FINRA Outlines Steps Firms May Take To Address Imposter Websites

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
FINRA outlined various steps broker-dealers may take to monitor and respond to the increasing frequency of imposter websites created to defraud clients.
United States Technology

FINRA outlined various steps broker-dealers may take to monitor and respond to the increasing frequency of imposter websites created to defraud clients.

According to an Information Notice, imposter websites are designed to obtain clients' personally identifiable information or login credentials. The Information Notice states that firms may take "proactive steps" to monitor for imposter websites by:

  • registering additional domain variations that include common misspellings or character substitutions; and
  • using social media or monitoring services to catch any potential imposter sites.

According to the Notice, if a firm identifies an imposter website, it may take various responses to address the issue and deactivate the website, including:

  • reporting the website to local law enforcement, the FBI or the FINRA Internet Crime Complaint Center;
  • generating a "WHOis" search to find the contact information of the imposter;
  • contacting the hosting provider or domain registrar to remove the imposter;
  • consulting a cybersecurity specialist attorney or similar consultant;
  • notifying the SEC, FINRA or other regulators; or
  • warning clients of the imposter threat.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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