Control framework: Define minimum preventive and detective fraud control requirements across onboarding, identity verification, authentication, account servicing, beneficiary and ownership changes, money movement, ACH, wires, disbursements, ACATS and other asset transfers, employee access, exception management and other high risk activities. Client and vulnerable-investor protection: Sponsor fraud prevention measures addressing account takeover, identity theft, impersonation, social engineering, scams, unauthorized transfers, insider activity and financial exploitation of vulnerable or specified adults while balancing protection, client experience and operational efficiency.