10 Steps RIA Firms Can Take to Reduce Wire Fraud Risk

1. Establish policies and procedures that directly address the risk of wire fraud as
part of the firm’s broader compliance policies and procedures.

2. Always verbally confirm all client wire requests and consider establishing a
“secret word” with each individual client to confirm the request.

3. Educate clients on information security best practices by providing cyber

security education and training to clients and their family members.

4. Educate clients on the firm’s wire confirmation procedures at the start of a

new client relationship to properly set expectations and to explain the policy and
rationale in detail.

5. All firm principals and staff members need to receive regular training on how
to identify potential wire fraud and the firm’s policies and procedures designed to
mitigate such risk.

6. Firm principals need to instruct all staff members that firm policy related to
wire transfers must be followed at all times even if it may result in near term client
dissatisfaction.

7. Educate all staff on how to identify “phishing” or fake emails coming from clients
which includes exercising a high attention to detail when reviewing client emails.

8. Test wire fraud policies and procedures by mimicking these types of incidents
to gauge how prepared the firm is and as opportunities to update relevant policies
and procedures.

9. Develop an incident response plan to directly address attempted or actual wire

fraud episodes which includes immediately informing designated firm principal(s).

10. Strongly consider purchasing the proper errors and omission insurance,
cybersecurity insurance, and/or fidelity or financial institution bond(s) to ensure
sufficient risk protection.

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