Q: My client has asked our firm to initiate wire transfers. What risks are associated with agreeing to initiate wire transfers and what protocols should our firm consider?
A: CPA firms continue to be at high risk of social engineering attempts due to the type of information firms gather and store. If the firm and/or a client’s email is hacked, a wire transfer request could come from a fraudster/hacker. As fraudulent wire transfers frequently cause large dollar losses, firms need to be hypervigilant in their efforts to protect the firm and clients against wire transfer fraud.
If the fraudster controls the client’s and the firm’s email, commonly referred to as a “man in the middle” attack, the fraudulent request may mimic previous legitimate requests, which can make it very difficult for a firm to identify the request as illegitimate. When the fraud is discovered after the transfer, the funds are usually not recoverable. Domestic banks are often not helpful in preventing fraudulent transfers, as laws tend to limit their risk exposure and enable them to deny responsibility.
Given the increasingly sophisticated phishing and spoofing scams, CAMICO strongly encourages firms to have written protocols in place with clients who need such services that outline the protocols to be followed when executing wire transfer requests. Certainly, best practice would be to verbally verify the authenticity of all wire transfer requests that are received by the firm via email correspondence, but for those clients who may wish to limit the requirement for your firm to verbally verify each wire transfer, the client should specify in writing those limits (e.g., by dollar threshold, business purpose, etc.) as well as acknowledge their responsibility for the added risks associated with this limited verbal verification process. We recommend including as part of the verification process specific questions to which only your client would know the answer.