http://www.ffiec.gov/pdf/Auth-ITS-Final%206-22-11%20(FFIEC%20Formated).pdf

FFIEC Agency Supplement to FFIEC Agency Supplement to Authentication in an Internet Banking Authentication in an Internet Banking

EnvironmentEnvironment

Released: June 2011

Review and Update: As new information becomes available Prior to implementing new services At least every 12 months

Consider the following: Changes in threat environment Changes in membership base Changes in functionality Actual incidents of breach and fraud

Risk AssessmentRisk Assessment

Defined as: Electronic transactions involving access to member information or the movement of funds to other parties. Not every online transaction poses the same level of risk.

Consumer online banking Layered Security

Commercial online banking Layered Security AND Multifactor authentication.

High-Risk High-Risk TransactionsTransactions

Effective Controls include: Fraud detection and monitoring systems Use of dual member authorization Use of out-of-band verification Use of positive pay and debit blocks Enhanced controls over activities Block connection to IP address known for fraud Address member devices identified as compromised Enhanced control over maintenance activities Enhanced member education

Layered SecurityLayered Security

Detect and Respond to Suspicious Activity At initial log-in and authentication At initiation of transfer to other parties

Controls for Admin functions-Business Accounts Additional authentication routine

Layered Security Layered Security ProgramsPrograms

Device Identification Simple – i.e. Cookies Sophisticated – i.e. Digital fingerprint

Challenge Question Basic Questions Out of Wallet Questions

Effectiveness of Effectiveness of TechniquesTechniques

Increase awareness and mitigate risk

Include business and personal account holders

Include: Protections under Regulation E When the CU would contact member for credentials Suggest commercial members perform Risk Assessment Mechanisms to mitigate risk List of CU contacts for members use

Member Awareness and EducationMember Awareness and Education