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ForeGaze research · Trust · Part 1b · Fraud

When Fraud Hits: Who Pays

14 min read · Data: statutes and regulations, Nacha, FBI, provider and bank pages, read 25 Oct 2026 · US, with California noted; Canada not covered

ForUS small businesses, from solo owners to 500 people, that take card payments, pay by bank or send moneyUS (California noted)

Fraud in 2026 for US small businesses: who pays, what proof to keep, and what fraud tools cost.

In our reading of the rules below, the business bears the loss unless an exception applies. The main exceptions: the card issuer pays when a chip card was read by chip or an online order passed 3-D Secure; a bank pays for a wire if it did not follow the agreed security procedure; and a bank can pay for a forged check if you report it in time. A business card can also cap your loss at $50 (Reg Z), under conditions we did not fully confirm. For a payment you send after being tricked, we found no rule that makes someone else pay; the main option is a fast bank recall.

2 banking daysTo return an unauthorized ACH debit on a business account. A consumer gets 60 days (EPCOR, a payments association, on the Nacha return rules).
58%Of the money the FBI’s Recovery Asset Team tried to freeze in 2025: $679M of $1.16B, in 3,900 cases (FBI IC3). The report does not define the rate or say how fast reports were made.
$0–$75Monthly bank fee for positive pay or an ACH debit block, across eight US banks’ 2025–26 fee schedules. Chase lists $0.
0.40%PayPal’s fee per transaction for Chargeback Protection (0.60% for the Effortless tier), subject to a monthly loss cap (PayPal fee page, 2026).
Part 1 · What fraud costsThe numbers$20.9B reported to the FBI in 2025 · $3.05B from business email compromise.
Part 1b · When fraud hits · you are hereWho pays, what to keep, what tools costThe business pays unless an exception applies · 2 banking days to return a business ACH debit · bank fraud controls cost $0–$75 a month.
The answer

Assume you pay. Know the few cases where someone else does.

  • Our reading: the business bears the loss unless an exception applies. The issuer pays for a counterfeit chip card read by chip, and for an online order that fully passed 3-D Secure (fraud codes only). A bank pays for a wire it released without following the agreed security procedure, and for a forged or altered check if you were not careless or slow.
  • Business accounts do not get consumer rules. Reg E covers personal accounts. A consumer has 60 days to return an unauthorized ACH debit; a business has 2 banking days.
  • For payments you send after being tricked, we found no rule that makes someone else pay. Business email compromise cost $3.05 billion in 2025 in FBI reports. The main option we found is a fast bank recall. The FBI’s Recovery Asset Team froze 58% of the money it chased in 2025, $679 million of $1.16 billion; the report does not say how those cases compare with small-business payments.
  • Proof wins disputes. IP address, device ID, login and delivery proof, saved at checkout and kept 13 months, are what rebut a buyer who disputes a real sale.
  • Our reading: bank controls are the cheapest first step. Positive pay and ACH blocks cost $0–$75 a month on the schedules we read, and calling back on a known number costs nothing. Fraud guarantees look worthwhile mainly for online sellers with real third-party fraud, which we have not measured.
First step: ask your bank two things today: how long you have to return an unauthorized ACH debit, and what security procedure your wires use. Get both in writing.
1 · Who pays · US, with California

Who bears the loss, case by case

Read each row with its last column. Primary means we read the law or the provider’s own page; secondary means someone’s summary of it.

CaseWho usually paysTime limitRecovery chanceWhat we read
Stolen card, chip or tap, in personCard issuerNetwork dispute window; rule text not readHigh for the merchantUnconfirmed: the chip liability shift is known history; network rules: Visa rules, Mastercard rules
Same card swiped or keyed though it had a chipMerchantSameLowUnconfirmed: network rules: Visa rules, Mastercard rules
Online order disputed as fraud, no 3-D SecureMerchantResponse windows are short; we did not confirm Shopify’s window from a Shopify source (secondary reports 7 to 21 days)Low to moderate for true third-party fraudStripe support note; network rules: Visa rules, Mastercard rules
Online order with completed 3-D SecureCard issuer, for fraud codes onlyAuthentication must have completed, not fallen backHigh for fraud codes; none for “not received” or “not as described”Stripe Support (primary for Stripe); processor guide
Buyer disputes a real sale (friendly fraud)Merchant, unless it rebutsVisa Compelling Evidence 3.0: two earlier undisputed sales on the same card, 120 to 365 days old, with matching IP or device ID plus one more elementModerate to high if the data was saved at checkout; near zero if notSecondary: vendor summaries; Visa rule text not read. Mastercard has a similar First-Party Trust program (Mastercard releases, primary)
Unauthorized ACH debit on a business accountYou, unless it is returned in time2 banking days after settlement for the return; your bank may ask for notice sooner (one bank guide says 24 hours)High inside the window; low afterSecondary: EPCOR, Modern Treasury and a Nacha-exam guide
Payment you sent after being tricked (fake invoice, changed bank details)YouRecall only, as fast as possibleUnclear; the FBI froze 58% of money it chased in 2025, but the figure may not apply to small-business paymentsFBI IC3 2025 report (primary). Time-window freeze rates seen online are not in that report
Wire after an account takeoverYou if the bank followed an agreed, commercially reasonable security procedure; otherwise the bank must refundReport within a reasonable time, at most 90 days, to keep interest; one-year outer limitDepends on the contract and the bank’s procedureCalifornia Commercial Code §§11202, 11204 and 11505 text; Zengen v. Comerica (2007). Primary. The §11505 link is not saved in Sources yet
Forged, altered or washed check on your accountThe bank, unless you were careless or slow to review statementsOne-year outer limit; account agreements often shorten review periodsModerate to high if reported fast and you use positive payUCC 3-406 and 4-406 text from three state codes (Michigan, Massachusetts, Kansas; primary); California text not read. The model text may add a shorter rule for repeat forgeries; not confirmed
Counterfeit check you depositedYou; the bank can charge it back—Very lowUnconfirmed: not read
Business credit card used without authorizationCard issuer, up to $50, unless the issuer gave you 10 or more cards and the agreement says otherwiseNot confirmed: we did not read a notice deadline; the $50 cap also depends on conditions the issuer must meet (rule text not read)High for firms with fewer than 10 cards12 CFR 1026.12 and the CFPB interpretation (primary)
Payment-app or processor account takeoverYou, as a ruleReport at once; payouts may freezeLow to moderateUnconfirmed: provider terms not read
Employee theftYou, unless insuredPolicy notice deadlinesDepends on cover; social-engineering cover is usually a sublimitBroker pages only; no policy wording reviewed
2 · Business accounts · US

Consumer protections mostly stop at the business door

CFPBReg E

Personal accounts only

  • Reg E defines an account as one “established primarily for personal, family, or household purposes,” and a consumer as a natural person (12 CFR 1005.2).
  • So a business account falls outside its limits ($50, $500, 60 days). That is our reading of the definition.
  • Consumer liability tiers are in 12 CFR 1005.6.
NachaACH returns

60 days vs 2 banking days (Nacha rules as read in 2026; our reading)

  • Consumer unauthorized debit (R10): 60 calendar days, with a written statement.
  • Business unauthorized debit (R29): the receiving bank must return it by the second banking day after settlement.
  • After that, the business’s rights come from the account agreement and other law; we found no rule that extends the ACH return window for a business.
eCFRBusiness cards

$50 cap, with a catch (Reg Z text as read in 2026; our reading)

  • Reg Z’s $50 limit applies to business cards too (12 CFR 1026.12).
  • An issuer that gives an organization 10 or more cards may agree different liability.
  • It may not use that clause if the firm clearly cannot hold 10 cards, such as a three-person shop.
3 · Payment providers · US

How a fraud loss flows through your processor

  1. The buyer’s bank sends a dispute. Your processor debits the amount plus a dispute fee from your balance.
  2. You respond with evidence inside the window. Win, and the amount comes back. Lose, and you carry it.
  3. Your dispute ratio is watched. From 1 Apr 2026 Visa names a merchant once fraud reports plus disputes reach 1.5% of online card transactions with at least 1,500 events a month. Acquirers use a lower limit of about 0.5% (secondary), so your processor can act long before Visa does.
  4. Reserves, holds or closure follow. These come from your processor agreement, so read the clause (see The Small Print).
ProviderDispute fee per chargebackRead
Stripe (US)$15 when received, plus $15 when you counter, refunded if you win (stripe.com/pricing, primary)Stripe pricing page, Oct 2026
Shopify Payments (US)Not stated on Shopify’s Shopify chargebacks page, which links its fee page; secondary guides say $15, returned if you winThird-party guides
PayPal (card chargeback)$20.00PayPal fee page, primary
PayPal Braintree$15PayPal fee page, primary
Square (US)$0: “There are no fees for dispute management services for chargebacks”Square Help, primary. Square’s old paid chargeback protection ended in 2019 (history).
4 · Proof · US

What to keep, in four tiers

Built from the official guides and rules we could read. The tiers are our grouping.

Tier 1Minimum

Every dispute

  • Order or transaction ID, date, amount, authorization code.
  • Customer name, billing and shipping address, email.
  • For online card orders: the address and security-code check results.
  • For in-person card sales: proof of a chip or tap read.
  • Delivery proof with tracking.
Tier 2Good

Wins most fraud-coded disputes

  • The 3-D Secure result.
  • IP address, device ID and login, saved at checkout and kept 13 months.
  • Signed delivery to the billing address.
  • Wires: logs showing whether your bank’s security procedure (MFA, call-back) was followed.
  • Checks: positive pay exception records and a statement review you can date.
Tier 3Supportive

Helps, rarely decisive alone

  • Customer messages and account age.
  • Earlier undisputed orders from the same buyer.
  • Usage logs for digital goods.
  • The refund policy shown at checkout.
  • A police report and your IC3 complaint number.
Tier 4Nothing to claim

No one else carries it

  • A payment you sent to a fraudster after the money has left.
  • A counterfeit check you deposited and spent.
  • A business ACH debit noticed after the 2-banking-day window: the ACH return window has closed, so only your account agreement and statement-review rules are left (low odds).
  • A wire or check objection made past the one-year limit.
  • A dispute on a one-time buyer with no checkout data and no signed delivery.
5 · Tools · US

What fraud tools cost small online sellers

Listed by category, not ranked. No provider paid to be here and we have no affiliate ties. “Quote only” means no price is published; we have not guessed one. Read 25 Oct 2026.

ProviderPrice modelPriceWhat it coversWorth it or skipWhat we read
Stripe Radar LiteIncluded with standard card pricing$0None; screening onlyAlways on. Radar Standard moves to a per-transaction fee from 22 Jan 2027Stripe notice and pricing page (primary)
Stripe Radar StandardPer screened transactionFrom $0.05 per screened transaction or from $10 a month (stripe.com/radar/pricing, primary; the page lists “starting at $10 per month” and does not show the per-transaction price or the 22 Jan 2027 date)NoneWorth it if card testing or fraud is real; skip at low fraud and low volumeStripe support pages say the fee starts 22 Jan 2027 but give no amount; the figure comes from a copy of Stripe’s email (secondary)
Shopify ProtectFree for eligible orders; requires Shopify Payments and Shop Pay, and the order must show protection active$0Covers the order amount and chargeback fee on eligible fraud chargebacksAlways on if you qualify (US stores, tracking within 7 days, approved carrier); fraud chargebacks onlyShopify page (primary); detailed terms not read
PayPal Chargeback ProtectionPer transaction0.40%; Effortless tier 0.60%Unauthorized and item-not-received chargebacks, up to a monthly loss cap; the cap amount is not publishedWorth it if those losses exceed the fee; skip if your losses are “not as described” or friendly fraud. Enrolling turns off PayPal’s Fraud Protection toolPayPal fee and help pages (primary)
SquareBuilt in$0 dispute feeNo paid chargeback protection. Square covers Cash App Pay fraud disputes in full; processing fees are not refunded on a lost dispute (Square Help)Low dispute cost; you still lose the amount on a lost disputeSquare Help (primary)
SignifydShare of approved order valueQuote onlyFinancial guarantee up to a full liability shiftFor larger online sellers; likely above small-shop scaleSignifyd pricing page (primary)
ClearSalePer approved order, or a fixed feeQuote only; a pricing page says from $0.25 per approved order (unconfirmed)Optional guarantee on fraud chargebacks; conditions not statedWorth a quote for small online sellers who want a guaranteeClearSale page (primary, prices unconfirmed)
NoFraudMonthly tiers by volumeQuote only; a Shopify listing says $250 a month or 1% of revenue“100% financial guarantee” on passed orders; limits not statedHigh-fraud online verticals; costly at 1% to 1.5% of revenue if fraud is lowShopify listing (vendor) and NoFraud policy
RiskifiedShare of approved ordersQuote onlyCovers fraud chargebacks on approved ordersUsually above small-shop scaleRiskified page (primary)
SiftVolume contractQuote onlyNoneUsually above small-shop scaleSift terms (primary)
ChargeflowSuccess fee25% of recovered chargebacks; other plans’ prices conflict across its pagesRecovers disputes; does not prevent themIf you lack time to respond to winnable disputesChargeflow pages (primary but inconsistent)
5b · What customers say · US

What customers say about fraud tools

Opinion, not measurement. The samples are small, run by the vendors’ review pages, and lean toward larger merchants. We rank no provider from this. Read 25 Oct 2026.

ProviderWhere we readPraiseComplaints
SignifydG2 (347 reviews, 4.6); Capterra (64, 4.7; visible reviews 2017 to Jun 2024)Guarantee shifts the risk; less manual reviewFalse declines; claim exclusions; opaque decisions
RiskifiedG2 (240 reviews, 4.4); 10 read, Oct 2025 to Sep 2026Fewer manual reviews; setupFalse declines; commission on thin margins
NoFraudG2 (269 reviews, 4.7, no text); Capterra (1 review, 2020)Not enough text readNot enough text read
SiftG2 (617 reviews, 4.6, no text)Not enough text readNot enough text read
ClearSaleTrustpilot (183 reviews, 2.8; unverified, some look invited); one page readNot enough readDenied reimbursements; orders refused with no appeal
Stripe (whole platform, not Radar)Capterra (3,390 reviews, 4.6)Not Radar-specificFalse declines; fund holds with little warning; slow support
PatternPraise

Risk moves off you

  • Guarantees that take on the fraud chargeback.
  • Less manual review of orders.
  • Easy setup.
PatternComplaints

The fine print and the false decline

  • Good customers refused (false declines).
  • Guarantee exclusions, such as not-received claims, and short claim windows.
  • Decisions that are hard to see into, and slow support.
  • Fund holds with little warning.
No usable dataNot covered

PayPal, Square, Chargeflow, bank controls

  • We found only marketing pages from 2024 on.
  • Older threads (a 2022 Shopify post, a 2020 Square article) are anecdotes older than 2024 and are not used.
  • Regulator complaint data (CFPB) was not searched.

Review counts are what the sites show, not what we verified; where a site gave a count but no text we say so. Next step if you want more: an export of CFPB complaints and the Shopify App Store reviews.

6 · Banks · US

What bank-side controls cost

Positive pay and ACH blocks are the cheapest high-value controls. Fees come from each bank’s published schedule.

BankACH debit block or filterCheck positive paySchedule date
Chase (business)$0 a month$0 a month per account14 Jun 2026
Beneficial State Bank (California)$20 a month per account (block and filter)$20 a month per account1 Apr 2026
Western AllianceListed; fee not captured$25 a month per account2 Feb 2026
Banner BankNot listed$35 first account, $20 each more2026
Cambridge Savings Bank$10 a month (ACH block)In a $50 checking tier20 Jul 2026
SSFCU (credit union)Not listed$15 a month plus $15 setup14 Oct 2026
ConnectOne BankNot listed$25 per account; required unless you sign an opt-out2026
Amalgamated BankNot listed$45 a month; ACH positive pay $60; bundle $7530 Apr 2025

Against $123,005, the average business email compromise loss per FBI complaint in 2025, even the $75 bundle is small. ConnectOne requires positive pay unless the customer opts out in writing; we draw no conclusion from that. The Fraud Costs post’s calculator uses $25, $45 and $80 a month from two credit unions’ schedules; this table covers eight banks. The samples differ and are not combined. Multi-factor sign-in and email-security costs were not researched.

7 · Judgment · US

Worth it, or skip

GetAlmost everyone

Cheap and high value

  • ACH debit block or filter, and check positive pay, if you write checks or publish an account number.
  • A call-back rule for any change to bank details.
  • Multi-factor sign-in on email, bank and payment accounts.
  • Your processor’s free screening (Stripe Radar Lite, Shopify Protect if you qualify).
MaybeDepends on your fraud

Test against your own numbers

  • PayPal Chargeback Protection: worth it if unauthorized and not-received chargebacks exceed 0.40% of card volume.
  • A guarantee product: get a quote only if third-party card fraud is a real, repeated loss.
  • Commercial crime insurance with a social-engineering endorsement; sublimits are often $25,000 to $100,000 (broker pages; Insureon puts the average at $75 a month, own-customer data).
SkipUsually not for small firms

Above scale or off target

  • Enterprise fraud platforms (Sift, Riskified) at small volume.
  • Any guarantee that excludes “not as described” and business email compromise, your biggest exposure.
  • Paying for tools before turning on the free ones above.
8 · What to do

Seven steps, cheapest first

  1. Ask your bank for your ACH return window and your wire security procedure, in writing. Accept its strongest wire procedure.
  2. Turn on an ACH debit block and check positive pay. Reconcile daily so a 2-banking-day window is usable.
  3. Write a call-back rule and require two approvals on wires.
  4. Save IP, device ID and login on every online order and keep them 13 months.
  5. Use 3-D Secure on risky orders and watch your dispute ratio each month, aiming well under 0.5%.
  6. If you use Stripe, decide before 22 Jan 2027 whether Radar Standard’s per-transaction fee is worth it.
  7. If money went out to a fraudster: call your bank to recall it first, then file at ic3.gov. Speed matters: the FBI report says time is of the essence.
9 · Gaps

What this research did not cover

Open, not answered.

  • Network rule text (Visa, Mastercard) and Nacha’s own rulebook: we used guides and vendor summaries.
  • California’s check-fraud code text (§§3406, 4406) and UCC 4-214 for deposited checks.
  • Provider terms for payment-app and processor account takeover.
  • The amount of PayPal’s monthly loss cap.
  • Recovery rates by how fast you report; the FBI report does not give them.
  • Prices for multi-factor sign-in and email security.
  • Canada: its laws and bank rules were not researched.
Your next step

Ask your bank two questions today

Your ACH return window and your wire security procedure decide who pays. Get both in writing, then turn on a debit block and positive pay.

See the seven steps

Rules and fees change; check with your bank and processor before you act. Provider names are trademarks of their owners. This is general research, not legal advice. See Disclaimers above.