INTERNATIONAL JOURNAL OF RESEARCH AND SCIENTIFIC INNOVATION (IJRSI)  
ISSN No. 2321-2705 | DOI: 10.51244/IJRSI |Volume XII Issue XI November 2025  
Cyber Fraud in Bangladesh’s Digital Financial Ecosystem: Tracing  
Responsibility across Banks, Mobile Financial Services and End  
Users  
Niloy Saha1, Samia Kashem Juhi2, MD Nizam Uddin3, MD Sezadur Rahman4*  
1Daffodil International University  
2Shanto-Mariam University of Creative Technology  
3Nanjing University of Posts and Telecommunications  
4University of Eastern Finland  
DOI: https://dx.doi.org/10.51244/IJRSI.2025.12110086  
Received: 19 November 2025; Accepted: 28 November 2025; Published: 09 December 2025  
ABSTRACT  
Bangladesh’s rapidly expanding digital financial ecosystem—driven by mobile financial services (MFS), online  
banking and fintech innovation—has transformed economic participation and inclusion. Yet, this digital boom  
has also triggered an alarming rise in cyber fraud, exposing structural weaknesses in how responsibility is shared  
across institutions and users. Using the 2025 Standard Chartered Bank (SCB) OTP scam as a focal case, this  
paper examines cyber fraud not as an isolated technical or user-level issue, but as a systemic failure within a  
distributed network of accountability. It analyzes how gaps in authentication protocols, inadequate coordination  
between banks and telecom operators, and insufficient user awareness collectively enable exploitation. Drawing  
on publicly available data, regulatory frameworks and incident reports, the study proposes a multi-actor  
responsibility model to map how trust and accountability should be shared among banks, MFS providers,  
regulators and end users. The findings highlight the urgent need for integrated cyber governance—one that  
bridges institutional silos, enforces shared liability, and builds digital resilience across Bangladesh’s evolving  
financial landscape.  
Index Terms: Cyber fraud, digital financial ecosystem, multi- actor accountability, systemic vulnerabilities,  
OTP scam, user-centered security.  
INTRODUCTION  
Within the last decade Bangladesh has become as one of the fastest growing digital economy in South Asia. With  
the launch of it’s first Mobile Financial Services (MFS) in 2011, the country has witnessed an extraordinary  
digital finance boom, by a decade exceeding 100 million registered users[1]. Bangladeshi MFS platforms such  
as bKash, Nagad and Rocket have become integral to everyday life—powering over BDT 1.4 trillion in domestic  
remittances in 2022 alone [2]. More than 40% of small and medium size enterprises (SMEs) now distribute  
salary and wage through MFS platforms. This illustrates how deeplythese platforms are woven into Bangladesh’s  
national economy[3].  
This rapid digital transformation has also drawn cyber criminal’s attention. Among millions of these users,  
many are elderly or with limited digital literacy that enter the digital financial system. They often become prime  
targets for scams exploiting through social engineering, SIM swapping and one- time-password (OTP)  
interception[4]. The most recent 2025 Standard Chartered Bank (SCB) OTP scam, which affected hundreds of  
users through coordinated network manipulation, brings the systemic vulnerabilities within this ecosystem into  
perspective. Despite continuous improvements in encryption, authentication and fraud detection, incidents  
continue to rise. These coordinated attacks breaks user trust and exposes the weaknesses that lies in institutional  
coordination.  
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Figure 1. Distribution of reported cyber incidents by attack types [14]  
Most existing studies and policy responses frame cyber fraud either as a technological failure (insufficient  
encryption, weak KYC systems) or as a user-level mistake (lack of awareness, negligence). This binary framing  
overlooks the inter- dependent nature of Bangladesh’s digital-finance infrastructure where banks, MFS providers,  
telecom operators, regulators and users operate within a shared trust architecture. Failures in one node across  
authentication protocols, network security or consumer education—can cascade across the entire system.  
This paper argues that cyber fraud in Bangladesh’s digital financial ecosystem is fundamentally a systemic  
failure of distributed responsibility. It examines how fragmented account- ability among banks, telecom  
operators, regulators and users has enabled financial exploitation. The paper introduces a multi-actor  
responsibility model to clarify the shared obligations of these stakeholders and offers policy recommendations  
for building a more resilient, accountable, and user-secure digital finance environment.  
Related Work  
The popularization of digital financial services has been a defining feature of emerging economies over the past  
decade, re- shaping the accessibility, speed and scale of financial transactions. In Bangladesh, Mobile Financial  
Services (MFS) and on- line banking platforms have similarly transformed the financial landscape, enabling  
millions to participate in formal finance [5]. The global literature agrees that such rapid digitization often  
introduces new vulnerabilities. Scholars have documented how fintech expansion, when coupled with insufficient  
cybersecurity governance, increases susceptibility to fraud, phishing and ac- count takeovers [6].  
Several studies examine the behavioral aspects of cyber fraud. A study done on sub-Saharan Africa note that  
low dig- ital literacy, particularly among elderly or rural users significantly increases exposure to scams [7].  
Researches have ob- served Similar pattern in Bangladesh’s MFS adoption where users with limited knowledge  
of authentication protocols are disproportionately affected by OTP interception and SIM swap- ping attacks [8].  
These insights underscore the importance of understanding fraud not merely as a technical failure but as a human-  
technology interaction problem.  
The institutional perspective of financial cyber security is equally well documented. Research shows that  
fragmented governance and unclear lines of accountability exacerbate fraud risks. For example, in the Indian and  
Kenyan contexts, overlap- ping regulatory mandates between central banks, telecom regulators and MFS  
providers often lead to delayed responses and inconsistent enforcement [9] [10]. In Bangladesh, the literature  
indicates a similar challenge: regulatory oversight is distributed among the Bangladesh Bank, the Bangladesh  
Telecommunication Regulatory Commission (BTRC) and the Digital Security Agency. While each institution  
has formal responsibilities, there is scant evidence of coordinated, multi-stakeholder frame- works to address  
systemic vulnerabilities.  
Several studies focus on technical fraud-mitigation strategies, including multi-factor authentication, transaction  
monitoring and machine learning–based anomaly detection. Research consistently highlights their limited  
effectiveness when institutional coordination is weak or user awareness is low [11]. Cybersecurity failures often  
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occur not because of a single actor’s negligence but due to misalignment among interdependent ac- tors. Despite  
its relevance Bangladesh’s digital-finance sector still tends to treat cyber fraud as an issue of either individual or  
organizational failure. High-profile fraud cases, including ATM heists, phishing attacks and OTP scams, are often  
cited in re- ports and media, but academic literature rarely provides system- level analyses of these incidents. The  
2025 Standard Chartered  
Bank (SCB) OTP scam exemplifies the kind of interdependent vulnerability that distributed-responsibility  
frameworks can illuminate. Such failures involve banks, telecom operators and regulatory oversight,  
compounded by user susceptibility.  
In sum, the existing literature provides robust evidence of the growth of digital finance, patterns of cyber fraud  
and the socio-technical vulnerabilities of users. It also demonstrates that fragmented governance and insufficient  
coordination among institutions significantly exacerbate these risks. However, there is a clear gap in applying a  
systemic, distributed- responsibility perspective to Bangladesh’s digital financial ecosystem. This gap justifies  
the present study, which integrates behavioral, technical, and institutional analyses to pro- pose a framework for  
multi-actor accountability in preventing and mitigating cyber fraud.  
METHODOLOGY  
This study employs a qualitative and interpretive approach to investigate how cyber fraud emerges from systemic  
weaknesses across interdependent actors in Bangladesh’s digital financial ecosystem. The SCB 2025 OTP scam  
was chosen as a focal case because it revealed cross-sector vulnerabilities and institutional fragmentation among  
banks, mobile financial service (MFS) providers, telecom operators, and regulators.  
Data were drawn from secondary sources, including verified news articles, regulatory communications, and user  
testimonies. The incident first surfaced on social media platforms such as LinkedIn and Facebook, where victims  
shared their experiences of unauthorized withdrawals and their struggles to receive assistance from banks and  
telecom operators. These early posts were later substantiated by mainstream news coverage that provided detailed  
accounts and official responses.  
The collected materials were analyzed thematically, identifying how technical, institutional, and user-level  
vulnerabilities interacted to enable systemic failure. While the study does not rely on confidential banking data  
or forensic audits, this interpretive approach captures the multi-actor dynamics that under- lie cyber fraud in  
Bangladesh’s fintech ecosystem, forming the analytical basis for the subsequent case study.  
CASE STUDY: THE SCB 2025 OTP SCAM  
Background of the SCB OTP Scam  
The 2025 Standard Chartered Bank (SCB) OTP scam, though not the most shocking indecent, emerged as one  
of the most talked cyber fraud incidents in Bangladesh’s recent digital- finance history. Over a period of several  
weeks, hundreds of customers reported unauthorized withdrawals from their ac- counts, facilitated through  
interception of one-time passwords (OTPs) intended for transaction verification [12]. The attackers supposedly  
employed coordinated social engineering campaigns, phishing calls and SIM swap techniques to gain control  
over victims’ mobile numbers. This incident not onlyhighlighted technical vulnerabilities but also underscored  
weaknesses in institutional coordination and regulatory oversight within the country’s rapidly digitizing financial  
sector.  
Technical and Institutional Vulnerabilities  
From a technical perspective, the scam exploited multiple points of failure. SIM swapping allowed attackers to  
reroute OTPs, undermining two-factor authentication. In several cases, SCB’s transaction-monitoring protocols  
failed to flag unusual patterns, partly due to reliance on assumptions that mobile numbers were secure under user  
control. At the institutional level, the case revealed fragmented responsibility among banks, MFS providers and  
telecom operators. Banks depended on telecom operators for secure communication channels, while telecom  
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operators operated under the guidance of the Bangladesh Telecommunication Regulatory Commission (BTRC).  
This protocol lacked mechanisms for proactive coordination with financial institutions. Regulatory oversight by  
the Bangladesh Bank and the Digital Security Agency was largely reactive, addressing fraud after occurrence  
rather than providing preventive monitoring. The systemic weaknesses were compounded even after the fraud  
was reported. Instead of coordinated action to halt on- going attacks and trace stolen funds, stakeholders engaged  
in a cycle of blame-shifting. This post-incident inertia underscores a critical absence of a clear framework  
delineating who is responsible for such incidents.  
User-Level Vulnerabilities  
Several news reports indicates that victims of the SCB OTP scam included not only elderly individuals or users  
with limited technological literacy—but also well-educated and technologically aware users. Interviews and  
reports from affected customers revealed that even users who understood digital security concepts were deceived  
by sophisticated social engineering tactics, mostly calls or messages identical to be from bank officials or  
regulators [13]. These interactions persuaded users to disclose sensitive information, including OTPs, creating  
critical points of failure in the human-technology interaction chain.  
This pattern demonstrates that user-level vulnerabilities were not merely a result of ignorance or lack of  
awareness. Instead, they functioned as enablers within a system already weakened by technical and institutional  
gaps. Elderly users with limited tech experience were naturally more susceptible, but even informed users  
became targets when attackers exploited trust, authority and urgency.  
System-Level Analysis  
The SCB OTP scam illustrates how interdependent actors interact to propagate risk. Combination of technical,  
institutional and human vulnerabilities combined to exploit security gaps, institutional fragmentation delayed  
responses and user susceptibility allowed social engineering to be succeed. This multi- layered failure  
demonstrates that cyber fraud in Bangladesh is a systemic problem, not solely a result of individual or  
organizational errors. The lack of a coordinated framework for account- ability meant no single actor could fully  
prevent the frauds in question.  
Key Insights  
Analysis of the SCB OTP scam yields several critical in- sights. First, cyber security failures are rarely isolated;  
they emerge from interactions among multiple actors. Second, fragmented governance and unclear lines of  
accountability create exploitable gaps that can undermine robust technical systems. Third, user vulnerability  
remains a decisive factor, but it is amplified by institutional and technical shortcomings rather than acting alone.  
These patterns underscore the necessity of a multi-actor responsibility approach, which recognizes that banks,  
MFS providers, telecom operators, regulators and users must all share accountability to prevent systemic failures.  
Systemic Vulnerabilities Across  
Actors  
The SCB 2025 incident revealed not a failure of one institution, but a collapse of coordination across the digital-  
finance chain. Each actor—banks, mobile-financial-service providers, telecom operators, and regulators—  
fulfilled its own compliance obligations, yet the interfaces between them remained unguarded. Responsibility was  
treated as a bounded checklist rather than a shared continuum. When the scam exploited those seams, every  
institution could plausibly claim it had “followed protocol,” leaving victims stranded in a gray zone of  
accountability.  
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Figure 2. System map of Bangladesh’s digital-finance transaction flow showing actors, core data paths and  
exploited weak points (red X) identified in the SCB 2025 OTP scam.  
Bangladesh’s regulatory architecture reinforces this diffusion of responsibility. The Bangladesh Bank oversees  
banks and MFS platforms; the BTRC monitors telecoms; CIRT handles cyber incidents; yet no body owns the  
intersections where fraud actually occurs. Reporting flows are fragmented, cross- institutional data sharing is  
minimal, and there is no unified mechanism for rapid joint response. The result is a governance vacuum: a  
system technically dense but institutionally porous. This framework extends existing cybersecurity governance  
models by emphasizing accountability as an emergent property of multi-actor interaction rather than isolated  
institutional duty.  
This diffusion also shapes public discourse. Blame routinely shifts downward to users—often portrayed as  
careless for sharing OTPs—while the systemic design that allows criminals to impersonate officials or reroute  
messages goes unchallenged. Such framing externalizes risk, erodes digital-trust, and discourages the very  
adoption the financial-inclusion agenda depends on.  
The lesson is structural: cybersecurity in financial ecosystems cannot be managed within organizational silos.  
Responsibility must extend across networks, covering not only what each actor controls but also how their  
systems interact. Until accountability becomes a shared architecture rather than an after-the-fact blame game,  
the vulnerabilities exposed by the SCB scam will persist—reproduced in new forms, across the same fault lines.  
Toward a Multi-Actor Accountability Framework  
The findings from the SCB OTP scam demonstrate that cyber fraud in Bangladesh’s digital-finance sector is not  
simply the result of technical lapses or user error but a manifestation of systemic disconnection between  
interdependent actors. Banks, MFS providers, telecom operators and regulators operate within overlapping but  
weakly coordinated domains, leaving critical gaps where accountability diffuses. To address this fragmentation,  
this study proposes a Multi-Actor Accountability Framework (MAAF) —a systemic model that redefines  
cyber security responsibility as a shared governance function rather than an isolated institutional task. The  
MAAF envisions a connected ecosystem in which information flow, oversight, and risk management are  
integrated across technical, institutional, and human levels.  
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Core Principles of the Framework  
The framework is grounded on four interlocking principles designed to promote resilience and transparency:  
Shared Accountability — Every actor in the digital-finance chain carries both individual and collective  
responsibility for security outcomes. The framework rejects the prevalent culture of blame-shifting and instead  
emphasizes co-ownership of risks and responses.  
Data Interoperability and Transparency — Cross-institutional information exchange must be standardized.  
Banks, MFS providers and telecoms should operate through interoperable platforms where fraud alerts, anomaly  
reports and risk signals circulate in real time under regulatory supervision.  
User - Centric Protection — End-users represent the most vulnerable link in the ecosystem. The framework  
prioritizes user safety through default safeguards—secure transaction notifications, verified communication  
identifiers and digital-literacy initiatives—without assuming high technical literacy.  
Preventive Oversight — Regulators must transition from reactive enforcement to proactive monitoring. Rather  
than responding post-incident, oversight bodies should deploy early-warning mechanisms, continuous risk audits,  
and coordinated incident- response protocols.  
Institutional Roles and Coordination  
Under the MAAF, distinct institutional roles are defined but integrated through continuous coordination:  
•
•
•
Banks and MFS Providers serve as the first line of detection and reporting. They maintain joint fraud-  
monitoring systems, shared anomaly-detection databases, and unified customer-notification standards.  
Telecom Operators provide the technical backbone for secure authentication, ensuring verified SMS routing  
and fraud-flagging protocols for suspicious SIM activities.  
Regulators—specifically the Bangladesh Bank, the BTRC, and the Digital Security Agency—form a Joint  
Cyber- Finance Task force, responsible for centralizing intelligence, coordinating inter-agency response, and  
enforcing compliance with shared cybersecurity standards.  
•
End-Users are incorporated as active stakeholders through structured awareness programs and secure reporting  
channels that enable direct communication with banks and regulators without bureaucratic delay.  
This configuration ensures that information does not stagnate within institutional silos and that responsibilities  
are explicit, traceable, and enforceable.  
Implementation Pathways  
A phased implementation strategy is essential to translate the MAAF from principle to practice:  
Short-Term (0–1 year): Establish a unified reporting protocol for cyber fraud incidents, accessible to banks,  
MFS providers, and telecom operators. Launch an encrypted communication channel supervised by the  
Bangladesh Bank for real-time alert sharing.  
Mid-Term (1–3 years): Develop a National Digital-Finance Fraud Intelligence Platform (NDFFIP) integrating  
transaction risk data, SIM-swap alerts, and phishing trend analytics.  
Long-Term (3–5 years): Institutionalize cross-sector account- ability clauses in financial and  
telecommunication regulations. Conduct annual joint security audits and publish transparent national reports on  
cyber-fraud trends and response effectiveness.  
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Figure 3. Conceptual schematic of the Multi-Actor Accountability Framework (MAAF), integrating technical,  
institutional and human responsibility layers.  
Expected Impact  
The proposed Multi-Actor Accountability Framework fundamentally reorients the governance of digital-finance  
cybersecurity from isolated reaction to collective prevention. By clarifying roles, promoting data transparency,  
and embedding user protection into system design, the framework addresses the accountability vacuum that has  
long undermined resilience. Its implementation would likely produce faster incident containment, improved  
trust between stakeholders, and measurable public confidence in digital financial platforms. Ultimately, the  
MAAF offers a structured pathway toward a coordinated, responsibility sharing ecosystem capable of reducing  
systemic vulnerability in Bangladesh’s digital financial services.  
Insights and Future Research  
Directions  
Analysis across Bangladesh’s digital-finance ecosystem reveals recurring patterns that go beyond isolated  
technical failures or user errors. Fraud frequently emerges at the intersections of multiple actors—banks, MFS  
providers, telecom operators, regulators, and end users—highlighting that vulnerabilities are systemic rather than  
incidental. Even tech-savvy users, including educated and elderly individuals, are susceptible to sophisticated  
social engineering, demonstrating that human behavior cannot be treated as uniformly predictable. Fragmented  
regulatory oversight further compounds this risk, delaying detection and response and leaving gaps that malicious  
actors exploit. Together, these patterns illustrate that cyber fraud arises from complex interactions within the  
ecosystem, rather than from any single point of failure.  
The sector-wide implications are significant. Users of all demographics face exposure to fraud, challenging  
assumptions that only low-literacy or elderly populations are at risk. Financial institutions and telecom operators  
must recognize their operational inter dependencies and design processes with cross- sector vulnerabilities in  
mind. Regulators, similarly, must adopt a system-level perspective, prioritizing coordination and intelligence-  
sharing rather than reactive enforcement. Under- standing these patterns shifts the focus from managing  
individual incidents to anticipating systemic weaknesses and designing measures that enhance resilience across  
the ecosystem.  
Despite growing awareness of these challenges, substantial research gaps remain. Quantitative modeling of fraud  
propagation could clarify how vulnerabilities interact across inter- dependent actors, while studies of human-  
technology interaction would help identify why even informed users are deceived. Empirical evaluation of cross-  
institutional coordination mechanisms and integrated fraud-detection systems would provide evidence for  
scalable, sector-wide interventions. Addressing these gaps is essential for developing practical strategies to  
safeguard users, institutions, and regulators alike, and for building a more resilient digital-finance ecosystem in  
Bangladesh.  
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CONCLUSION  
In conclusion, cyber fraud in Bangladesh is fundamentally a system-level problem that arises from the interplay  
oftechnical, institutional, and human factors. Byrecognizingpatternsofvulnerability across the entire ecosystem,  
rather than focusing on individual cases, researchers, policymakers, and industry actors can develop strategies  
that strengthen resilience, improve trust, and support sustainable growth of digital financial services. Future  
research integrating behavioral, technical, and institutional perspectives will be critical to achieving these goals.  
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