Page 56 - 《期货和衍生品行业监管动态》（2022年合集）

期货和衍生品行业监管动态

 issuing fund transfer instructions, usually to bank accounts under their
control at multiple receiving banks, some of which are located overseas, to

maximise their chances of receiving the funds.

In most cases where fraudsters succeeded, the identities of the email senders

were either not verified or were checked improperly. For example, an LC staff simply

called the phone number provided by the fraudster and followed the confirmation to

process the fund transfer instructions.

In addition, many red flags were ignored by the LCs. In one incident, fund

transfers were rejected or withheld by some banks. Instead of promptly investigating

the irregularities, the LC proceeded to act on the transfer instructions to other banks.

Eventually, a number of fund transfers were effected, inflicting financial losses on the

LC.

The SFC’s expectations

The SFC expects LCs to have internal control procedures and financial and

operational capabilities which can be reasonably expected to protect their operations

and clients from financial losses arising from theft, fraud and other dishonest acts,

professional misconduct or omissions. LCs are reminded to vigilantly monitor and

effectively manage BEC risks, especially at times when remote working arrangements

are commonplace.

Control mechanisms

LCs should establish effective policies and procedures to provide guidance to

their staff for managing BEC risks. In addition, LCs should strengthen internal

controls in the following aspects:

Client contact information

 Establish true identities of the clients and their authorised representatives
during the account opening process.

 Periodically review and update the official records to keep client contact

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