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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.

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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.

National Cybersecurity Awareness Month bannerOctober 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?

May 20, 2019

Could Federal Privacy Law Happen in 2019?

Some payments people have suggested that this could be the year for mobile payments to take off. My take? Nah. I gave up on that thought several years ago, as I've made clear in some of my previous posts. I'm actually wondering if this will be the year that federal privacy legislation is enacted in the United States. The effects of the European Union's General Data Protection Regulation (GDPR) that took effect a year ago (see this Take on Payments post) are being felt in the United States and across the globe. The GDPR essentially has created a global standard for how companies should protect citizens' personal data and the rights of everyone to understand what data is being collected as well as how to opt out of this collection. While technically the GDPR applies only to EU citizens, even when traveling outside the European Union, most businesses have taken a cautious approach and are treating every transaction—financial or informational—that they process as something that could be covered under the GDPR.

A tangible impact of the GDPR in the United States is that the state of California has passed a data privacy law known as the California Consumer Privacy Act of 2018Off-site link (CCPA) that is partly patterned after the GDPR. The CCPA gives California residents five basic rights related to data privacy:

  • The right to know what personal information a business has collected about them, where it was obtained, how it is being used, and whether it is being disclosed or sold to other parties and, if so, to whom it is being disclosed or sold
  • The right to access that personal information free of charge up to two times within a 12-month period
  • The right to opt out of allowing a business to sell their personal information to third parties
  • The right to have a business delete their personal information, except for information that is required to effect a transaction or comply with other regulatory requirements.
  • The right to receive equal service and pricing from a business, even if they have exercised their privacy rights under the CCPA.

According to the National Conference of State Legislatures (NCSL) 17 statesOff-site link have mandated that their governmental websites and access portals state privacy policies and procedures. Additionally, other states have privacy laws related to privacy, such as children's online privacy, the monitoring of employee email, and e-reader policies.

Take On Payments has previously discussed the numerous efforts to introduce federal legislation regarding privacy and data breach notification with little traction. So why do I think change is in the air? The growing trend of states implementing privacy legislation is putting pressure on Congress to take action in order to have a consistent national policy and process that businesses operating across state lines can understand and follow.

What do you think?

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

-payments">Retail Payments Risk Forum at the Atlanta Fed

May 6, 2019

Business Email Compromise Moves Mainstream

The Retail Payments Risk Forum has blogged extensively on business email compromise (BEC) over the past few years. With losses attributed to BEC already in the billions of dollars and the number of attacks increasing over 475 percent from fourth-quarter 2017 to fourth-quarter 2018, the topic warrants continued attention. As the "business email" part of the phrase suggests, businesses and executives of businesses have been the primary targets of this type of fraud. The goal of most of these incidents is to trick businesses into moving funds into the criminals' accounts using wire transfers.

When perpetrators of this fraud scheme experienced great success with businesses and executives as their primary targets, they quickly moved to include ordinary individuals. That is, the fraud has gone mainstream, evolving beyond businesses and executives with wire transfers as the key payment platform. As the scheme has begun to involve employees as victims and reached the person-to-person payment arena, fraudulent transactions are occurring more often using ACH, not just wire transfers. Since BEC is not just for businesses and their executives anymore, BEC is sometimes more aptly referred to as EAC—that is, email account compromise.

In April, CNBC reported a new scheme whereby the fraudsters are targeting the human resources function of businesses to change employees' direct deposit payroll information to an account held by the fraudster. The fraudster either spoofs an employee's email account or gets access to it and then sends a message to human resources requesting a change to the banking account associated with their direct deposit. While the amounts fraudulently transferred in this scheme are generally well below those of the traditional BEC scheme, they are simple and cheap to execute and could become more attractive for criminals.

In more troubling news on this fraud scheme, the Association for Financial Professionals (AFP) reported that the number of businesses reporting that they had been victims of actual or attempted fraud increased significantly for both ACH credit and debit transactions, while instances of fraud involving checks, cards, and wire transfers declined. And what could be the reason behind this increase in ACH fraud? According to a representative with the AFP, "a likely explanation for the higher fraud lies in the popularity of ACH…for schemes like business email fraud."

And as I mentioned earlier, fraudsters aren't limiting this scheme to businesses. In fact, I was a target of an EAC scam earlier this year when fraudsters took control of a relative's email account. But for a bit of good news (at least for me), I was immediately suspicious and a phone call to the relative confirmed that my gut feeling was accurate. This image is a screenshot of the text conversation I had with my "relative."

IM screenshot

To piggyback on a recent post by my colleague on using discipline to fight BEC: having the discipline to make a follow-up call to the person emailing a request for funds or a change to bank account information can make the difference between being a victim and being a spoiler.

How are you attacking this growing threat, and what are you doing to educate your employees and customers?

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.

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