Family Office
INTERVIEW: Citi Private Bank Sets Out Cybercrime Challenge For Family Offices

The private bank has brought a report charting what family offices must do to reduce vulnerability to a threat that appears to grow by the day.
Cybercrime will cost business and individuals an estimated $2.1
trillion by 2019 and create an annual $400 billion bill. Banks
have been hit; most recently, the UK’s National Health Service,
the German railway network and US logistics firm FedEx fell
victim to a massive ransomware attack. Wherever you look,
cybercrime is big news and threatening to weaken confidence in
digital ways of doing business.
For all these reasons and more, those who work in private banks,
family offices and wealth management houses are or should be
placing cybersecurity at the top of their agenda. (A recent
Family Wealth Report conference discussed this topic;
see
here.) And in a new report, entitled Family Offices and
Cybersecurity, Citi Private
Bank examines where family offices are vulnerable, advises
them on how to be more robust and considers future implications.
(See
here.) The report is written by Edward Marshall, a
director in the global family office group at Citi Private Bank.
FWR recently interviewed him.
In particular, Marshall talked about "ransomware" attacks and
their significance, which he described as the “latest iteration
of extortion”.
“This form of cybercrime denies a victim access to critical data
and systems. It is often spread through phishing emails. Think of
phishing as form of social engineering where criminals pretend to
be from a legitimate service provider (e.g. your email provider,
a bank, a social media site. They try to get you click on the
link, sometimes ask you to fill out a form, and then you end up
downloading a piece of malware. People also fall victim to
“drive-by” downloading of malware where a victim visits an
infected website and malware is downloaded and installed without
their knowledge. After ransomware has been executed on a victim’s
computer, the attacker responsible for the malware demands a
ransom payment before allowing the victim to regain access to
their systems and data,” he said.
“The actual `ransom’ demand comes on your screen after the
malware has been installed where the criminals demand a payment
or they will delete or release information they control on your
system. Cybercriminals will typically demand payment in
cryptocurrency and often be thoughtful enough to provide
instructions on how to set up digital currency accounts. After
payment is made, the information is usually released however; the
payment mechanism makes it nearly impossible for law enforcement
to trace where the money went,” he continued.
“Ransomware is not going away anytime soon. A wide scope of
industries have started to face ransomware attacks ranging from a
hotel that couldn’t create new key cards for its rooms, free
rides on public transportation because payment systems were
overrun, or a police station losing evidence that was stored
digitally. Moreover, individuals have also experienced ransomware
attacks in the form of attackers threatening to share
compromising pictures taken from an exploited laptop camera or
threats to post personal data online. Medical facilities have
been a common target of ransomware to date,” he said.
Marshall set out some eye-popping statistics. “There have been
over 4,000 new ransomware attacks on any given day since January
1, 2016 - a 300-per cent increase over 2015, he said, citing data
from the FBI. In fact, he said, the FBI thinks that $209 million
was lost in ransomware attacks during just the first three months
of 2016, overtaking the $1.6 million total in losses reported to
the FBI’s Internet Crime Complaint Center in 2015. “These figures
are ransoms alone and don’t include costs associated with lost
business or fixing the damage,” he continued.
Family offices are vulnerable because they are where the money
is. Family offices may think they are out of the firing line
because they are supposedly discreet, little-reported bodies:
what does Marshall think can be done to change that mind-set by
FOs?
“Many family offices have the `wealth’ commensurate with small
and medium enterprises, but typically don’t put in place the same
levels of security, making them lucrative targets for hackers.
Unfortunately, the idea that only corporations and governments
are at risk from cyberattacks is prevalent. This lack of
preparation makes Family Offices an easier target when compared
to other institutions or businesses,” he said. “I think Sun Tzu
has a better quote than Mr Sutton that encapsulates the
cybersecurity threat to family offices and preventative measures
family offices should take: `Know the enemy and know yourself; in
a hundred battles you will never be in peril’.
“However, looking at wealth alone as a predictor of cyberattack
threats is myopic. Family offices face complex cybersecurity
challenges because informal governance structures, efficient
service vs. effective security operating procedures,
underinvestment in critical technology systems, heavy reliance on
small staff with outsized access to critical data, security risks
from external vendors (supply chain risk), and fame and
publicity,” he said.
“Prominence often accompanies significant wealth and wealth
creation. This attention, whether desired or avoided, could make
the family office a target. Many single family offices are
notoriously private and do what they can to stay off the radar,
attempting to anonymize and protect the underlying family they
serve by choosing generic names and separate LLC entities.
Despite these efforts, wealthy individuals are easily identified
making them potentially lucrative targets for cyber criminals,”
Marshall continued.
The ransomware angle
“Early ransomware attacks mostly target individual consumers and
seemed largely opportunistic. By 2016, however, attackers began
to focus their efforts on both businesses and individuals,
according to observations by the FBI. Herein lies the
problem for family offices - they are financial institutions,
private individuals with substantial wealth, and quite often the
family members they serve are business owners/executives,”
Marshall said.
“A number of factors may converge to bolster this trend.
Family offices and businesses may have more money to spend
to pay ransoms to unlock their data than a typical individual
victim; be more willing to pay because the data is more valuable,
be subject to a legal obligations or privacy concerns to protect
their data, or need to pay to perform critical operational
functions. Moreover, because most ransoms are now paid using
cryptocurrency, the transactions become very difficult or
impossible for law enforcement to investigate after a ransom has
been paid,” he said.
Action points
Marshall started by talking about prevention, which is a first
step for FOs. “Employee awareness and training efforts are a
critical first step to preventing ransomware, as employees who
can identify and properly handle phishing emails and other common
attack vectors that deliver ransomware can prevent many
ransomware infections,” he said. Examples of steps that people
can take include:
- Check the address: Did that email come from “@myvendor.com” or
“@myvend0r.com?” Check email addresses for accuracy and look for
anything suspicious, like improper formatting or misspelled
names;
- Avoid clicking on links: Avoid clicking links in email
altogether. If you must click the link, place your cursor over
the link before clicking and observe the destination URL at the
bottom left of your screen. When in doubt, Google the website you
need instead of clicking the link;
- Be wary of attachments: Never open attachments from senders you
do not recognize. When you do know the recipient, it is still
wise to treat any attachment you didn’t request as
suspicious;
- Do not conduct any personal business with your work email
address: Avoid situations in which you might be tempted to click
on emails related to issues like package delivery or other
personal matters.
If ransomware interacts with a system, family offices must be
sure that security best practices are followed to reduce the
chance it will penetrate a system. “Keeping your systems current
on updates and security patches, disabling macros in Microsoft
Office, and running antivirus software can help catch ransomware
that isn’t caught by your employees,” he said.
Another point, Marshall said – echoing comments from other
experts – is to regularly back up critical data. “Having a data
backup and recovery plan for all critical information renders the
extortionist’s demands ineffectual. This could entail keeping
copies of important files safe on an offline storage disk, or
having a clean version of your operating system handy in case the
machine itself becomes locked entirely.”
Marshall also urged family offices to get in touch quickly with
professional and law enforcement when trouble strikes, arguing
that just paying a ransom will leave threats unresolved. There’s
no guarantee that a ransom payment will prevent future
threats.
Where are the weak links in the chain?
“Businesses globally continue to be impacted by a long-standing
scheme that exploits executive email accounts and email-based
invoicing procedures to execute fraudulent wire transfer payments
to foreign banks. This attack traditionally targets how your
business processes wire transfers and exploits vulnerabilities in
those procedures. As awareness is increasing among victims,
actors have recently focused on also compromising sensitive data
along with redirection of wires,” Marshall said.
Victims have recently reported a new scenario which involves
fraudulent requests from a compromised business executive’s email
account to internal HR, finance or auditing staff to compromise
W-2 data or employee Personally Identifiable Information (PII).
These requests for PII may or may not occur along with a request
for a fraudulent wire transfer. Law enforcement reports that
victims have fallen for this data loss scenario, even if they
were able to previously identify traditional incidents of
attempted fraudulent wire transfers,” he said.
Marshall said that lw enforcement and security researchers agree
that the primary BEC scenario involves the compromise of a senior
executive’s corporate email account or the impersonation of a
senior executive’s corporate email address. An email appearing to
be from the executive is sent to an individual who is responsible
for processing wire transfers with a message to process the
transaction immediately. This scenario relies upon
executive-level authority to authorize such a transaction and
conveys a sense of urgency so the employee will execute the
fraudulent wire transfer without double checking the authenticity
of the request,” he said.
Marshall has some other words of advice:
“Avoid using publicly-available email accounts for business
purposes. Entities with open-source email accounts are the most
targeted in BEC schemes as these accounts are easiest for the
attackers to access and impersonate,” he said.
Other points:
- Closely examine email addresses. Ensure that you check the
entire email address and do not rely upon shortened addresses
that some email providers substitute for the actual address –
e.g. JohnSmith instead of john.smith@gmail.com;
- The field following the @ sign in an email address is known as
the domain name. When using a corporate email account, consider
filtering email traffic to flag emails from domain names that are
similar, but not identical, to either your domain name or your
customer domain names. When possible, consider purchasing domain
names that are similar, but not identical, to your company name
to ensure these variations are not exploited for nefarious use –
e.g. a legitimate domain: company-a.com and a possible attacker
domain: company_a.com;
- For individuals in the company who have been previously
targeted, consider eliminating their ability to use the “Reply”
function in email transaction requests. Instead, rely upon a
secure list of addresses for contacts that are physically typed
in during every email exchange;
- Consider implementing procedures for verifying urgent or
confidential wire transfer orders to eliminate this often used
technique;
- Explore a second factor authentication method for receiving
internal wire transfer requests. This can be as simple as a phone
call or as sophisticated as a PIN system to authenticate the user
placing the wire transfer request. This will enable the payment
processor to authenticate if the transfer order comes from an
authorized requester or if the legitimate email account is being
used by an unauthorized user; and
- Closely monitor high value transactions, new trading partners,
new bank or account numbers, and transfers to any new countries.
Once thresholds are established, implement maker/checker
requirements to ensure anomalies are not overlooked in processing
wire transfer orders.
FWR asked Marshall if turnover at family offices creates a
threat. “People are often the weakest link in the information
security system for a family office. The level of awareness on
information security threats and the proper ways to combat them
has great variability. Therefore, cybersecurity education should
be a key part of family planning and business operations
meetings,” he said.
Another simple way to help shore up cyber defenses is
through the creation of family office cybersecurity policies.
These policies can be derivations from parent companies that
created the wealth that are customized to the unique nature of
the family office. Policies should include recommendations on how
to prevent cyberattacks and what to do in case a breach is
detected.
Inevitably, FWR had to ask about the implications of social
networking. What is Citi Private Bank’s approach in the advice it
gives?
Because they are largely unmanaged by businesses, incredibly easy
to use and globally scalable, they present both an unprecedented
opportunity to businesses from a marketing, branding and customer
engagement perspective as well as an unprecedented threat from a
cybersecurity, brand risk and compliance perspective. Family
offices face issues from SNSs both from staff at the family
office and from family members themselves.
Often, family offices will downplay the risks stemming from SNSs
by discussing their infrequent low usage of SNSs. This opinion is
a form of cognitive bias and ignores several factors of
cyberattacks that originate on SNSs. Firstly, cyber criminals
that target businesses and family offices tend to work in complex
organized crime networks. These criminal networks write programs
that estimate your net worth based on largely publically
available information and use highly sophisticated attack methods
to infect SNSs. Moreover, there is a market for the programs that
allow cyber criminals to conduct these SNS attacks. Secondly,
SNSs are becoming more effective at profiling users. This
profiling provides substantial demographic and net worth
information that can be used to target heads of families through
children, relatives, and staff.
Cyber insurance
“While cyber insurance is a burgeoning field for insurance
companies and corporation businesses, it can serve as another
potential line of defense for family offices. Insurance, at its
core, is a risk management tool and with an evolving threat
stemming from information security, Cyber Insurance presents an
opportunity for Family Offices to evaluate gaps and build
customized solutions,” Marshall said.
Cyber Insurance requires an underwriting process and this is an
aspect that Family Offices should explore as well. While
actuarial data for cyber insurance is in its infancy compared to
more established lines, underwriting practices are being improved
as the size of the market grows, threats expand, and the attack
data sets are analysed,” he said.
Finally, how can and should family offices work with other FOs on
security?
"These organizations will often jump at the chance to meet and
network with other family offices to share intelligence. This
data sharing is typically of the investment nature or concerning
next generation issues. Family offices would benefit from
expanding intelligence sharing to include cybersecurity issues.
As family offices become distinct and visible, numerous
conferences have emerged to cater to this group both in the US
and abroad. Family Offices should also consider adding
information security conferences to their annual circuit such as
the RSA Conference, Black Hat, SANS, Spooks and Suits, or
Infosecurity Europe," Marshall added.