Imposter Prompts Citigroup Wire Transfer

October 11, 2013

You think you know. You're pretty sure. That email is from your customer. Except, these days, what is it that you really know or should even be sure about when it comes to anything online?  Today's BrokeAndBroker Blog pounds one more nail into the coffin of Internet uncertainty.

For the purpose of proposing a settlement of rule violations alleged by the Financial Industry Regulatory Authority ("FINRA"), without admitting or denying the findings, prior to a regulatory hearing, and without an adjudication of any issue, Philippe R. Oertle submitted a Letter of Acceptance, Waiver and Consent ("AWC"), which FINRA accepted. In the Matter of Philippe R. Oertle, Respondent (AWC 2012033616101, September 30, 2013).

Oertle was registered with with Citicorp Investment Services in October 2006, where he remained until his May 2007 association with Citigroup Global Markets Inc. ("CGMI").  The AWC asserts that Oertle had no prior relevant disciplinary history.

July 3rd Email

On July 3, 2012, an email requesting a $44,743 wire transfer was sent from a customer email account to Oertle's firm email account - the email requested the transfer from the customer's account with the brokerage firm's affiliated bank to another domestic bank. The communication explained that the customer was in an important meeting and would not be available to speak by telephone.

In response to the email transfer request, Oertle collected the necessary information to process the wire transfer, which included the names of the receiving bank and account to be credited, plus the American Banking Association routing number. Some of this information was obtained through further email exchanges between Oertle and the customer. 

After Oertle obtained the required information, he entered it on the affiliated bank's transaction request form, on which he noted that the request had been initiated by "Telephone." The AWC asserts that Oertle knowingly mischaracterized the initial and subsequent email queries as done by telephone.

Following Oertle's preparation of the transfer request form, the affiliated bank's Client Service Offer completed the form and the requested wire was faxed to the firm's Funds Transfer Unit.

July 6th Email

On the morning of July 6, 2012, Oertle received another email from the same customer seeking a second wire between the same two banks in the amount of $48,690. As with the first transaction, Oertle allegedly filled out the transfer form with misleading "telephone" notation and the wire was again faxed to the firm's Funds Transfer Unit.


The AWC asserts that, in fact, the purported customer was not the party transmitting the two funds transfer requests; to the contrary, an online imposter was at work.  Apparently, on July 6th, the actual customer became aware of the July 3rd transaction and immediately contacted Oertel. Although the customer's communication resulted in the cancellation of the July 6th wire, the earlier wire had been processed. The affiliated bank subsequently repaid the customer for the July 3rd wire.


According to online FINRA documents as of October 11, 2013, CGMI "Discharged" Oertle on July 11, 2012 based upon allegations of:


FINRA asserted that Oertle's preparation of two forms falsely attesting that he had spoken to a customer to confirm two wire transfer instructions violated FINRA Rule 2010. In accordance with the terms of the AWC, FINRA imposed upon Oertle a $5,000 fine and a 15-business-day suspension from association with any FINRA member in any capacity.

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