After reviewing penetration tests for Money Services Businesses over the years both as a security practitioner and alongside banking and insurance reviewers—one pattern becomes very clear:
Most MSBs misunderstand what penetration testing is supposed to prove.
Banks and insurers are not looking for technical virtuosity. They are not impressed by long vulnerability lists, dense scanner output, or overly technical narratives that never connect back to financial risk. What they are looking for is far simpler and far more demanding.
They want assurance that your organization understands how it could realistically be abused, and that leadership is capable of managing that risk.
Penetration Testing as a Proxy for Trust
For MSBs, penetration testing serves a different purpose than it does for most commercial organizations.
Because MSBs directly handle funds, payment flows, and sensitive transactional data, external reviewers use penetration testing as a proxy for broader questions: Can this organization be trusted with financial access? Does it understand how fraud actually occurs? Are security controls validated in practice, not just described in policy?
Regulators such as the Financial Crimes Enforcement Network, along with correspondent banks and cyber insurers, are less concerned with whether vulnerabilities exist—because they assume they do. What they want to know is whether those vulnerabilities could be combined in ways that lead to unauthorized fund movement, data exposure, or systemic abuse.
Why Automated Reports Rarely Satisfy Reviewers
Automated testing plays an important role in any MSB security program, but under scrutiny it is almost never sufficient on its own.
From a reviewer’s perspective, automated reports tend to read as operational artifacts rather than assurance evidence. They show that scanning occurred, but they do not demonstrate that someone actually evaluated how an attacker would move through the environment. They rarely address transaction logic, identity abuse, or privilege escalation in a way that reflects real-world financial crime scenarios.
As a result, banks and insurers typically treat automated pentest output as supporting documentation useful, but not decisive.
What Reviewers Pay Attention to First: Scope and Realism
The first thing a serious reviewer looks at in a penetration test report is not the findings section. It is the scope.
For a Money Services Business, scope communicates intent. A test that meaningfully includes identity systems, administrative access paths, customer-facing applications, APIs, and the infrastructure that supports transaction processing signals that the organization understands where its real risk lives.
Conversely, a narrowly scoped test that focuses only on external perimeter exposure often raises more questions than it answers. Reviewers are quick to notice when testing avoids the systems that would actually matter in a financial incident.
The Difference Between Vulnerabilities and Abuse Paths
Experienced reviewers read penetration test reports looking for evidence of thinking, not scanning.
They want to see whether the tester explored how small issues could be chained together. They want to understand whether authentication could be bypassed, whether privileges could be escalated, and whether lateral movement could reach systems that control money or sensitive records.
This is where human-led testing carries disproportionate weight. A well-written manual penetration test doesn’t just state that something is misconfigured it explains how that misconfiguration could be abused in context. That narrative is far more valuable to a bank or insurer than a list of medium- or high-severity findings.
Business Impact Is Not Optional for MSBs
One of the most common weaknesses in MSB penetration test reports is the absence of business translation.
Banks and insurers do not want to infer impact. They expect it to be clearly stated. They want to know whether customer funds could be accessed, whether transaction integrity could be compromised, or whether regulatory obligations around data protection and financial controls were placed at risk.
When a report frames findings in terms of operational and financial exposure, it signals maturity. It tells reviewers that the organization understands its own risk profile and can communicate it internally at an executive level.
Governance Matters as Much as Detection
Another area where reviewers focus is what happens after the test.
A penetration test that identifies issues but shows no evidence of prioritization, remediation planning, or executive awareness often weakens confidence rather than strengthening it. Perfection is not expected. What is expected is governance.
Banks and insurers want to see that findings were reviewed, that material risks were addressed or consciously accepted, and that there is accountability for outcomes. Even unresolved issues can be acceptable if they are documented and managed appropriately.
Why Human Judgment Still Carries Weight
Ultimately, what differentiates strong penetration testing evidence for MSBs is the presence of professional judgment.
Human-led testing demonstrates that someone evaluated edge cases, adjusted tactics, and made decisions based on observed behavior rather than predefined signatures. That mirrors how financially motivated attackers actually operate.
To reviewers, this matters because it shows that the organization is not relying solely on tools to think for it.
The Real Standard MSBs Are Being Held To
Banks and insurers are not asking MSBs to be breach-proof. They are asking them to be credible.
Credible means understanding how your systems could be abused, having tested those assumptions under realistic conditions, and being able to explain the results in language that reflects financial and regulatory risk.
Penetration testing evidence that accomplishes that does more than satisfy a requirement—it strengthens trust relationships that MSBs depend on to operate.
Final Thought
For Money Services Businesses, penetration testing is not about proving technical excellence. It is about demonstrating institutional maturity.
When banks and insurers review your penetration testing evidence, they are asking a simple question: Does this organization truly understand its risk, and is it capable of managing it?
A well-executed, human-led penetration test answers that question far more convincingly than any automated report ever could.
