Cyber Security for Financial Services

Where the pressure comes from

The FCA expects regulated firms to manage operational resilience and to protect client assets and data, with senior management accountable. The obligations are principles-based rather than a checklist of technical controls, which in practice means firms are expected to make and evidence proportionate decisions.

For smaller firms — IFAs, mortgage and insurance brokers, wealth managers — this lands as a series of practical questions: do you have MFA, have you tested, what happens if your systems are unavailable, and can you demonstrate any of it. Professional indemnity insurers ask the same things at renewal.

Regulatory expectations change. Verify the current position with your compliance adviser rather than relying on a summary.

What we consistently find

• Adviser email without MFA, which is where payment redirection and client impersonation begin.
• Client data in spreadsheets outside the back-office system, on laptops and in mailboxes.
• Back-office platforms exposed for remote working with weak access control.
• Third-party integrations — platforms, custodians, comparison services — with standing credentials nobody reviews.
• No tested continuity plan, despite operational resilience being an explicit regulatory theme.

Client payment fraud

The same pattern as conveyancing: a compromised mailbox, a watched transaction, altered payment details at the moment funds move. For a wealth manager or broker the sums involved make this a firm-ending risk rather than an inconvenience. The technical controls are mailbox security and MFA; the procedural control is verified callback on any change of bank details, using a number you already hold.

Where to start

Cyber Essentials, a Microsoft 365 and identity review, and external infrastructure testing. For firms operating a client portal or any customer-facing application, application testing follows. Alongside that, a continuity plan you have actually walked through — operational resilience expectations are about demonstrable capability, not documentation.

CREST accreditation matters more here than in most sectors, because it is frequently what a compliance officer or insurer is specifically looking for.

Common questions