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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September 21, 2020
Personal Responsibility for Irrevocable Payment Scams
Those who have experience with parenting know that with many joys come challenges. For me, one of those challenges is teaching my children the importance of personal responsibility. Picking up after themselves, making sure their chores are finished before running out the door to play, and owning up to mistakes are just some of the personal responsibilities that they struggle with daily. And while there is a light at the end of the tunnel for this struggle, I firmly believe it is their having to experience the consequences that is getting us there. In this parent's opinion, knowing there are consequences for their actions helps children become responsible.
You might be thinking, "What does this notion of teaching personal responsibility have to do with payments?" Earlier this year, my colleague Dave Lott started the dialogue among those of us at the Risk Forum, and perhaps within some of our readers' circles, when in a post he posed the question "What is the likelihood that similar protections will be extended to consumers here (United States)?" The post was related to the extension of consumer protections in the United Kingdom to combat its growing problem of authorized push payment (APP) fraud.
In August, a UK-based consumer advocate organization called Which? released a research report based on the experiences of 150 consumers related to the Contingent Reimbursement Model (CRM) Code adopted by many financial institutions in the United Kingdom in 2019. The CRM Code has two primary goals: to reduce the occurrence of APP fraud and, for the fraud that occurs, to reduce the impact. Many of these scam payments in the United Kingdom are occurring on their faster payments rail, which was designed to make payments immediate and irrevocable. The report concluded that consumers' experiences with reimbursement for APP scams were mixed. Some consumers were reimbursed by their financial institution after authorizing payments to scammers while others were unable to receive any reimbursements.
The primary payment instrument in the United States today for large-scale corporate APP scams is wire. For consumers, person-to-person (P2P) services such as CashApp, Venmo, and Zelle are being used to scam individuals out of money. All these payments, both business and consumer, are irrevocable. Once the payments leave their accounts, neither the financial institution nor service provider has liability. But should individuals in the United States, like those in the United Kingdom, be afforded protections for these wire and P2P payments if they're scammed? And should these protections also apply to newer real-time payment schemes here in the United States?
My personal belief is that financial institutions or P2P services should not be responsible for people who fall victim to APP scams. Their responsibility should be limited to educating their customers on the rules around these payments and their finality when executed. APP scams are often the result of social engineering campaigns, and I am of the thought that, just as I expect my children to accept personal responsibility for their mistakes, it's fair for consumers to accept their responsibility for making sure they do not become the next social engineering victim. Do you think this is a reasonable approach to these scams and payments? Or should the United States banking industry and regulators move toward a model like the United Kingdom has in place?
August 17, 2020
Executive Spoofing Hits Close to Home
Sitting around a table outdoors, physical distancing with my family, the conversation turns to executive spoofing scams at work.
- Millennial works at a factory automation start- up: "Yeah, right. The CEO is sending me an email [snicker]."
- Millennial working in government contracting: "I get them all the time, sometimes from the CFO."
- Boomer works in software industry: "We got a warning just the other day that one is floating around. Don't send money."
We are talking about three businesses with employees numbered in the low hundreds. All privately held. Small fry, really. Every one of my family considers executive spoofing via phishing to be an everyday, ho-hum event.
Everyday, yes. Ho-hum, not so much. The FBI reports that 114,702 victims of phishing and its cousins vishing, pharming, and smishing lost almost $60 billion in 2019. Phishing is executed via email; vishing, via phone call or voicemail; pharming, via bogus websites; and smishing, via text message. Perpetrators request personal information or money. In addition, business email compromise (BEC), the foundational criminal act for executive spoofing of the sort my family members describe, resulted in more than $1.7 billion in losses related to 24,000 incidents in 2019, reports the FBI. The Association for Financial Professionals (AFP), in a survey of Treasury and finance professionals, found that BEC was the source of six in 10 fraud attempts in 2020.
A number of vendors offer products that use machine learning to fight these forms of fraud. Machine learning holds promise for automatically detecting these attacks. Nevertheless, as with much automation, the human being is the important last line of defense. A few days after that family meal, I see a scam alert. The gist: never, never, never will the Atlanta Fed president text me with a request to purchase $500 in gift cards.
The late Intel CEO Andy Grove said it perfectly: "Success breeds complacency. Complacency breeds failure. Only the paranoid survive." So please don't be ho-hum or complacent about these attacks and warn your family members and others.
April 6, 2020
Will COVID-19 Exacerbate Ecommerce Fraud?
Ecommerce sales in the United States continue to gain a greater share of overall retail sales each year. The Department of Commerce reports that in 2019, total ecommerce sales increased almost 15 percent over 2018 and represented 11 percent of total retail sales. There is no question that with the current COVID-19 environment, our daily habits have undergone tremendous change. As part of that change, I expect that ecommerce sales will increase at a greater rate in 2020 than in 2019.
Following social isolation guidelines, consumers and businesses are turning more and more to conducting their commerce transactions online. Prepaid carry-out, drive-through, and delivery orders now dominate the dining industry as inside dining options have been largely shuttered. Large retailers have been promoting online ordering and ship-to-home delivery options as their stores are closed. TransUnion reports that in the week from March 11 to 17, when the World Health Organization classified COVID-19 as a global pandemic, ecommerce transaction volume increased 23 percent over the previous week.
This spike in ecommerce traffic will likely bring with it a parallel spike in criminal activity, possibly adding to the increasing fraud levels in ecommerce. This shouldn't come as any surprise. It will be important for the good guys not only to be expecting this but also to be prepared for it by making swift adjustments that match the challenge.
One of the key adjustments to consider and apply quickly is properly tuning algorithms for detecting ecommerce fraud. In normal times, anomalous-pattern detection schemes are relied on to expose fraudsters. Elements such as the type of stores commonly used, frequency of usage, average or range of transaction values, and more go into making up an overall usage pattern for a given customer. While these transaction risk models have become very sophisticated over the years, they are challenged by abrupt changes in usage patterns, especially at an individual account level. They need to be smartly and quickly adjusted. Issuers and merchants need to balance the decision of denying transactions—which brings with it the risk of disgruntled legitimate customers and lost revenues—against approving fraudulent transactions and taking financial losses. No easy task, but doable and necessary to undertake, with constant attention.
Working collaboratively with merchants, consumers can help to surprise the criminals as fraud fighting evolves. The good guys win if we exercise patience with one another and remain mindful of the balance between purchase friction and fraud avoidance as fraud-fighting tools and methods adjust. Both sides being considerate of the needs on both sides of the transaction—working together, again, with patience and willingness to engage, perhaps differently than we've been willing to in the past, could yield results that everyone (except the crooks) is happier with, in both the short run and long run.
We know fraud management teams will be busy managing their fraud-detection tools and processes and expect they will rise to the challenge. We also expect consumers are ready and willing to assist in ways that are helpful as well. The constant chess match with the criminal element will continue, and we look forward to seeing a chess piece on the good guys ' side of the board with some new moves to help aid in the fight against the bad guys.
March 30, 2020
Do We Use a Payments Risk Thermostat?
I read a blog post last week that is eerily evocative of the individual actions we take—or don't take—to protect our personal and payments information. You can read it here: Handwashing Can Stop a Virus—So Why Don't We Do it?
The blogger identifies some reasons we don't wash our hands as much—or as thoroughly—as we should, including lack of awareness and inconvenience.
- We are not aware that hand washing is so effective.
- We balk at the least inconvenience or practical barriers—for example, having to take a few extra steps to get to the soap and water.
Sounds a lot like the reasons people may cut corners on payments security. For example, people may not be aware of the efficacy of credit freezes, or they might find imposing them to be inconvenient. People may not be aware that it is not optimal to use the same password for multiple accounts, or they may consider it to be inconvenient to set up different passwords.
I think this paper positing a "risk thermostat" applies not only to handwashing but also to payments security. We use our risk thermostats to make tradeoffs, so taking one kind of preventive measure could increase our willingness to accept more risk in another way. The author writes: "individual risk taking decisions represent a balancing act in which perceptions of risk are weighed against propensity to take risk."
So, for example, maybe you start wearing gloves and stop washing your hands so carefully. (Don't do that, please.) Or maybe you put a credit freeze on your accounts at the major credit bureaus and stop watching your bank and card statements so carefully. (Don't do that, either.)
As these writers on behavioral science note, awareness is the first step. So be aware of payments and other financial risks facing your business and your customers during the coronavirus outbreak. Here are some resources you can use to educate your colleagues and customers:
- U.S. Secret Service : Watch out for phishing scams posing as medical or health providers, charity scams on social media.
- Federal Trade Commission (FTC): Ignore emails claiming to be from the CDC; ignore online offers for vaccinations.
- U.S. Securities and Exchange Commission Beware internet and social media promotions claiming that products or services "prevent, detect, or cure coronavirus" and that the stock of providing companies will increase in value.
As of March 16, the FTC and the Food and Drug Administration already have issued warning letters to seven sellers of unapproved and misbranded products.
Best wishes and good health to you and your families. Now, go wash your hands. And check your bank account when you're done.