Take On Payments

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Take On Payments, a blog sponsored by the Retail Payments Risk Forum of the Federal Reserve Bank of Atlanta, is intended to foster dialogue on emerging risks in retail payment systems and enhance collaborative efforts to improve risk detection and mitigation. We encourage your active participation in Take on Payments and look forward to collaborating with you.

July 20, 2015


Unsafe at Any Speed?

If you're a Corvair enthusiast, you likely get the title's reference to Ralph Nader's book that polemically accused manufacturers of resistance to the advancement of automotive safety. Shift your thoughts from automobiles, axles, and bumpers to payments, cyberattacks and data breaches. Then consider this question—if we successfully speed up payments, is payment safety more likely to advance or retreat?

I hear the question often. Since I first blogged about this topic in January, I've attended several conferences set in the context of building a better, faster, more efficient payments system. If the conversation hasn't gone straight to "safety," the topic has surely been broached before closing. The answers that presenters offer, in terms of how we make payments more secure, remain unchanged from earlier this year. The updated summary follows.

  • Innovate. Make full use of such things as biometrics and tokenization. Do not fear but rather make use of the best things coming from the cryptocurrency world.
  • Collaborate and coordinate. Share everything, taking full advantage of groups of all types to facilitate deployment and spread of best practices, among other things.
  • Prevent and plan. In a continuous and ever-improving activity, make use of such things as enhanced threat detection and continue to layer security measures. Also, educate fully, across the spectrum of both providers and users.
  • Track and report. We must do more of this in a frank, transparent way and it must be timelier.

Emphasizing and pursuing all these goals is still right in my view, yet something seems missing. I believe what's missing is a more expansive, easily accessible law enforcement regime—something that more closely parallels what's available for conventional crime fighting.

There has been good news, of late, in that various law enforcement agencies have both apprehended and successfully prosecuted cybercriminals of all sorts. What's important about this is, as law enforcement has more success, there is hope that miscreants will have an increasing expectation of getting caught. Let's assume a drop in crime rates is highly correlated to the likelihood or certainty of being caught. Self-test the theory by thinking of it this way. How often do you exceed the speed limit (answer silently to yourself). Now consider—how often do you speed when a patrol car is in the lane right next to you? It's imperative that law enforcement continue to evolve and improve such that the criminals who contemplate cybercrime increasingly anticipate they'll be caught.

The cliché that faster payments will mean faster fraud if we don't have faster security is somewhat beside the point. The fact is cybercrime has been and remains a material and looming threat. The world is all but fully a digital one and that means our police have to be able to put more—and more effective—digital patrol cars on the digital highway. Until then, to varying extents, payments are likely to be unsafe—at any speed.

Photo of Julius Weyman By Julius Weyman, vice president, Retail Payments Risk Forum at the Atlanta Fed

July 20, 2015 in crime, cybercrime, innovation, law enforcement, payments risk | Permalink

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June 08, 2015


Is the Conventional Wisdom about EMV Migration Right?

We're within five months now of the initial EMV (chip) card liability shift for POS transactions. Most people in the industry have held the belief that as the ability to create counterfeit cards is shut down, the criminals will shift their focus primarily to the card-not-present (CNP) environment, where they can continue to use payment card data they take from the magnetic stripe or other data breaches. In fact, my colleagues and I have been broadcasting this message in our presentations and posts for quite some time. Our assessment, along with most other industry experts, was based on the statistics released by banking groups in major countries that had already gone through the EMV migration. The chart illustrates one view of their experiences. It seems to leave no doubt about what we can expect.

Chart_cnp_fraud_losses

But does it mean what we think it means? While the chart clearly shows an increase in the CNP channel in fraud losses, did the ratio of CNP fraud to overall sales increase? Unfortunately, definitive data is not readily available to provide that answer. Using some confidential sources and partial—but significant volumes of—payment data, we were able to determine that during the period from 2010 to 2013, as a percentage of overall sales, CNP fraud in Canada actually held relatively steady. But was that stability created due to the large increases in the recurring billing segment in the CNP environment, which has a relatively low rate of fraud? At this point, we just don't have data granular enough to tell us.

I don't think this means that there isn't a reason to be concerned about CNP fraud as the EMV migration in the United States continues. For one thing, the experience of others is no guarantee that we will experience the same. But perhaps the biggest reason for us not to relax about the issue is that, even if the levels hold flat through our migration, CNP fraud is still quite significant and has a major negative financial impact on merchants and issuers. The 2013 Federal Reserve Payments Study found that CNP fraud by volume is three times that of card-present fraud.

This situation also demonstrates the need to be able to collect detailed and accurate data on fraudulent payments activity. Fraud has been a real challenge in this country because of the large number of payments stakeholders that end up saddled with the loss. The Federal Reserve is interested in working with the industry to develop a process for collecting such information for the benefit of all.

Photo of David Lott By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

June 8, 2015 in chip-and-pin, cybercrime, EMV | Permalink

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May 11, 2015


The Hill Tackles Cybersecurity

In a post last month, Take on Payments highlighted recent cybersecurity-related executive orders. Cybersecurity has been a hot item inside the Beltway in 2015, and the activity hasn't been limited to the executive office. Beginning on April 22, the House passed two separate cybersecurity bills. And now all eyes are on the Senate, as it looks like a vote on its own cybersecurity bill is set to take place later in May. Today's Take On Payments post will highlight the two House bills recently passed by the House and the Senate's bill under consideration.

Protecting Cyber Networks Act (H.R. 1560)
This bill encourages the timely sharing of cyber threat information among private entities, nonfederal government agencies, and local governments. It provides businesses liability protection for sharing cyber threat indicators when taking reasonable efforts to remove personally identifiable information (PII). The bill also allows the federal government (excluding the National Security Agency and Department of Defense) to share cyber threat information with private entities, nonfederal government agencies, and local governments. To further promote and protect individual privacy, it requires that the Department of Justice (DOJ) periodically review the information shared to ensure that PII is not being received, used, or disseminated by a federal entity. Finally, this bill directs the Cyber Threat Intelligence Integration Center (CTIIC), under the direction of the Office of the Director of National Intelligence, to serve as the primary organization to analyze and integrate all intelligence shared.

National Cybersecurity Protection Advancement Act of 2015 (H.R. 1731)
The purpose of this bill is to also encourage information sharing of cyber related risks among the private sector and government. Unlike its companion bill, which directs the CTIIC as the overseer of the information-sharing program, this bill authorizes the Department of Homeland Security (DHS) to do so. In order for the DHS to serve in this capacity, the bill expands the composition and scope of the DHS national cybersecurity and communications integration center to include additional parties, namely private entities and information-sharing and analysis centers, among its non-federal representatives. As with H.R. 1560, the bill has provisions to protect individual privacy and requires that the DHS performs an annual privacy policies and procedures review. As with its companion House bill, liability protection is afforded to parties sharing information.

Cybersecurity Information Sharing Act (CISA) of 2015 (S. 754)
The Senate's version of cybersecurity legislation is a companion bill to the two recently passed House bills and combines tenets of both of them. It's viewed as an information-sharing bill, with the DHS serving as the federal entity responsible for overseeing the sharing of data between the government and private sector. The DOJ is responsible for ensuring that privacy and civil liberties are upheld within the information-sharing program. As with the House bills, liability protection is provided to all entities sharing information.

The goal of information sharing featured in these bills is the hope both government and private sector would benefit. As evidenced by the participation of a significant number of financial institutions (FIs) with the Financial Services Information Sharing and Analysis Center, many FIs are seeing value to sharing cybersecurity information within their own sectors. Additionally, the Retail Industry Leaders Association established the Retail Cyber Intelligence Sharing Center earlier this year to share cyber threat information between retailers and law enforcement. Whether or not these bills accomplish the goals of creating a private environment to safely share cybersecurity information and risks, I think the payments industry and other private industries would benefit from sharing information among themselves and with government and law enforcement agencies.

Photo of David Lott By Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

May 11, 2015 in collaboration, consumer protection, cybercrime, law enforcement, regulations | Permalink

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April 13, 2015


Leaving a Cybersecurity Legacy

On April 1, the current administration's fourth executive order related to cybersecurity was signed into action. This executive order shows an ongoing commitment to securing cyberspace. In 2009, the executive office released its Cyberspace Policy Review, which triggered a flurry of cybersecurity policy. (Relatedly, the government's "Buy Secure" initiative to increase payment security mandated the issuance of chip-and-PIN cards for all federal employees and benefits programs beginning in January 2015.) This week, Take On Payments summarizes the four cybersecurity-related executive orders that have ben signed over the last six months and what these orders could mean for the banking and payments industries.

Blocking the Property of Certain Persons Engaging in Significant Malicious Cyber-Enabled Activities (4/1/15)
Authorizes swift and severe sanctions by the Treasury Department to those engaged in malicious cyber activities that pose a significant threat to national security, foreign policy, economic health, or the financial stability of the United States. This action occurs regardless of where the offenders are domiciled, and can include the freezing of assets and denial of entry into the United States for individuals and entities. These malicious activities include, but are not limited to, distributed denial-of-service (DDOS) attacks and misappropriation of financial information for financial gain. According to an insider, attacks on banks and the financial sector, including the unauthorized access of payment credentials, would likely qualify as significant enough to warrant these new sanctions. While critics debate the enforceability of these sanctions, the banking and payments industry should find this development promising. Law enforcement is often challenged to bring these individuals to swift justice.

Promoting Private Sector Cybersecurity Information Sharing (2/13/15)
Encourages the Secretary of Homeland Security to establish information sharing and analysis organizations (ISAOs) as well as standards and guidelines to establish a robust information-sharing network related to cybersecurity incidents and risks. ISAOs can be organized on the basis of multiple attributes, including industry sector or region. Information sharing would take place both within and across ISAOs. Although the financial services industry has had some success with information sharing within their sector through organizations such as Financial Sector-Information and Security Center, the private sector generally remains challenged to share information across sectors. We hope this order will lead to the development of standards and better coordination to allow for information sharing of cybersecurity incidents and risks between the financial services sector and other industries.

Improving the Security of Consumer Financial Transactions (10/17/14)
Although cybersecurity wasn't the main focus of this executive order, two cybersecurity components are included in it. The first relates to the remediation of identity theft. It specifies that the Attorney General will issue guidance to promote regular submissions by federal law enforcement agencies of compromised credentials to the National Cyber-Forensics and Training Alliance (NCFTA) Internet Fraud Alert System. Secondly, the order requires that all federal agencies that make personal data accessible develop a plan to implement multifactor authentication. While directed towards federal agencies, it is possible that this order will pressure financial institutions and other private industry entities within the payments industry to adopt similar compromised credential submission and multifactor authentication practices, if they have not already.

The current cybersecurity activity isn't just limited to executive orders. Several cyber-related bills have circulated the congressional floor the past several years. A future Take On Payments post will highlight several bills that have been introduced in 2015 on Capitol Hill and what they could mean for banking and payments.

Photo of Douglas KingBy Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

April 13, 2015 in cybercrime | Permalink

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December 22, 2014


Top 10 Payments Events in 2014

As the year draws to a close, the Portals and Rails team would like to share its own "Top 10" list of major payments-related events and issues that took place in the United States this year.

#10: Proposed prepaid rule. After a long wait, the Consumer Financial Protection Bureau issued its proposed rules on general reloadable prepaid cards in November. While the major players in the prepaid card industry had already adopted most of the practices included in the proposed rule, the proposal allowing overdrafts and credit extensions is likely to generate differing perspectives during the comment period before a final rule is adopted in 2015.

#9: Regulation II. The U.S. Circuit Court of Appeals for the District of Columbia upheld the Federal Reserve Bank's rules regarding interchange fees and network routing rules, reversing a 2013 decision. Notice of appeal on the interchange fee portion of the ruling has been given, but resolution of the network routing rules has cleared the way for the development of applications supporting routing on chip cards.

#8: Payment trends. The detailed Federal Reserve Bank's triennial payments study results were released in July 2014, continuing the Fed's 15-year history of conducting this comprehensive payments research. Cash usage continued to decline but remained the most-used form of payment in terms of transaction volume.

#7: Card-not-present (CNP) fraud. With the growing issuance of chip cards and the experience of other countries post-EMV migration—with substantial amounts of fraud moving to the online commerce environment—the payments industry continues to search for improved security solutions for CNP fraud that minimize customer friction and abandonment.

#6: Faster payments. Continuing a process it began in the fall of 2013 at the release of a consultative white paper, the Federal Reserve Bank held town halls and stakeholder meetings throughout the year in preparation of the release of its proposed roadmap towards improving the payment system.

#5: Virtual currencies. Every conference we attended had sessions or tracks focused on virtual currencies like Bitcoin. While there was some advancement in the acceptance of Bitcoin by major retailers, the number of consumers using the currency did not rise significantly.

#4: Mobile payments. The entry of Apple with its powerful brand identity into the mobile payments arena with Apple Pay has energized the mobile payments industry and brought improved payment security through tokenization and biometrics closer to the mainstream. (Apple Pay's impact on mobile payment transaction volume will likely be negligible for a couple of years.) Additionally, the use of host card emulation, or HCE, as an alternative contactless communications technology provides another option for mobile wallet development.

#3: EMV migration. The frequency and magnitude of the data breaches this year have spurred financial institutions and merchants alike into speeding up their support of EMV chip cards in advance of the October 2015 liability shift.

#2: Third-party processors. Regulators and law enforcement escalated the attention they were giving to the relationships of financial institutions with third-party processors because of increased concerns about deceitful business practices as well as money laundering.

And…drum roll, please!

#1: Data breaches. The waves of data breaches that started in late 2013 continued to grow throughout 2014 as more and more retailers revealed that their transaction and customer data had been compromised. The size and frequency of the data breaches provided renewed impetus to improve the security of our payments system through chip card migration and the implementation of tokenization.

How does this list compare to your Top 10?

All of us at the Retail Payments Risk Forum wish our Portals and Rails readers Happy Holidays and a prosperous and fraud-free 2015!

Photo of Mary Kepler Photo of Doug King Photo of David Lott Photo of Julius Weyman



Mary Kepler, vice president; Doug King, payments risk specialist; Dave Lott, payments risk expert; and Julius Weyman, vice president—all of the Atlanta Fed's Retail Payments Risk Forum.


December 22, 2014 in chip-and-pin, cybercrime, data security, EMV, innovation, mobile payments, prepaid, regulations, third-party service provider | Permalink

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August 18, 2014


Crooks Target Business Clients

Fraudsters are always looking for ways to take advantage of trusted relationships, such as between a business and their established vendors. The fraudster's goal is to trick the business into thinking they are paying their vendor when the dollars are actually being diverted to the crook. A common scheme is for a business to receive instructions on a spoofed but legitimate-seeming e-mailed invoice to send a wire transfer to the vendor or business partner immediately. The business may pay, not realizing until it's too late that the funds are actually going to a fraudster or money mule. The Internet Crime Complaint Center (IC3) recently issued a scam alert on this scheme noting reported losses averaging $55,000, with some losses exceeding $800,000.

Criminals can perpetrate this type of fraud in many ways. Devon Marsh, an operational risk manager at Wells Fargo and chairman of the Risk Management Advisory Group for NACHA–the Electronic Payments Association, addressed some of the ways at a Payments 2014 conference session "Supply Chain Fraud Necessitates Authentication for Everyone," including these:

  • Calling or e-mailing the business, pretending to be the vendor, to change payment instructions
  • Sending counterfeit invoices that appear genuine because they are patterned after actual invoices obtained through a breach of the business's e-mail system or a vendor's accounts receivable system

Marsh also discussed important ways to reduce the risk of falling victim to these schemes. As with any e-mail that seems questionable, the business should verify the legitimacy of the vendor's request by reaching out to the vendor with a phone call—and not using the number on the questionable e-mail or invoice. The business should also educate its accounts payable department to review any vendor's payment requests carefully, verifying that the goods or services were received or performed and questioning and checking on anything at all that does not look right, such as an incorrect or different vendor name or e-mail address.

The Federal Financial Institutions Examination Council's 2011 supplement to its guidance stresses the need in an internet environment for financial institutions to authenticate their customers. The concepts this guidance addresses are also sound practices for businesses to use in authenticating their vendors.

Photo of Deborah ShawBy Deborah Shaw, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

August 18, 2014 in authentication, cybercrime, data security, identity theft | Permalink

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June 30, 2014


A Call to Action on Data Breaches?

I recently moved, so I had to go online to change my address with retailers, banks, and everyone else with whom I do business. It also seemed like an ideal opportunity to follow up on the recommendations that came out after the Heartbleed bug and diligently change all my passwords. Like many people, I had a habit of using similar passwords that I could recall relatively easily. Now, I am creating complex and different passwords for each site that would be more difficult for a fraudster to crack (and at the same time more difficult for me to remember) in an attack against my devices.

I have found myself worrying about a breach of my personal information more frequently since news of the Heartbleed bug. Before, if I heard about a breach of a certain retailer, I felt secure if I did not frequent that store or have their card. Occasionally, I would receive notification that my data "may" have been breached, and the threat seemed amorphous. But the frequency and breadth of data breaches are increasing, further evidenced by the recent breach of a major online retailer's customer records. This breach affects about 145 million people.

As a consumer, I find the balance between protecting my own data and my personal bandwidth daunting to maintain. I need to monitor any place that has my personal data, change passwords and security questions, and be constantly aware of the latest threat. Because I work in payments risk, this awareness comes more naturally for me than for most people. But what about consumers who have little time to focus on cybersecurity and need to rely on being notified and told specifically what to do when there's been a breach of their data? And are the action steps usually being suggested comprehensive enough to provide the maximum protection to the affected consumers?

Almost all states have data breach notification laws, and with recent breaches, a number of them are considering strengthening those laws. Congress has held hearings, federal bills have been proposed, and there has been much debate about whether there should be a consistent national data breach notification standard, but no direct action to create such a standard has taken place. Is it time now to do so, or does there need to be more major breaches before the momentum to create such a standard makes it happen?

Photo of Deborah Shaw

June 30, 2014 in consumer protection, cybercrime, data security, privacy | Permalink

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April 22, 2014


My Bleeding Heart

Over the past week, there has been much discussion about the OpenSSL coding flaw, the Heartbleed bug. OpenSSL is a commonly used implementation of Secure Sockets Layer (SSL). A diverse array of devices use OpenSSL to secure Internet communications. Heartbleed could allow someone to monitor log-in transactions as well as to grab and extract confidential data from affected websites and from hardware such as servers, mobile phones, and laptops. Research indicates that as many as 20 percent of all Internet sites could have been affected by this bug, including many high-profile sites. Google confirmed that phones operating Android 4.1.1 were also vulnerable to the bug, and they will remain so until the user installs its recent patch.

If there is a silver lining from the Heartbleed bug news, perhaps it is that the largest financial institutions have indicated they are not vulnerable. Even so, many smaller and mid-size banks and credit unions could still be vulnerable. Thus, the Federal Financial Institutions Examination Council issued a release urging financial institutions to incorporate patches on systems, applications, and devices that use OpenSSL. But unfortunately, this silver lining from the large banks isn’t enough to stanch this payments risk expert’s bleeding heart.

So what's the reason for my distress if the largest banks don’t appear to be vulnerable? I do not think that I am alone in admitting that I have used my credit card credentials all over the Internet. While I can count the number of cards that I have in my wallet, I couldn't begin to tell anyone the number of websites that those card credentials have been used or stored over the last two years—which is when Heartbleed appeared. Sure, I have a few go-to sites for online shopping, as I suspect many do, but I have used my cards and created accounts on many sites that I rarely visit or maybe even just visited once for a specific purchase. Are some of these sites vulnerable to this bug? I have a sinking feeling that the answer probably is "yes." And if my log-in credentials were extracted from websites other than my financial institution, I'll sheepishly admit that may be bad news as I have not always followed the best practice of maintaining separate IDs and passwords for each site. Is it really feasible to do that for so many sites?

No doubt talk and discussions in the days ahead will revolve around whether or not OpenSSL is a secure implementation of the SSL and transport layer security protocols. However, I think the heart (ahem) of the discussion of the Heartbleed bug should revolve around the use of passwords and card credentials on the Internet. This bug potentially exposes the flaws of relying on user IDs and passwords and highlights the vulnerability of using sensitive card data in the online environment. These flaws are well-documented, and fortunately, solutions are being discussed to mitigate these risks. My bleeding heart anxiously awaits their implementation.

Douglas A. KingBy Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

April 22, 2014 in cybercrime, mobile payments | Permalink

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April 14, 2014


Danger Ahead! ATM Cash-Outs

The Federal Financial Institutions Examination Council (FFIEC) issued a warning in April to financial institutions about criminals continuing to launch attacks against ATM and web-based card management systems, especially those of small- to medium-size financial institutions (FI). Dubbed "unlimited operation" by the U. S. Secret Service, this type of attack can saddle a financial institution with fraud losses in the millions of dollars. As we highlighted in a post from last May, a bank in Oman experienced this type of attack in late 2012, which resulted in a loss to the bank of almost $40 million. Imagine the impact of a loss of that magnitude to a small to midsized FI.

These attacks are especially concerning for a number of reasons. First, the criminal organizations that carry them out are highly sophisticated and well-organized, and they have an international reach. The Oman attack included a money mule network across 26 countries—including the United States—performing more than 36,000 withdrawals in a 12-hour period.

Second, unlike typical counterfeit card fraud attacks that involve a large number of accounts, the criminals behind the card management system frauds need to compromise only a small number of card accounts. The attack that resulted in the $40 million loss involved only 12 accounts. Early in this type of operation, the criminals generally obtain the PINs of the cards for these accounts by conducting some sort of covert surveillance (pinhole camera or shoulder surfing). They then counterfeit the cards using those PINs.

Third, the attacks are generally timed to take place around holidays, when bank, IT, and fraud monitoring staff levels are low.

Fourth, the criminals get remote access to the financial institutions' card management systems to reset account balances and card withdrawal parameters. They can then use the counterfeit cards over their pre-established transaction limits or balances and drain the ATMs of all cash. The criminals usually obtain access to FIs' networks using e-mail phishing schemes that target processor or network employees. Through gullible employees, malware is loaded onto the network that later gives the criminals access to the FIs’ card management systems.

Major online networks now have transaction velocity monitoring capability, which detects a high number of transactions on an individual account. This approach is necessarily only a secondary and reactive measure, not a preventive measure.

FIs should immediately address the risk mitigation steps that the new FFIEC warning outlines. Because the vast majority of small to midsized FIs depend on third-party processors to run their card management systems, it is imperative all FIs verify that their processors have the controls and safeguards in place to prevent such attacks, and they should insist on seeing validation of those controls.

Photo of David LottBy David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

April 14, 2014 in ATM fraud, cards, cybercrime, fraud | Permalink

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March 24, 2014


The Fraudsters Are Omni-Channel--and Omnipresent

"Omni-channel banking" is an in-vogue term for what bankers have known for quite some time: customers can access multiple channels to conduct their banking, have a preference for one over the others, and that preference to a large degree reflects their ages. Despite their primary preference, these consumers are likely to use multiple delivery channels, and when they do, they want a seamless experience when moving from one to another. The banking industry has struggled to successfully implement such an experience. Achieving this seamlessness is difficult because the industry has historically had a vertical organizational structure, in which each distribution channel has its own strategic plan and sometimes even an independent technology, which leads to differences among the channels. For example, if a customer were to check his or her account balance from an ATM or automated call center, the balance can be different from the balance they would get from a teller inside a branch.

Unfortunately, criminals have also adopted omni-channel usage, and at an even faster pace—they are not concerned with having a transparent or seamless experience. In fact, they seem to be more successful when there are disparate systems because that makes the detection of fraudulent activity more difficult. For example, we have seen criminal attacks move from in-branch armed robberies to ATM cash-out cyberheists. Why risk a physical confrontation and mandatory jail sentence when you can work anonymously and actually get a greater haul? We are also aware of cross-channel fraud activity within the electronic channels. In one case, e-mail phishing attacks led to a customer unwittingly disclosing online banking credentials (user ID and password) and then fraudulent payments or wires being initiated through the online channel. In a recent post, we talked about how criminals often target call centers. They use social engineering techniques to gain sufficient account information to fraudulently access accounts through a variety of channels.

A lesson from these incidents is that financial institutions must take a holistic view of fraudulent activity and not just a channel-specific view. For major losses, they have to perform forensics to determine the channel where the fraudulent effort began not just the channel where the actual fraudulent transaction occurred. Only after such investigative work can the financial institution identify the weak points in its system and processes and take the necessary steps to fortify them to provide a higher level of protection against future attacks.

Photo of David LottBy David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed

March 24, 2014 in banks and banking, crime, cybercrime, financial services | Permalink

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