R. Kinney Williams & Associates
R. Kinney Williams
& Associates

Internet Banking News

October 26, 2003

CONTENT Internet Compliance Information Systems Security
IT Security Question Internet Privacy Internet Auditing Services


FYI  -
IT Managers Concerned Over New Security Threats - The worldwide study, which was carried out for NetScreen by Vanson Bourne and took in responses from 1,300 managers during July and August, found that managers were most concerned about application-level attacks.  http://www.infosecnews.com/sgold/news/2003/10/22_04.htm 

FYI  - Posthearing Questions from the September 10, 2003, Hearing on Worm and Virus Defense: How Can We Protect Our Nation's Computers From These Serious Threats?  http://www.gao.gov/new.items/d04173r.pdf 

FYI  - Perils of unplugging: 11 steps to successful wireless security.  http://gcn.com/22_30/news/23832-1.html   


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INTERNET COMPLIANCEThe Role Of Consumer Compliance In Developing And Implementing Electronic Services from FDIC:

When violations of the consumer protection laws regarding a financial institution's electronic services have been cited, generally the compliance officer has not been involved in the development and implementation of the electronic services.  Therefore, it is suggested that management and system designers consult with the compliance officer during the development and implementation stages in order to minimize compliance risk.  The compliance officer should ensure that the proper controls are incorporated into the system so that all relevant compliance issues are fully addressed.  This level of involvement will help decrease an institution's compliance risk and may prevent the need to delay deployment or redesign programs that do not meet regulatory requirements.

The compliance officer should develop a compliance risk profile as a component of the institution's online banking business and/or technology plan.  This profile will establish a framework from which the compliance officer and technology staff can discuss specific technical elements that should be incorporated into the system to ensure that the online system meets regulatory requirements.  For example, the compliance officer may communicate with the technology staff about whether compliance disclosures/notices on a web site should be indicated or delivered by the use of "pointers" or "hotlinks" to ensure that required disclosures are presented to the consumer.  The compliance officer can also be an ongoing resource to test the system for regulatory compliance.


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INFORMATION SYSTEMS SECURITY
- We continue our series on the FFIEC interagency Information Security Booklet.  


SECURITY CONTROLS - IMPLEMENTATION

LOGICAL AND ADMINISTRATIVE ACCESS CONTROL 


Examples of Common Authentication Weaknesses, Attacks, and Offsetting Controls (Part 1 of 2)

All authentication methodologies display weaknesses. Those weaknesses are of both a technical and a nontechnical nature. Many of the weaknesses are common to all mechanisms. Examples of common weaknesses include warehouse attacks, social engineering, client attacks, replay attacks, and hijacking.

Warehouse attacks result in the compromise of the authentication storage system, and the theft of the authentication data. Frequently, the authentication data is encrypted; however, dictionary attacks make decryption of even a few passwords in a large group a trivial task. A dictionary attack uses a list of likely authenticators, such as passwords, runs the likely authenticators through the encryption algorithm, and compares the result to the stolen, encrypted authenticators. Any matches are easily traceable to the pre-encrypted authenticator.

Dictionary and brute force attacks are viable due to the speeds with which comparisons are made. As microprocessors increase in speed, and technology advances to ease the linking of processors across networks, those attacks will be even more effective. Because those attacks are effective, institutions should take great care in securing their authentication databases. Institutions that use one - way hashes should consider the insertion of secret bits (also known as "salt") to increase the difficulty of decrypting the hash. The salt has the effect of increasing the number of potential authenticators that attackers must check for validity, thereby making the attacks more time consuming and creating more opportunity for the institution to identify and react to the attack.

Warehouse attacks typically compromise an entire authentication mechanism. Should such an attack occur, the financial institution might have to deny access to all or nearly all users until new authentication devices can be issued (e.g. new passwords). Institutions should consider the effects of such a denial of access, and appropriately plan for largescale re - issuances of authentication devices.


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IT SECURITY QUESTION:

B. NETWORK SECURITY

15. Determine whether appropriate controls exist over the confidentiality and integrity of data transmitted over the network (e.g. encryption, parity checks, message authentication).

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INTERNET PRIVACY
- We continue our series listing the regulatory-privacy examination questions.  When you answer the question each week, you will help ensure compliance with the privacy regulations.

Content of Privacy Notice


12. Does the institution make the following disclosures regarding service providers and joint marketers to whom it discloses nonpublic personal information under §13:

a. as applicable, the same categories and examples of nonpublic personal information disclosed as described in paragraphs (a)(2) and (c)(2) of section six (6) (see questions 8b and 10); and [§6(c)(4)(i)]

b. that the third party is a service provider that performs marketing on the institution’s behalf or on behalf of the institution and another financial institution; [§6(c)(4)(ii)(A)] or

c. that the third party is a financial institution with which the institution has a joint marketing agreement? [§6(c)(4)(ii)(B)]


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INTERNET AUDITING SERVICESR. Kinney Williams & Associates is recognized as a leader in independent Internet auditing for financial institutions.  With clients in 37 states, and an outstanding record of successful expedient testing, R. Kinney Williams & Associates is your ideal choice as an independent entity to perform your penetration assessment study, which includes the Vulnerability Internet Security Test Audit (VISTA).  You will find information about VISTA at  http://www.internetbankingaudits.com/ or email Kinney Williams at examiner@yennik.com.

 

PLEASE NOTE:  Some of the above links may have expired, especially those from news organizations.  We may have a copy of the article, so please e-mail us at examiner@yennik.com if we can be of assistance.  

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