inc., argues that the FBI's $20.9 billion in 2025 reported fraud losses, up 26%, grew in places where identity controls did their job. Federal agencies say their own payments-fraud data is too fragmented to size that category.
The Board Room · Leadership desk
What happened
- The Federal Reserve's 2025 household well-being report found that 20% of adults experienced financial fraud or scams during the year and estimated $100 billion in non-credit-card fraud.
- A 2025 joint request for information from the Federal Reserve, FDIC and OCC put losses from payment-app, bank transfer, wire and check fraud at $2.99 billion in 2024, up about 271% from $806 million in 2020.
- The Federal Reserve's FraudClassifier model already separates payments initiated by authorized parties from unauthorized ones and covers cases where an authorized party was manipulated or acted fraudulently.
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Why it matters
- constraint A board that asks what share of its bank's losses came from customers who passed authentication is asking for a figure the federal collections would have to carry, and those are the collections the agencies themselves call fragmented.
- decision The spending choice for this cycle: another verification layer at the front door, or correlating signals the bank already holds across the relationship. Minasyan's case points the budget at the second.
- exposure Consumers absorbed $56 billion of the Federal Reserve's $100 billion estimate, 56% of it, so the argument over who reimburses authorized-payment scam losses reaches banks while pricing it still waits on a standardized number.
- contradiction The Federal Reserve's population estimate runs about five times the FBI's reported-loss total for the same year, so a trend argued off either series alone is fragile.
Take the FBI series on its own terms. A 26% rise to $20.9 billion implies about $16.6 billion in 2024 and roughly $4.3 billion of growth in a single year [1][14]. That series counts complaints filed with one channel, and the 2025 report logged more than a million of them [1]. Whether the increase is more fraud or more filing, the figures do not separate.
The 271% line checks out. $2.99 billion against $806 million is 3.71 times, a 271% increase across four years and about $2.18 billion in absolute terms [7][15]. The Federal Reserve, FDIC and OCC published that figure in their 2025 joint request for information [7]. The same document described payments-fraud data collection as "incomplete, non-standardized, ad hoc and fragmented," with gaps involving authorized payments that are part of scams or fraud [8].
Minasyan's claim is about what happens after the controls work. He wrote that some of the harder fraud problems begin after those controls have done exactly what they were designed to do [4]. The distinction is already in federal taxonomy. The Federal Reserve's FraudClassifier model separates payments initiated by authorized parties from those initiated by unauthorized ones, and covers the case where an authorized party was manipulated or acted fraudulently [5]. Federal Reserve Financial Services has noted that scams can lead to authorized transactions made by the authorized account owner [6]. "Trust cannot be a permanent status assigned during onboarding and refreshed only when a password, device or biometric challenge succeeds," Minasyan wrote [9].
Read the byline while you read the argument: Minasyan is CTO at Twin Peaks Inc. with more than 15 years in banking technology, AI and digital transformation, writing in a Forbes council column [10]. Two parts of the case come from elsewhere. The words calling the data fragmented are the agencies' own [8]. The category of the manipulated authorized customer is the Federal Reserve's [5]. His addition is the prescription: correlation across weak signals, on the grounds that lifecycle signals sit in different systems, owned by different teams and evaluated at different times [11][12].
None of the totals in the record is broken out by initiation category, so the share of the $20.9 billion that came through sessions a bank authenticated correctly remains unpublished [17]. If the 2025 request for information turns into standardized reporting, the split becomes something examiners ask for. A bank whose authentication history, device changes, payment behaviour and dispute records are owned by separate teams will be assembling it under deadline [12]. The OCC, in its Spring 2026 Semiannual Risk Perspective, said "banks continue to face challenges from both the elevated levels and rising sophistication of fraud and scams" [3].
What to watch
- Whether the Federal Reserve, FDIC and OCC follow the 2025 request for information with standardized reporting that splits authorized-payment scam losses from unauthorized ones.
- Whether the next OCC Semiannual Risk Perspective puts a figure on authorized-party scams, or stays with language about rising sophistication.
- Whether the FBI's 2026 report shows the 26% rise continuing, and whether complaint volume moves with the loss total.