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.
By David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
April 07, 2014
Learning from Experience to Handle Suspicious Payment Transactions
In a post earlier this year, we addressed the difficulty of identifying and tracking remotely created checks (RCCs) in the payments stream. Electronic payment orders (EPOs), which are electronic images of "checks" that never exist in paper form, are another payment vehicle difficult to identify and track. EPOs can be created by the payee as an image of an RCC, or created and electronically signed by the payer.
Financial institutions have to address all suspicious payment transactions, whether they occur with traditional payments, like checks and ACH or these new variants, the RCCs and EPOs. Institutions rely on a variety of ways to become aware of suspicious payment transactions:
- The institution's anomaly detection processes highlight transaction patterns that are atypical for a customer.
- A bank customer contacts the bank after identifying an unauthorized transaction on the bank statement.
- Consumer complaints about a business suddenly increase.
- Another institution contacts the bank with concerns about a particular business.
- The bank becomes aware of legal actions taken against a business.
- Returns for a business's payment transactions increase.
Regardless of payment type, institutions can apply the simple approach in this diagram to handling suspicious payment transactions.
When an institution becomes aware of suspicious transactions, its first step is to take care of the customer. This may include returning transactions, placing stop payments, monitoring account activity, addressing security protocols, or changing authentication tools.
The next step would be to reach out to other institutions, law enforcement, and regulators. Other institutions may not be aware of the issue and can assist with resolving the customer’s concern and addressing the underlying cause of the problem. Support for information sharing between financial institutions includes the safe harbor provisions within Section 314(b) of the U.S. Patriot Act. Submitting suspicious activity reports, or SARs, and contacting appropriate law enforcement such as the local police or FBI enables law enforcement to address fraudulent behavior, monitor the extent of the fraud, and address areas of concern that are affecting multiple institutions. Information-sharing groups, such as the Financial Services Information Sharing and Analysis Center (FS-ISAC) and BITS, are other important avenues.
Critical to the approach is the importance of the affected institution consistently adjusting its identification processes based on its experiences with suspicious transactions. For example, if the anomaly detection system has default settings for origination volume or return rates, and the institution learns that those settings were ineffective in identifying a problem, then the institution should adjust the settings.
As the payments industry continues to evolve, with newer payment types such as RCCs and EPOs, criminals will find new ways to use them to their benefit. And as perpetrators of fraudulent payments adjust their approaches, a financial institution must also be a "learning" institution and adjust its approach to identifying the suspicious payments.
How often does your institution adjust its processes for handling suspicious transactions based on current fraud experiences?
By Deborah Shaw, a payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
March 31, 2014
Ignore Millennials at Your Own Risk
At a recent conference primarily for credit unions and small banks, I participated in an interesting discussion about the future role of banks and legacy payments for person-to-person (P2P) payments. Few of the attendants offered a P2P solution as part of their online or mobile banking platform and those that did claimed the product was seldom used, if at all. There was consensus that a majority of their customers just aren't interested in this product.
I recently wrote on this topic, hailing the check as an efficient form of P2P payment thanks in large part to mobile remote deposit capture. But perhaps my experience of writing a check to a 20-something babysitter was more of an anomaly than the norm. A recent survey that GOBanking Rates conducted reveals that nearly 40 percent of consumer banking customers never write checks and 61 percent of banking customers between the ages of 18 and 24 claim to never write checks. Another survey of 10,000 millennials (those born from 1981 to 2000) reveals that the banking industry is at the highest risk of disruption. Seventy percent of the respondents believe that the way we pay for things in five years will be totally different. One in three of the respondents believe they will not need a bank.
So what can financial institutions take away from my experience and these surveys? Two things stand out to me. First, there are still banking customers (young ones included) that continue to write checks or prefer to receive checks over alternatives from banks and nonbanks. Though I fully expect check usage to continue to decline, the complete demise of the check is a fantasy. Second, and most important, financial institutions that choose not to evolve in the payments space risk disintermediation or even becoming irrelevant. While their customers today may not want specific products or payment capabilities, the reality is that the makeup of a majority of these customers today won't be the same as in the future. A generation of potentially new customers has a very different view on payments and banking. Ignoring these future customers will lead to harsh realities for financial institutions. What is your institution doing in terms of payments to attract and keep millennials and avoid becoming a dinosaur?
By Douglas A. King, payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed
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.
By David Lott, a retail payments risk expert in the Retail Payments Risk Forum at the Atlanta Fed