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.
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November 4, 2019
Encouraging Password Hygiene
Practicing good password hygiene such as using strong passwords and never using them for any other application can be a huge nuisance. Many people, including yours truly, would love to see passwords fade into oblivion and be replaced by stronger authentication technologies, such as biometrics. But the fact remains that passwords will continue to be used extensively for the foreseeable future, and for as long as they remain with us, it's imperative that we adhere to good password protocol. Verizon's 2019 Data Breach Investigation Report reveals that more than 60 percent of successful data breach hacks were due to compromised or stolen log-in credentials.
Information that describes good password practices is abundant, but people continue to be careless. So how can we successfully encourage people to actually follow these practices?
Interestingly, while I was pondering this issue, I came across a Wall Street Journal article. Written by a cybersecurity professor, the article describes research that the author and her colleagues did on this very topic—how to get people to create strong passwords—and I thought it would be useful to share their findings.
So what's the secret to getting us to use strong passwords, according to these researchers? It's the simple incentive of time—and by this I mean the length of time we're allowed to keep our passwords. The researchers found that people were willing to use stronger passwords if they could keep them for longer than they had in the past.
The conventional wisdom used to be that we should change passwords at least once a year. Now many financial service providers and others require users to change passwords every 30 days. However, some organizations continue to allow longer time periods, or perhaps don't enforce change at all, but offset the longer duration with stricter rules, requiring longer passwords with a minimum number of special characters. I imagine most of us are accustomed to the strength bar or bubble graphic that shows us the strength of a password as we're creating it. These might be useful in educating us about what strong passwords look like, but the researchers found them to be ineffective in driving people to create strong passwords.
I'll admit I don't always practice the best password hygiene. One of several reasons for this is that it seems my passwords expire so frequently. But I could get fully on board with building stronger, unique passwords if that meant I would have more time before I had to change them.
Have you seen or experienced other tactics or solutions that have pushed you to use better password hygiene? If so, we would love to hear from you!
October 28, 2019
Should We Throw in the Towel When It Comes to Data Breach Prevention?
We've all heard it said—we've probably, cynically, said it ourselves: "It's not a matter of if but when your company will be hit by a data breach." Reports about cyberattacks and network breaches fill my daily newsfeed with headlines on ransomware attacks, attacks on multifactor authentication, and 5G network vulnerabilities. For each new, better, stronger, faster solution the industry comes up with, criminals find a way to circumvent it in seemingly short order. Is there anyone whose personal information hasn't been stolen once, twice, five times? I've lost count of how many times I've received six months of free credit monitoring.
In today's world, is there any way for an organization to fully protect itself against the broad spectrum of ever-evolving threats and still have time, resources, and capital left over to conduct its everyday business? Or should we assume that breaches are a foregone conclusion, throw in the towel when it comes to prevention, and turn our focus instead to incident response?
According to Verizon's 2019 Data Breach Investigations Report , small businesses were frequent targets of breaches. (The report looked at incidents occurring from November 1, 2017, to October 31, 2018.) Other findings it reported: outside actors perpetrated 69 percent of breaches, 52 percent were the result of hacking, and it took months or longer to discover 56 percent of the incidents.
Last year, I wrote about committing to muscle memory your organization's plan for the right of boom. A Google search on "data breach response" returns pages of results with guides, resources, and services, but the midst of a cyber-event is probably not the best time to come up with a plan. Turns out, there's an app for that! At a recent fintech conference, I saw a demo of a dynamic breach response solution that turns response into a routine business process. The company likens its app to "an airbag for network breaches" and claims the tool helps organizations prepare for, detect, and respond to data breaches. Another company demonstrated a white-labeled application for financial institutions that aims to reduce post-breach fraud and identity theft of consumers through algorithmic risk assessments that produce recommendations for actions to take to mitigate these risks.
October is National Cybersecurity Awareness Month. It's a good time to review your own right of boom plan or take steps to implement one. One resource: the Department of Homeland Security's Cybersecurity Resources Road Map for small and midsize businesses.
While it is not hyperbole to assert that criminals will breach your organization's network, you should not throw in the towel or lower your defenses against such threats. Rather, you should avail yourself of technological innovations to support breach prevention and response preparedness so your organization can restore normal business operations as quickly as possible. What approach has your organization taken to adopting threat prevention and response preparedness?
July 22, 2019
Ransomware Attacks Continue
Ransomware attacks have only continued since I addressed the problem in a recent post, and they've continued to target municipal and state agencies. Riviera Beach (May) and Lake City (June), both in Florida, were successfully attacked. Lake City paid a bitcoin ransom of approximately $470,000 while Riviera Beach paid about $600,000, also in bitcoin. These attacks took place soon after the one in Jackson County, Georgia, whose government paid $400,000 for decryption keys. While law enforcement officials recommend that victims not pay ransom for fear that doing so encourages the criminals to continue their attacks, the affected agencies often view paying the ransom as a cost-effective way to restore operations as soon as possible. Moreover, Lake City and Riviera Beach were both insured against such attacks, with a $10,000 and a $25,000 deductible, respectively. It appears that in all three of these instances, when they got their ransom, the criminals supplied the necessary data that allowed officials to regain control of the systems.
So how can governments, schools, hospitals and doctors' offices, financial services, and consumers best protect their systems from these nefarious attacks? It's not easy—criminals are constantly developing new malware to get into systems. However, here are some critical guidelines from IT security professionals that can help us all avoid or minimize the impact of a ransomware attack.
- Perform data backups at least daily, and keep at least one backup copy offsite or on portable storage devices not connected to the network.
- Avoid using end-of-life operating systems and software that cannot be updated to address known vulnerabilities.
- Install software updates and security patches as soon as possible, and follow established change control guidelines.
- Evaluate segmenting your network into separate zones to minimize the spread of a ransomware infection.
- Train and test employees regularly about how criminals use phishing attacks to load malware onto computers that can then compromise system access credentials.
- Require employees to use strong passwords.
- The IT security community is divided about how frequently passwords should be changed, but do so at least every six months.
- Maintain comprehensive access controls so that only the employees that require access to individual system have such rights, especially regarding remote access.
- Use reliable security software and, as the second bulleted item recommends, keep it updated. Evaluate adding special trusted anti-ransomware tools, some of which are free.
- Evaluate your cybersecurity insurance policy in terms of its ransomware coverage.
In addition, every agency and organization should develop a ransomware response plan that can be implemented as soon as an attack has been detected. While the immediate focus should be on minimizing the impact of the attack, elements for business continuity, law enforcement notification, media communications must also be part of the plan.
We hope you won't be a victim, but simply keeping your fingers crossed isn't an effective plan.
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
July 1, 2019
Ransomware: Hopefully Not Coming Soon to a Computer Near You
In March 2018, the city of Atlanta fell victim to a ransomware attack. Criminals gained access to the city's computer network and loaded SamSam Ransomware, a malicious software. The criminals demanded a payment of approximately $51,000 in virtual currency to provide the decryption keys necessary to regain access to the infected and locked systems. The attack laid siege to the city by rendering police, utility billing, traffic court, and other systems unusable. The city refused to pay the ransom, and has since spent at least $6 million in forensic and remediation work with as much as an additional $11 million earmarked for system upgrades and other resources to combat future attacks.
Ransomware attacks have been a growing threat. While studies such as the Symantec Internet Threat Security Report show that the overall incident rate has decreased slightly, they also indicate that the range of targets has shifted. From 2013 until last year, consumers were the most frequent targets, with ransom requests in the hundreds of dollars. In the early years of these attacks, individuals would get a message that their computers had been infected and they had to pay a fee to download a fix. In many cases, the infection claim was false. Beginning in 2018, businesses—including municipalities, hospitals, and health care networks—have become primary targets, with ransom demands in the tens or hundreds of thousands of dollars. Typically, the criminals demand that the ransom be paid in cryptocurrency (nearly always bitcoin). As in the Atlanta case, these attacks often prevent customers from making payments, whether for traffic violations, business permits, or even marriage licenses.
Should ransomware targets pay the ransom? Law enforcement communities officially say "no." In some cases, when victims pay the ransom, they never receive the decryption keys to regain access to their data, or the keys don't work. There is concern that payments only encourage the criminals to commit further attacks, sometimes against the same business and demanding additional money. It is not illegal for a business to make ransomware payments, and many, including Newark, New Jersey ($30,000), have done so.
Is your computer or network prepared to defend against such an attack? Ransomware attacks typically exploit weak passwords or known security vulnerabilities in applications and operating systems. But a common entry point is through phishing of an employee to compromise legitimate system access credentials. As in business email compromise, the criminal conducts surveillance to learn about the different systems in operation and plans the initial attack to have the greatest possible impact. As we have stressed so often, prevention starts with employee education and the adoption of security best practices. In a future post, I will write about more prevention and mitigation best practices.
As for the Atlanta ransomware attack, last December, a federal grand jury returned indictments against two foreign nationals for the attack. The grand jury indicated these two people were also behind the April 2017 attack on Newark, New Jersey. There was hope in the law enforcement and cybersecurity communities that the arrest of these individuals would dampen enthusiasm for this threat vector, but attacks this year against Akron, Ohio (January), Albany, New York (March), and Baltimore, Maryland (May) suggest otherwise. None of these cities made any ransom payments.
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
April 29, 2019
In early April in Boston, I happened by the annual conference and competition of the Massachusetts School Bank Association (MSBA). Two hundred eighty-four students from 30 high schools competed in three segments: product design, marketing, and a quiz show that covered financial literacy topics. The MSBA is an association of schools with financial literacy programs and financial institutions that operate educational branch offices in schools.
I learned that next-gen security is firmly within the sights of the next gen of Massachusetts bankers. The conference theme of “personal financial security” played out in each segment. It was clear that the organizers—high school teachers and executives at financial institutions—had the financial safety of the next gen firmly in view:
- The trivia contest consisted of general banking and personal finance questions including questions related to identity theft awareness, financial fraud, and financial cybersecurity.
- The marketing challenge tackled the need to educate customers about security and, according to the prompt, "the need to use good security practices and tools to protect [customers] from identity theft and/or fraudulent use of their accounts."
- In product design, the winning team from Taunton High School designed an app to help students determine if they were more or less likely to be victims of identity theft.
I chatted with students from Chelsea High School about their app: "Are you smarter than a fraudster?" Teaching others is a good way to learn yourself, and these young people were on top of best practices for protecting their payments cards (don't give out info in email or on the phone), preventing identity theft (shred documents), and keeping email safe (don't click on links from unknown parties).
When they aren't designing apps, the Chelsea students work as interns at the Chelsea High School branch of Metro Credit Union.
What is your bank doing to educate the next gen of security ninjas?
April 8, 2019
Insuring Against Cyber Loss
Over the last few months, my colleagues and I have had multiple speaking engagements and discussions with banking and payments professionals on the topic of business email compromise (BEC). Generally, these discussions lead to talk about a risk management strategy or approach for this large, and growing, type of scam. One way some companies and financial institutions are mitigating their risk of financial loss to BEC and other cyber-related events is through a cyber-risk insurance policy. In a recent conversation, someone told me their cyber-insurance carrier mandates that they get an outside firm to audit and assess their cybersecurity strategy and practices, or they risk losing coverage.
According to a recent Wall Street Journal article, some large insurers are even going a step further and collaborating with each other to offer their own assessments of cybersecurity products and services available to businesses. Their results, which they will make publically available, will identify products and services they deem effective in reducing cybersecurity incidents and potentially qualify insured companies with improved policy terms and conditions if they use those products or services.
Cybersecurity vendors who would like their products and services to be assessed must apply by early May. They are not required to pay any fees for the evaluation. In light of the rising number of cyber-related events and increasing financial losses, along with the growing number of legal cases between companies and their insurance providers, this move by the insurance companies makes sense as a way for them to potentially reduce their exposure to cyber incidents. But it will be very interesting to see just how many cybersecurity vendors apply for participation in the program and how effective the insurers are at assessing the vendors' products and services. Moreover, for businesses, just using cybersecurity solutions helps them meet only part of the challenge. How they implement and maintain these solutions is critical to an effective cybersecurity approach.
Also of note in the Wall Street article is a graph that depicts the percentage of a particular global insurance company's clients, by industry, that have purchased a stand-alone cyber-insurance policy. Financial institutions, at 27 percent, rank last. Perhaps they are more confident in their cybersecurity strategies than are other industries, or perhaps insurers have no attractive stand-alone policies for financial institutions.
The cyber threat today is serious. In fact, Federal Reserve Board chairman Jerome Powell in a recent CBS 60 Minutes interview, when asked about a possible cyberattack on the U.S. banking system, responded that "cyber risk is a major focus—perhaps the major focus in terms of big risks."
As the Risk Forum continues to also focus on and monitor cyber risks, we look forward to the public findings from the insurers' collaborative assessment of cybersecurity products and services and will be interested to see if, over time, more financial institutions obtain cyber-risk insurance policies. I suspect the cyber-insurance industry will evolve in the products they offer and will continue to grow as companies look to mitigate their risks in the event of a cyber event.
What are your thoughts on this collaborative effort by the insurers? How do you see the cyber-insurance industry evolving? And do you think more financial institutions (or perhaps your own) will acquire cyber-insurance policies?
By Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
February 25, 2019
Fighting Discipline with Discipline
When I meet with law enforcement officers, they often describe the growing sophistication of criminal groups that commit large-scale fraud. Just like legitimate enterprises, these global organizations follow a disciplined process to reach their business goals. As a successful salesperson follows specific steps from prospecting to closing, successful criminal enterprises follow defined steps that improve their chances of successfully executing financial crimes.
Let's take a look at a disciplined, five-step process that criminals generally follow to successfully execute a business email compromise (BEC) attack. The process can also apply to other types of cybercrimes, such as account takeover.
- Identify targets. Fraudsters scan specific industries to identify firms to attack. While firms handling real estate closings and trusts remain primary targets of BEC attempts, other businesses, across multiple industries, that have large-value accounts payable have increasingly become targets.
- Gain access. Fraudsters attempt a variety of methods to gain entry to the business accounting or IT system. With BEC, the most common way in is to get an employee to open an email or click on a link containing malware that will result in the compromise of the employee's log-in credentials. Another method is to exploit a security gap in the company's IT access control system. Social engineering is also becoming more frequent.
- Establish a foothold. Upon gaining access to the business records of the company, the fraudsters are likely to create hidden paths to enter and exit the company's systems without detection.
- Conduct surveillance. More and more often, fraudsters take their time monitoring the activity and records of the company, sometimes for months. Doing so helps them better understand the company's controls related to authorizing large-dollar-value transactions and customer records maintenance. When they eventually conduct their misdeed, they stay within normal controls and therefore don't set off any additional oversight.
- Steal and retreat. When the criminals have gained the necessary knowledge—by conducting their thorough, sometimes lengthy surveillance—they make a funds transfer request. In a BEC, this is generally an email from a senior official of the company to the finance department conveying some sense of urgency. In most cases, the request refers to a valid invoice or customer account number in an attempt to appear legitimate. Of course, the criminal controls the account that would receive the funds. If the request succeeds, the criminal may make additional funds transfer attempts. When they're done, they try to erase any evidence of their intrusion.
These sophisticated criminals achieve their results with discipline, but you can successfully stop BEC and similar attacks by relying on your own discipline in several areas. BEC is totally preventable if a business combines employee education and testing with meticulous authorization control processes, audit oversight, and IT security techniques. Instill this discipline and you won't be a victim.
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
January 14, 2019
Hiding in Plain Sight
Over the holidays when our family is all together, we always try to watch A Christmas Story. There are so many memorable moments in the movie, from the triple-dog-dare-you, tongue-frozen-to-the-flagpole scene to the leg lamp breakage. When the story revolves around Ralphie and the Little Orphan Annie secret decoder ring, it triggers my childhood memories of having a similar decoder ring that came with a pair of P.F. Flyers sneakers (think pre-Nike and Adidas). This year, our movie-watching led to a storytelling session of techniques worthy of any spy movie for passing secret notes. Many of the examples were like the decoder ring—they used some sort of secret alphanumeric table as a key to solve the cryptic message. In other words, we were talking about a rudimentary form of encryption, which, in today's technology, renders data useless to those without a key, whether they're bad guys or good guys.
But our conversation didn't stop there. I told a childhood story of dipping a toothpick in lemon juice and writing a message on paper. After the juice dried, the message became invisible, and I would then write an innocuous—and visible—message on the paper with pen or pencil. The recipient would carefully hold the paper over a flame to slowly reveal the hidden message. (Kids, try this only under adult supervision!) Little did I know I was using a technique called steganography—hiding a message within another message—that people also use today to protect information online.
Various forms of the technique date back to Greek civilization when untrusted messengers had to convey sensitive or classified information, or a message was at risk of being intercepted. (There is an entertaining and educational video on steganography by Richard Buckland, a professor at the University of New South Wales in Australia.) Today, technology has created a new technique in the form of digital steganography, which is the practice of hiding an image, audio, or data file within another image, audio, or data file.
A recent article in infoRisk Today highlighted the darker side of steganography, with its use by the criminal element. That article prompted me to conduct more research on the technique as a payments risk. From a cybersecurity standpoint, the greatest risk to consumers appears to be when the criminal hides a malware file within an image, audio, or other data file that, when opened, will load malware onto the device for future eavesdropping or control. Such an event could lead to the compromise of PII (or personally identifiable information), online credentials, or other sensitive information on the device without the owner's knowledge. In an August 2017 release, Kaspersky Lab warned about the difficulty for existing data protection processes to detect embedded malicious code.
Account takeover fraud is a major criminal activity that generally begins with the compromise of an individual's legitimate banking log-in credentials. A criminal who obtains this information can execute payment transaction fraud and, ultimately, synthetic identity fraud (see last week's post). While there are valid uses for steganography as an alternative to encryption, the criminal element will continue to develop uses of digital steganography to further their criminal operations and, as the infoRisk article notes, this usage is becoming more sophisticated and harder to detect.
By David Lott, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
December 17, 2018
Card Fraud Values Often above Average
Recent data from the Federal Reserve Payments Study remind me of my first experience with payments fraud as a 20-something college grad freshly arrived in Boston. I left my wallet in a conference room, and someone lifted my credit card. I still remember the metaphorical punch to the stomach when the telephone operator at the card company asked, "Did you spend $850 at Filene's Basement?" $850! That was more than twice my rent, and far more than I could conceive of spending at Boston's bargain hunters' paradise in a year, let alone on a one-night spree.
Decades later, the first thing I do to check my card and bank statements is to scan the amounts and pay attention to anything in the three digits. For noticing high-value card fraud, this is a pretty good habit.
That's because, on average, fraudulent card payments are for greater dollar values than nonfraudulent card payments. In 2016, the average value of a fraudulent credit card payment was $128, almost 50 percent more than $88 for a nonfraudulent credit card payment. For debit cards, the relationship was more pronounced: $75 for the average fraudulent payment, about twice the $38 average nonfraudulent payment, according to the Federal Reserve Payments Study.
Even to the noncriminal mind, this relationship makes sense: get as much value from the card before the theft or other unauthorized use is discovered. For a legitimate user, budgetary constraints (like mine way back when) and other considerations can come into play.
Interestingly, this relationship does not hold for remote payments. In 2016, the average dollar values of remote debit card payments, fraudulent and nonfraudulent, were the same: $68. And the average value of a nonfraudulent remote credit card payment, $151, exceeded that of a fraudulent remote credit card payment, $130. Why the switcheroo?
A couple of possibilities: Remote card payments include online bill payments, which often are associated with a verified street address and are of high value. So that could be pushing the non-fraudulent remote payments toward a high value relative to the fraudulent remote payments. Another factor could be that fraud detection methods used by ecommerce sites look for values that could be outliers, so perpetrators avoid making purchases that would trigger detection—and thus average values for remote fraud are closer to average values for remote purchases generally. But this is speculation. What do you think?
The relationships described here are depicted in figures 21 and 28 of the recent report of the Federal Reserve Payments Study, Changes in the U.S. Payments Fraud Landscape from 2012 to 2016. You can explore other relationships among average values of payments, and more, on the payments study web page.
By Claire Greene, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
November 5, 2018
Organizational Muscle Memory and the Right of Boom
"Left of boom" is a military term that refers to crisis prevention and training. The idea is that resources are focused on preparing soldiers to prevent an explosion or crisis—the "boom!" The training they undergo in left of boom also helps the soldiers commit their response to a crisis, if it does happen, to muscle memory, so they will act quickly and efficiently in life-threatening situations.
The concept of the boom timeline has been applied to many other circumstances, as I can personally attest. More years ago than I will admit to, I was a teller and had to participate in quarterly bank-robbery training that focused on each employee's role during and immediately after a robbery. The goal was to help us commit these procedures to muscle memory so that when we were faced with a high-stress situation, our actions would be second nature. My training was tested one day when I came face-to-face with a motorcycle-helmet-wearing bank robber who leaped over the counter into the teller area. Like most bank robbers, he was in and out fast, but thanks to muscle memory, we were springing into action as soon as he was leaping back over the counter and running out of the branch.
This type of muscle memory preparation has also been applied to cybersecurity. Organizations commit significant human and capital resources to the left of boom to help prevent and detect threats to their networks. Unfortunately, cybersecurity experts must get things right 100 percent of the time while bad actors have to be right only once. So how do organizations prepare for the right of boom?
Recently, I had the opportunity to observe a right-of-boom exercise that simulated a systemic cyberbreach of the payments system. This event, billed as the first of its kind, was sponsored by P20 and held in Cambridge, Massachusetts. Cybersecurity leaders from the payments industry convened to engage in a war games exercise that was ripped from the headlines. The scenario: a Thanksgiving Day cyberbreach, the day before the biggest shopping day of the year, of a multinational financial services company that included the theft and online posting of 75 million customer records, along with a ransomware attack that shut down the company's computer systems. The exercise began with a phone call from a reporter asking for the company's response to the posting of customer records online—BOOM! Immediately, the discussion turned to an incident response plan. What actions would be taken first? Who do you call? How do you communicate with employees if your system has been overtaken by a ransomware attack? How do you serve your customers? What point is the "in case of fire break glass" moment, meaning, has your organization defined what constitutes a crisis and agreed on when to initiate the crisis response plan?
An overarching theme was the importance of the "commander's intent," which reflects the priorities of the organization in the event of an incident. It empowers employees to exercise "disciplined initiative" and "accept prudent risk"—both principles associated with the military philosophy of "mission command"—so the company can return to its primary business as quickly as possible. In the context of a cyberbreach that has shut down communication channels within an organization, employees, in the absence of management guidance, can analyze the situation, make decisions, and then take action. The commander's intent forms the basis of an organization's comprehensive incident response plan and helps to create a shared understanding of organizational goals by identifying the key things your organization must execute to maintain operations.
Here is an example of a commander's intent statement:
Process all deposits and electronic transactions to ensure funds availability for all customers within established regulatory timeframes.
Having a plan in place where everyone from the top of the organization down understands their role and then practicing that plan until it becomes rote, much like my bank robbery experience, is critical today.
By Nancy Donahue, project manager in the Retail Payments Risk Forum at the Atlanta Fed
- Encouraging Password Hygiene
- Should We Throw in the Towel When It Comes to Data Breach Prevention?
- Looking for Partners in Safer Payments
- The Range of Un-Friendly Fraud
- Payments Webinar October 10: Cash in the 21st Century
- "Insuring" Ransomware Will Continue to Flourish
- Designing Disclosures to Be Read
- Is There a Generation Gap in Cash Use?
- What the Most Convenient Food Tells Us about Payments
- Is Friction in Payments Always Bad?
- November 2019
- October 2019
- September 2019
- August 2019
- July 2019
- June 2019
- May 2019
- April 2019
- March 2019
- February 2019
- account takeovers
- ATM fraud
- bank supervision
- banking regulations
- banks and banking
- card networks
- check fraud
- consumer fraud
- consumer protection
- credit cards
- cross-border wires
- data security
- debit cards
- emerging payments
- financial services
- financial technology
- identity theft
- law enforcement
- mobile banking
- mobile money transfer
- mobile network operator (MNO)
- mobile payments
- money laundering
- money services business (MSB)
- online banking fraud
- online retail
- Payment Services Directive
- payments fraud
- payments innovation
- payments risk
- payments study
- payments systems
- phone fraud
- remotely created checks
- risk management
- Section 1073
- skills gap
- social networks
- third-party service provider
- trusted service manager
- Unfair and Deceptive Acts and Practices (UDAP)
- wire transfer fraud
- workforce development
- workplace fraud