Wednesday, March 7, 2012

Fraud Fight: How to Pick Your Battles

Interview\Podcast preview of my RSA session discussing prioritization in infosec: Fraud Fight- How to Pick Your Battles
http://www.bankinfosecurity.com/interviews.php?interviewID=1377

The Call of Hacktivism

I was quoted in Tracy's blog on bankinfosecurity:The Call of Hacktivism

Mobile Banking: Guidance Coming?

 I was interviewed about Mobile Guidance on Bankinfosecurity.com:

Mobile Banking: Guidance Coming? http://www.bankinfosecurity.com/articles.php?art_id=4455&opg=1

Friday, December 30, 2011

FFIEC Guidance: Are Banks Ready?

FFIEC Guidance: Are Banks Ready?
Some Institutions Still Confused About Regulators' Expectations
Tracy Kitten
December 20, 2011


As 2012 nears and federal regulators prepare to examine financial institutions for conformance with the FFIEC Authentication Guidance, just how prepared are U.S. banks and credit unions? The answer, industry observers say, depends in part on the asset size of the institution.
The nation's largest institutions are working to stay ahead of the updated guidance issued this past June, but smaller institutions are facing stiff challenges to improving online banking security, says Gartner analyst Avivah Litan.
"Mid-tier and regional banks are confused about how far to go to meet FFIEC compliance requirements, especially with regard to payment batch-file processing, which can be expensive to re-engineer," she says.
Litan believes most community institutions are working hard to meet the FFIEC's demands for risk assessment strategies, layered security controls and improved customer awareness of online banking risks - the core tenets of the guidance. But for the smaller institutions, FFIEC conformance depends heavily on the effectiveness of their core processors - their third-party service providers.
"[Institutions] are very dependent on their online banking processors, most of whom are still upgrading their security strategies," Litan says. And many, including the processors themselves, are still confused about minimum requirements for conformance, especially when it comes to authenticating payments.
"They have little or no resources to deal with payment security," Litan adds.

Survey: Confused About Expectations

According to a new FFIEC Online Banking Security Readiness Study commissioned by Guardian Analytics, while banking institutions are prepared to share plans for ongoing risk assessments, many still struggle with grasping regulators' baseline security expectations.
Of the 300 U.S. institutions surveyed - 75 percent banks, 25 percent credit unions - most respondents say they've spent the last six months jumping into conformance action. [See the full survey on Guardian's website.]
Fifty-six percent have already completed their risk assessments, and 59 percent have already created plans to address identified risks.
What's more, institutions are addressing security across the board, focusing on enterprise-level security. Most institutions are embracing the need for substantial security upgrades. They're investing more in anomaly detection, and they're addressing fraud from a higher perspective.
"About 85 percent said they've made changes to address the guidance, and they plan to do more," says Guardian CEO Terry Austin. "The first part of 2012 will be very busy."
Austin speculates banks and credit unions are seeing improved fraud detection as a competitive differentiator. "Layered security is a focus," he adds. And so is customer and member education.
Two out of three of the institutions surveyed by Guardian said they already have extensive customer education programs in place; and most over the next six months plan to expand on those programs.
But only 50 percent say they fully understand minimum requirements for authentication conformance. "We're not criticizing the FIs here, but we're highlighting that there is still some education and interpretation help that the institutions need with the guidance," says Guardian's Terry Austin.
Doug Johnson, vice president of risk management policy for the American Bankers Association, says that confusion proves that more industry education is needed.
"Many community banks have not had the benefit of participating in the many webinars or conference sessions on this subject," he says. "As a result, we have written a number of articles for our various publications and bulletins on the subject and will continue to get the word out to help alleviate any confusion."
Litan says most institutions also have expressed concerns about how to interpret the updated guidelines relative to mobile banking, which is not addressed explicitly in the guidance.
"The regulators may have to issue an FAQ to clarify some of the points," she says. "I think the audits starting early in 2012 will clarify what the regulators want. I don't expect a hard-handed approach from them come January 2012. But by 2013 the regulators will expect to see substantial security upgrades across the board for online banking."

Conformance Strategy

Joe Rogalski, information security officer and first vice president of Buffalo-based First Niagara Bank, says taking an enterprise-level view is a good idea. "It's good to look beyond the requirements, to make sure you're doing the best thing for your institution," he says.
What more should institutions do to ensure preparation for their 2012 examinations? Experts offer these six tips:

  1. Plan for Ongoing Risk Assessments. Annual and quarterly risk assessments look good as ideas on paper, but institutions must be prepared to prove they have thorough plans in place to follow through with these assessments. "I think the annual risk assessment is a much bigger deal than most banks realize," Litan says. "Most banks have not done an annual risk assessment to the level that the new guidance calls for."
  2. Organize for Fraud Management. Upon conducting these assessments, institutions need to be equipped to take fast action on identified risks. "Fraud management is not one-size-fits-all," Litan says. "It's different in every bank, and most decisions are made by committee." More flexibility needs to be built into the response plan, so committee decisions don't choke or stall reaction time.
  3. Show Layered Security Plans. Regulators want to see what institutions have done to fill the gaps identified in their assessments - especially in terms of the layered security controls prescribed by the guidance. "If you're not going to be compliant by [the time of your exam], make sure you have a reason why, or the ability to show that you have very good compensating controls," Rogalski says.
  4. Tackle the Basics. A lot of banks are busy implementing out-of-band authentication, Litan says. Yet, they're still struggling to detect and prevent ACH and wire fraud. Rather than investing millions of dollars in out-of-band solutions, she recommends that institutions focus on core security requirements first. Address identified weaknesses with basic and well-understood solutions.
  5. Examine Vendors. For institutions that rely on vendors for stronger authentication, be sure you know how well your vendor is performing. After all, it is the institution that will be held to the fire for conformance - not the vendor. Review the vendor's own internal conformance assessment, or - if the organization is large enough to be examined by federal regulators - ask to review its FFIEC examination later in 2012 to see the agencies' own impressions. "It does give you some insights, and the examiners can provide that exam," Johnson says. "But you're only allowed to [view] that exam if you have an existing contract in place with that party."
  6. Show Metrics of Progress. Experts agree that regulators won't expect to see 100 percent conformance in 2012. But institutions must prove they will reduce risk over time. Even if more technology investments are needed, proof of progress will satisfy auditors. "I think institutions are not measuring the potential exposure they may have, and the potential losses which they've managed to mitigate against their existing losses," Johnson says. "If they can demonstrate that they have mitigated potential losses, even if exposure increased because of more attacks, then they can show that their measures of protection are improving. It demonstrates effectiveness."

Friday, December 2, 2011

2011- The year of the breach


2011 has been one of the worst years ever for security breaches with both large and small companies being affected. Among these big headline breaches were Sony’s PlayStation network, RSA, Citigroup, ADP and a large email marketer, Epsilon.  The trickledown effect from the Epsilon breach was felt by many companies; large financial institutions JPMorgan Chase and Citibank, major hotel chains Marriott and Hilton as well as big retailers Best Buy and Walgreens.
The bad guys are out there and they are constantly trying to gain access to customer and confidential data. For a typical breach, it costs approximately $212 per record lost for credit monitoring and notifications sent to customers and this does not include the cost associated with reputational loss. For example, if 650,000 records were compromised it would cost approximately $137,800,000. That would be quite a hit for most business could yours recover?
As this year comes to an end, I have put together a top 10 list if things you can do to keep both you and company safer online in 2012.
10. If you are not expecting a package from UPS or any other parcel-delivery service, do not click on the link they sent you, as it is probably a phishing email. Instead, access the site by going through the homepage to avoid being sent to a fraudulent site where your information could be stolen.
9. Do not click on links within an unsolicited e-mail.
8. Avoid filling out forms contained in e-mail messages that ask for personal data.
7. Log on directly to the official Web site for the business identified in the e-mail, instead of “linking” to it from an unsolicited e-mail. If the e-mail appears to be from your bank, credit card issuer or other company you deal with frequently, your statements or official correspondence from the business will provide the proper contact information.
6. If an e-mail asks you to respond quickly or states there is an emergency, it may be a scam. Fraudsters create a sense of urgency to get you to act impulsively.
5. The FBI or other government agencies will not contact you about a lawsuit or subpoena through e-mail. They tend to like to talk to you in person about those things.
4. Ensure that your home PC’s patches are up to date as well as your anti-virus.
3. Always compare the link in the e-mail to the web address link you are directed to and determine if they match.
2. On social media sites, (Facebook, etc) be careful what kind of information you share and whom you share it with.
1. My personal favorite, remember what Mom always said, “If it looks too good to be true, it probably is.”
Have a happy and safe holiday season and a safe new year.

Monday, October 24, 2011

Security Initiatives: The ceiling is collapsing where to start?

Being able to take the time to create your strategic plan for the Information Security Program as well as understanding when and where to concentrate your resources should always be a priority.   That is until reality sets in and you realize that there is no time to think strategically and you must act like an M*A*S*H unit and triage.  When you have multiple high-risk immediate priorities how do you decide what comes first to stabilize the situation

When I need to prioritize and am in the weeds I tend to use the following criteria.

1.    Is there an active problem, intrusion or data loss situation in flight or is a critical service not being provided.

2.    Is there a pending situation that will lead to a problem or loss situation?  Glaring situations that can cause big losses, firewall mis-configuration etc.

3.    Will my data be out of my control or in an unknown state? Is data leaving the network to a third party?

4.    Are there regulatory or compliance issues?  Projects required for industry or regulatory compliance?

The triage situation should only deal with issues that are critical to the enterprise in the near term, typically less than six months, concentrating resources to correct the mission critical issues.  After those immediate issues are corrected time and resources must be spent on strategic planning and execution.  Strategic planning of projects and initiatives should happen as quickly as possible even during triage situation and   at a minimum have an outline of where the plan is going to ease in switching gears. 

Wednesday, October 5, 2011

Smishing: How Banks Can Fight Back



Credit
Eligible

Police Warn of Text-Based Scams Targeting Banking Customers
October 5, 2011 - Tracy Kitten, Managing Editor

Police in Pima County, Ariz., have issued a warning about smishing, or text-based phishing attacks, targeting mobile users. The warning comes after a Tucson-area resident filed a complaint about a phishy text message that appeared to be from the recipient's financial institution. The text, which asked the accountholder to call a specified number to resolve a possible compromise of his bank account, included the last four digits of the user's debit card, making the text appear legitimate.
"If the victim had called the number provided, he would have been asked to verify his debit card number and the security code on the back of the debit card," the department said in its warning. "With this information, the debit card could have been reproduced, and the victim's bank account would have been cleaned out."
Smishing attacks are low-tech schemes, but they nevertheless prove frustrating for financial institutions. Jason Rouse, a mobile security expert and consultant with Cigital Inc., says smishing, like most socially engineered schemes, preys on victims' trust. "So, the bank should issue very clear guidelines about the way it will communicate with customers," he says. "The must tell customers they will never ask for a password or information over a cell."
Rouse's advice, incidentally, is in line with the new FFIEC Authentication Guidance, which directs institutions to give their customers "an explanation of under what, if any, circumstances and through what means the institution may contact a customer on an unsolicited basis and request the customer's provision of electronic banking credentials."

Smishing on the Rise

In the Tucson case, the would-be victim was quick to contact his financial institution before responding to the text. But not all consumers are quite so savvy, especially in the mobile environment. "People are used to phishing by e-mail," says mobile expert Dr. Markus Jakobsson. "Smishing has still not sunk in."
The mobile phone is a social device, and consumers' communications and behavior over mobile devices mirror casual phone communications. "Their trust in their friends rubs off on everything that has to do with the [mobile] phone," Jakobsson says [See Mobile Banking: The New Risks]. That casual mobile behavior is likely to perpetuate more mobile fraud, and encourage fraudsters to exploit even the most low-tech mobile schemes, such as smishing.
The good news for financial institutions is that smishing attacks have not hit a tipping point. But it's only a matter of time. "We will see it peak in the next couple of years," Rouse says. "From an organized crime perspective, smishing is simple, and I think you will see more organized crime lean toward it."
Smishing scams are increasing in popularity over traditional voice/phone call scams known as vishing because consumers are more apt to fall for them. "The absence of an awkward pre-recorded or live voice call increases the probability of success for the criminal," says John Buzzard, of FICO's Card Alert Service. "The consumer is only evaluating the words in the text without the weight that hearing a voice or recording would add to their decision-making process."

Consumer Education and Anomaly Detection

As smishing attacks like the one in Tucson proliferate, financial institutions have to hone customer and member education efforts. The Tucson scheme proves how crafty smishing attacks can be, says Joe Rogalski, information security officer of Buffalo-based First Niagara Bank [$38 billion in assets]. "The last four [digits] of the card number and the increase in the use of text alerts give the customer confidence and improve validity of the scam," Rogalski says. "Customers need to understand how and when the institution will contact them on an unsolicited basis, and if they will ever request a PIN or other confidential information. Getting this message out to consumers consistently is very important."
There's little financial institutions can do to stop smishing. The real success of controlling attacks and subsequent losses begins and ends with the consumer.
Anthony Vitale, who oversees mobile solutions for San Francisco-based Patelco Credit Union [$3.75 billion in assets], says financial institutions are quickly learning that the convenience of mobile banking comes with a price. As the use of mobile explodes, the threats and risks associated with mobile behavior have never been greater.
"Organizations are putting in layers of security and tools to safeguard information and assets, however, the fraudsters are attacking our weakest link, the consumer," Vitale says.
To ensure it's sufficiently addressing existing and emerging mobile risks, Patelco invested in a behavior-monitoring solution. When something out of the ordinary occurs, the credit union can react. So, if a user has been duped by a smishing attack and the bank account is hit with requests for funds in amounts and to recipients that seem out of line, a red flag goes up.
Institutions also should monitor mobile transactions in the same ways they monitor online transactions. If fraud is detected, transactions can be stopped and addressed with the mobile carrier. Mobile carriers can assist banks in tracking anomalous behavior and shutting it down before it results in big losses.
But how can institutions initiate better communication and education with customers and members? Getting the word out about mobile and even online risks has proved challenging in the past.
Citigal's Rouse says institutions should not be intimidated from using common channels, like mobile. "I think the No. 1 channel banks should be using is the mobile channel itself," he says. "There is no reason why they can't use the mobile device to disseminate information to their users."