POLICY BRIEF  |  FRAUD INFRASTRUCTURE & ELDER PROTECTION

How Bank Outsourcing Creates the Infrastructure Scammers Exploit

Sherry Spurlin | Spurlin Digital Solutions | Licensed Mortgage Professional, 30+ Years Financial Services nmls#204917

THE PROBLEM

When Americans open a bank account, they believe their financial data is protected by the institution they trust. That assumption is increasingly false.

Major banks are quietly outsourcing core operations — including direct access to customer account systems — to third-party contractors operating in regions with documented fraud activity. No federal law requires disclosure of where these contractors are located. No law mandates real-time monitoring of their access. No whistleblower protection exists for the overseas employees who witness abuse.

$3.4B

Elder fraud losses (2023) 3-5x higher unreported

69,000+

Victims in Coinbase/TaskUs breach alone

784,000

Accenture employees with access to bank systems

THE DOCUMENTED CASE: COINBASE/TASKUS BREACH (2024 - 2025)

    A TaskUs contractor in Indore, India photographed and sold 200 customer records per day — names, SSNs, balances, government IDs — for $200 per image.

    Over 69,000 Coinbase customers were affected. Criminals impersonated Coinbase staff using the stolen data. Multiple victims lost their entire retirement savings.

    TaskUs concealed the breach for months, filed regulatory documents claiming no material breach, and simultaneously negotiated a $1.6 billion acquisition.

    Victims had no notification for 7 months — no law required it. No monitoring caught it. No whistleblower reported it safely. 

EXAMPLE: Accenture — Truist Bank's primary outsourcing partner since 2017 — employs 784,000 people globally including 80,000 in Bonifacio Global City, Philippines, the same area where the U.S. Treasury has sanctioned scam compound operations. Truist forced laid-off employees to become Accenture contractors in 2024. Customers were never informed.

THE REGULATORY GAP

Current law does not require financial institutions or their contractors to:

    Disclose the geographic location of personnel with access to customer account systems

    Implement real-time behavioral monitoring at outsourced data access points

    Provide a protected reporting channel for overseas contractor employees

GLBA, OCC Third-Party Risk Guidance (2023-17), and Dodd-Frank all address adjacent issues — none close these specific gaps.

 

THREE TARGETED ASKS

1.

Geographic Disclosure

Require banks to disclose in annual reports where third-party contractors with account access are located. (Amend GLBA §501)

2.

Real-Time Monitoring

Mandate behavioral monitoring at all outsourced access points — key logging, anomaly detection, escalation protocols. (Joint OCC/CFPB rulemaking)

3.

Whistleblower Pathway

Create a protected, anonymous reporting channel for outsourced contractor employees who observe data misuse. (Amend Dodd-Frank §922)

Sherry Spurlin  |  Spurlin Digital Solutions  |  Market 4 Social | Author: Digital Predators, HiJacked: The Digital Invasion, The Scammer's Playbook  |  @sherry_spurlin (TikTok, 28K+ followers)