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SOC 2CC3 — Considers Fraud Risk

CC3.3

Considers Fraud Risk

SOC 2 · 2017 TSC (2022 Revised Points of Focus) · Last verified August 2026

Objective

Consider incentives, opportunities, attitudes, and methods for fraudulent reporting, asset misuse, corruption, or management override.

Points of focus

  • Evaluate fraud scenarios relevant to digital services and financial processes
  • Consider management override and unauthorized use of technology
  • Assess incentives and pressures that can change fraud exposure

Implementation notes

Threat-model refund abuse, promotional credits, support impersonation, insider data export, and management override; separate approvals and retain immutable logs for financially or operationally sensitive actions. Operationalize evaluate fraud scenarios relevant to digital services and financial processes in ticketing, IdP, or GRC workflows with named owners — not only in a static policy PDF. Retain fraud risk assessment with saas-specific scenarios with reviewer identity, population scope, dates, and remediation outcomes auditors can sample. A recurring failure mode is that the fraud assessment covers expense reports but ignores account credits and tenant impersonation Revisit after material architecture, vendor, data-flow, or leadership changes and document the decision.

Audit tip: Sample fraud risk assessment with saas-specific scenarios with dates and named reviewers. Be ready to walk through how you detect and correct: the fraud assessment covers expense reports but ignores account credits and tenant impersonation

Evidence auditors typically request:

  • Fraud risk assessment with SaaS-specific scenarios
  • Segregation-of-duties review for refunds, credits, and privileged actions
  • Monitoring reports for anomalous billing or administrative behavior

Common gaps

  • The fraud assessment covers expense reports but ignores account credits and tenant impersonation
  • One administrator can alter billing, issue refunds, and delete the audit trail

Cross-Framework Mapping

FrameworkRequirementImplementation note
SOC 2CC3.3This control
ISO 27001A.5.1, A.5.2Organizational controls provide related governance evidence but are not equivalent criteria.
HIPAA164.308(a)(1)HIPAA administrative safeguards overlap where ePHI systems are in scope.
GDPRArticle 32GDPR accountability and security duties can reuse evidence when personal data is in scope.

Primary sources

Frequently Asked Questions

Considers Fraud Risk applies to the systems and commitments in your Trust Services Criteria scope. Translate the requirement into concrete operating workflows — evaluate fraud scenarios relevant to digital services and financial processes — with evidence stored where auditors and customers can sample it.

Lead with fraud risk assessment with saas-specific scenarios and pair it with segregation-of-duties review for refunds, credits, and privileged actions. Samples should show who performed the control, when, against which population, and what changed as a result.

Teams often fail because the fraud assessment covers expense reports but ignores account credits and tenant impersonation Close the loop with dated operating records and test the control on a realistic production path.

Control operation can often be shared across SOC 2, ISO 27001, GDPR, and HIPAA — but each framework uses different vocabulary and accountability. Maintain an explicit crosswalk rather than assuming equivalence.

Review at least annually and after material product, vendor, or data-flow changes. High-risk or privileged paths may need quarterly sampling even when the criterion does not prescribe a cadence.

Framework versions referenced in this page:

  • SOC 2 — 2017 TSC (2022 Revised Points of Focus)

Last verified: August 2026 · Primary sources linked above