Dear registered liquidator
The COVID-19 pandemic has changed our working routines and resulted in a significant worldwide increase in cyber attacks. It is important for all registered liquidators to review their fraud prevention measures and cyber threat protections to ensure they consider our changed environment.
ASIC’s June 2019 survey of registered liquidators (and reported in ASIC’s Corporate Insolvency Update – Issue 14) indicated a high level of fraud awareness and training.
Our article in the March 2019 ARITA journal (ASIC’s article) encouraged all registered liquidators to regularly review their systems and processes. Given the significant changes to practice operations experienced during COVID-19, it is more important than ever to consider how these changes have impacted your fraud prevention and detection measures.
ASIC’s email to registered liquidators on 19 March 2019 provided information about email scams and cyber attacks, and together with ASIC’s article included several actions and resources for you to consider.
Some key considerations in the COVID-19 changed working environment include:
- the impact on segregation of duties and/or usual practices brought about by partial or full remote working
- the potential need for heightened measures, including additional authentication steps and validity of invoices and payment requests
- communicating to staff, reminding them be curious, vigilant and alert to cyber threats, and providing information about how to respond to suspicious emails (e.g. not clicking on links and who to contact if they receive a suspicious email)
- providing staff training on fraud awareness
- cyber insurance to protect against impacts resulting from a cyber attack
- informing third parties, who hold money on your behalf, to be wary of emails requesting account information
- understand functionality and consider trialing add-ons that may enhance fraud detection capabilities via your software providers
the potential for uncharacteristic behaviour due to elevated financial and other stress caused by the impact of COVID-19.
Further resources that you may also find useful include:
- ASIC’s Regulatory Guide 258 Registered liquidators: Registration, disciplinary actions and insurance requirements provides guidance for the registration, renewal and maintenance of registration for registered liquidators. This includes guidance about capacity and fidelity insurance to manage risk and insure against theft
- Accounting Professional and Ethical Standards APES 330 Insolvency Services provides specific guidance on funds handling, noting at 6.1, that members should have policies and procedures which prohibit partners and employees, etc. from acquiring or deriving a benefit from external administration assets
- ASIC’s general information on cyber resilience
- practical tips on keeping your business safe from cyber threats published by business.gov.au.
Yours faithfully
Thea Eszenyi
Senior Executive Leader
Insolvency Practitioners Stakeholder Team