How to Build an Incident Response Plan for Wire Fraud Recovery

Key Takeaways:

• Implementing a proactive Incident Response Plan is essential for businesses to quickly and effectively address cyber threats like wire fraud.
• An effective IRP should have clear guidelines for contacting financial institutions and law enforcement to facilitate wire recalls and freeze funds, alongside immediate IT evaluations to assess and contain the breach.
• This involves pre-drafting messaging for various incident profiles, ensuring rapid response without compromising legal liability, and regularly updating the IRP to align with new technologies, policy changes, and potential threats.

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The CertifID recovery team are the first responders on the line when business partners experience wire fraud. They have firsthand insight into daily incidents, including cyber attacks, data breaches, disbursement fraud, financial losses, and successful recovery. What is their top recommendation based on all the incident data over the years? Protect your business with a proactive Incident Response Plan (IRP). 

“We’re in the business of prevention, but in the current cyber threat landscape, it’s a matter of when, not if, an attack will impact your company,” says Tim Yokom, Manager of Customer Support.

Our 2024 State of Wire Fraud Report shows that technical innovation is outpacing cyber security measures, resulting in more frequent and costly incidents of wire fraud than ever before, despite growing awareness and prevention strategies across industries. Instant payment technology allows fraudsters to move money into untraceable accounts before it can be discovered missing, and AI enables fraudsters to create such convincing deepfakes that the most sophisticated employees can’t spot impersonators. In cases like these, prevention strategies aren’t sufficient.

That’s where a proactive Incident Response Plan comes into play. If companies take action in the first 24-48 hours, they can typically recover funds, data, and even customer loyalty, but time is of the essence. Building a plan in advance empowers your team to move quickly and get back in business, even when emotions are running high in the aftermath of a crisis. Let our IRP template do the heavy lifting. Use this guide as a checklist for building an airtight recovery plan.

Define the scope of your incident response plan

Every industry is vulnerable to unique threats. In cases of wire fraud, risk and liability vary depending on the industry and the kind of attack. Start designing your IRP by mapping the types of fraud that are most likely to target your business. Categorize the crises you may face and assign a risk level to each. By anticipating the incidents that may occur, you’ll also be able to set up detection and escalation protocols for the specific kinds of incidents and tailor your responses accordingly. You may even want to create separate IRPs for each threat category. 

1. Refine action steps to recover funds

Prioritize steps for mitigating financial losses in your IRP. Include the procedures and contact information necessary for reversing fraudulent wire transfers, freezing compromised accounts, and retrieving stolen funds before fraudsters can cash out or convert funds into untraceable currency.

Pick stakeholders

This means that your plan should include the contact information for your corporate bank account representative and your bank's fraud department. If they hear from you in the first 24-48 hours after an incident, they can initiate a wire recall and help open a case at the receiving bank so that both institutions are running parallel investigations. Wire recall typically only works when the recipient approves the reversal. In cases where fraudsters are obstructing the reversal process, law enforcement can help.

Contact authorities

Include the link to the FBI Internet Crimes Division incident reporting form and the contact information for your local field office. Completing the form will give you a case number and add you to the queue for a response from Federal Law Enforcement who have the power to freeze funds, even when receiving banks don’t. 

Get support

Lastly, designate a staff member responsible for visiting ReportAFraud.org and connecting with CertifID Fraud Recovery Services. The CertifID recovery team has a close partnership with the secret service that enables you to bypass the early stages of the investigative process and save precious hours in the wake of an attack. Their jobs are to advocate for your case to receive priority attention and resolution. They also have an index of contacts at each FBI field office to include in your plan.

2. Document IT evaluation procedures

Next, identify the processes for connecting with your IT experts to assess the origin and extent of the breach. Then you’ll be able to scale your response and remediation to the volume of compromised data.

For example, if the attack originated in your cloud storage software, you may not need to suspend email communications. Or if the breach affected one staff member, you can contain the damage by freezing their accounts while other staff with different security clearance can continue doing business.

The goal is to isolate and freeze the technology at the source of the breach, repair the vulnerability, and relaunch the software as quickly as possible.

Define the playbook for achieving business continuity regardless of where the breach occurs. You’ll need these contingencies in case the investigation lasts long enough to disrupt use of your usual enterprise software. For example, if you need to suspend use of your virtual meeting software, will you use phones for teleconferencing instead? Where will you store back-ups of your meeting data and who will be responsible for restoring them after you relaunch the software?

If certain criteria are met, you may need to authorize enterprise-level actions, like company-wide password resets. Define the thresholds that would trigger these decisions and include them in your plan.

Decide whether to include internal contacts or representatives from third party vendors and software providers in your plan. Even breaches that originate externally can have an impact on your business, so it will help to have copies of vendor policies and incident response plans to align with your own.

You’ll rely on these contacts, and the evaluations they conduct, to reveal the extent of your liability, and even additional support to which you are entitled as part of your cyber insurance policy.

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3. Understand and file cyber insurance policy and claims

Building your IRP is the perfect opportunity to reevaluate your cyber insurance policy and update it to better limit your liability. A holistic policy that covers wire fraud, cyber attacks, and even third party data breaches might better meet your needs and match your company’s risk profile. Similarly, some policies contain a low file limit and charge up to $200 per file for additional coverage on compromised records. Make informed decisions on the extent of your coverage based on the size of your portfolio or account database.

Make sure you have adequate coverage

Depending on your policy, your cyber insurance coverage may extend beyond wire fraud to include data breaches, business email compromise, and more. A robust policy can even offer legal, forensic, and IT assistance. The forensic investigators can help uncover the origin of a data breach and detect prior incidents that triggered wire fraud, which may be covered to a greater extent under a different part of your policy. Include a copy of your policy in your IRP, along with the contact information for your account manager and instructions for their claims process.

Work with a recovery expert

CertifID recovery experts are on hand to walk through your cyber insurance policy and recommend critical upgrades. Successful claims are usually contingent on compliance with cyber security basics, like identity verification. CertifID wire transfers automatically meet the highest standards for authentication and are backed by $1M in direct, first-party insurance.

4. Create proactive crisis communications

Lastly, map out each audience—both internal and external—whom you’ll need to inform regarding a data breach or wire fraud incident impacting them, and the order in which they should be notified. Audiences should include every party who touched the transaction, such as underwriters, staff, vendors, partners, and customers. Tailor these contact lists to the kinds of incidents you indexed in the first section of your IRP. For example, your entire customer base doesn’t need to know about wire fraud impacting one customer with a unique vulnerability, but your entire staff should hear about a phishing email that a colleague received so they can avoid a similar email compromise.

Pick your distribution channels

Identify which communications channel is appropriate for each audience. In some cases, a landing page with a simple URL and FAQ is the best one-stop-shop to reach multiple stakeholders at once, especially if you’ve frozen email or phone communications to curtail a breach. Denote the spokespeople who will take the lead on sharing messages and make sure your plan includes procedures for training them and notifying them immediately after an attack.

Have crisis communications pre-written

Pre-draft messaging—including phone scripts, press releases, and email templates—for each incident profile for rapid deployment in a crisis. When a fraudster strikes unexpectedly, you won’t have time to craft thoughtful messaging and secure approval from your legal council and PR lead. By getting their input in advance, you’ll be able to “press go” on your communications without doing further damage to your reputation or legal liability.

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5. Implement and maintain relevancy

Once you’ve checked the boxes of a strong IRP, socialize it for feedback from collaborators named in the plan. Make sure the staff responsible for executing each component feel confident in the steps to take and resources at their disposal.

Include the plan in onboarding for new staff accountable for incident response leadership. Each leader should deputize the person who will fill in for them when they’re out of office and document it in the plan. Your IRP should remain intact, even when staff are taking sick leave or vacation time.

Don’t wait until a real attack occurs to test the plan and close the gaps. Incident response leaders can run tabletop simulations with real-life threat examples to pressure test the IRP. If there’s a missing component, you’ll find it and fix it during the low stakes simulation.

Plans should also survive the regular cadence of staff transitions and tech upgrades. By scheduling periodic reviews and updates to your IRP, you’ll make sure your plan includes the most current names and contact information for each incident.

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Download free wire fraud incident response plan template

Lastly, don’t reinvent the wheel. Running a business and mitigating the constant threat of fraud is hard enough without starting from scratch on an IRP. Customize our free IRP template to establish a sophisticated recovery strategy without the heavy lifting. It comes with the peace of mind that systems are in place to retrieve thousands, or even millions, in stolen funds when prevention strategies aren’t enough.