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Fraud patternsSettelmayer Global Legal3 min read

CEO fraud: how forged instructions reach the accounts department

CEO fraud does not work through technology, but through hierarchy and time pressure. That is precisely why technical protective measures alone fall short.

In CEO fraud — also known as business e-mail compromise — the accounts department receives a payment instruction that appears to come from management. It is urgent, confidential and plausible. The weak point is not the technology, but the expectation that an instruction from above will be followed without further enquiry.

Preparation with public information

The preparation uses what is in any case accessible: the naming scheme of e-mail addresses, responsibilities from the legal notice, commercial-register data, press releases about acquisitions, and absences from social networks. The timing is chosen deliberately — Friday afternoon, holiday periods, ongoing transactions.

Technically, a similar domain or a manipulated reply field is often enough. In more serious cases a mailbox is actually compromised; genuine conversations are then written into, which makes detection considerably more difficult.

Why approval processes decide

Most losses arise not because rules are missing, but because they can be circumvented in the exceptional case. A four-eyes principle that is dropped in the event of urgency does not protect precisely when it is needed. What is effective are rules without an exception: a call-back to a stored number for every change of bank details, regardless of amount and sender.

For the assessment of a loss event it is additionally relevant whether these processes were documented. Both for insurance cover and for possible claims, what matters is what was provided for internally and whether it was complied with.

After a payment has been made

Time-critical are the recall via your own bank and informing the receiving bank. In parallel, the e-mail headers should be exported in the original, access to the affected mailbox examined and the internal approval chain documented. Depending on the facts, a criminal complaint, information claims against banks and a review of insurance cover may come into consideration.

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General information. The legal assessment depends on the circumstances of each case.

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  • General information. The legal assessment depends on the circumstances of each case.

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