wire-fraud-and-trust-account-controls

name	wire-fraud-and-trust-account-controls
description	Protect the money: verify every wire by out-of-band callback before sending, require dual authorization, reject email-changed instructions, and safeguard the escrow trust account with three-way reconciliation, no commingling, and daily oversight. Business-email-compromise sensitive; each control specific is verify-at-use.

Wire-Fraud & Trust-Account Controls

The two controls that keep a settlement operation solvent: no wire leaves without out-of-band verification, and the escrow trust account is reconciled and protected absolutely.

Advisory, not legal or financial advice. These are operational control patterns, not a compliance certification; specific ALTA pillar language, state trust-account rules, and bank product terms are [verify-at-use]. No PII. This skill designs controls; a licensed officer executes them.

Wire-fraud controls (the disbursement never skips these)

Control	What it is	Why
Out-of-band callback	Verify every payoff/proceeds destination by phone to a number you sourced independently — never from the email/instruction itself	Business email compromise supplies fake numbers
No change by email	Any account/routing change to instructions already on file is treated as fraud until re-verified by callback	The classic BEC "updated wire instructions" attack
Dual authorization	A second authorized person approves every outgoing wire	Removes the single point of failure
Positive pay / bank controls	Bank-side control on outgoing items	Catches altered/unauthorized items
Educate the parties	Warn buyers/sellers in writing that wire instructions will not change by email	Most consumer wire fraud hits the party, not the agent

The rule: verify the wire before you send a dollar. A callback is cheap; a wire loss is often unrecoverable.

Trust-account controls (protect the escrow account absolutely)

Control	Standard
Three-way reconciliation	Bank balance = book balance = sum of open file ledgers, reconciled on a set cadence ([verify-at-use])
No commingling	Escrow/trust funds never mixed with operating funds
No negative ledgers	No file ledger goes negative — that is spending another file's money
Daily oversight	Positive-pay, ACH blocks, and reconciliation reviewed by someone independent of the disbursing officer
Segregation of duties	Whoever reconciles is not whoever disburses

Every dollar in the account belongs to someone else. A shortage is a fiduciary breach, not a bookkeeping lag.

Read metrics

Signal	What it tells you
Wires sent without documented callback (target: zero)	A live fraud exposure
Three-way reconciliation variance / age	Trust-account health
Days to detect a ledger negative	Oversight cadence adequacy

See also

• Traverse the wire-verification before disbursement tree in ../../knowledge/title-escrow-decision-trees.md.
• Companion: ../escrow-closing-and-disbursement/SKILL.md; ALTA-pillar reference: ../../knowledge/title-escrow-reference-2026.md.
• Best practices: ../../best-practices/verify-the-wire-before-you-send-a-dollar.md, ../../best-practices/protect-the-escrow-trust-account-absolutely.md.