Tag Archives: banking

New AWS whitepaper: AWS User Guide for Federally Regulated Financial Institutions in Canada

Post Syndicated from Dan MacKay original https://aws.amazon.com/blogs/security/new-aws-whitepaper-aws-user-guide-for-federally-regulated-financial-institutions-in-canada/

Amazon Web Services (AWS) has released a new whitepaper to help financial services customers in Canada accelerate their use of the AWS Cloud.

The new AWS User Guide for Federally Regulated Financial Institutions in Canada helps AWS customers navigate the regulatory expectations of the Office of the Superintendent of Financial Institutions (OSFI) in a shared responsibility environment. It is intended for OSFI-regulated institutions that are looking to run material workloads in the AWS Cloud, and is particularly useful for leadership, security, risk, and compliance teams that need to understand OSFI requirements and guidance applicable to the use of AWS services.

This whitepaper summarizes OSFI’s expectations with respect to Technology and Cyber Risk Management (OSFI Guideline B-13). It also gives OSFI-regulated institutions information that they can use to commence their due diligence and assess how to implement the appropriate programs for their use of AWS Cloud services. In subsequent versions of the whitepaper, we will provide considerations for other OSFI guidelines as applicable.

In addition to this whitepaper, AWS provides updates on the evolving Canadian regulatory landscape on the AWS Security Blog and the AWS Compliance page. Customers looking for more information on cloud-related regulatory compliance in different countries around the world can refer to the AWS Compliance Center. For additional resources or support, reach out to your AWS account manager or contact us here.

If you have feedback about this post, submit comments in the Comments section below. If you have questions about this post, contact AWS Support.

Dan MacKay

Dan MacKay

Dan is the Financial Services Compliance Specialist for AWS Canada. He advises financial services customers on best practices and practical solutions for cloud-related governance, risk, and compliance. Dan specializes in helping AWS customers navigate financial services and privacy regulations applicable to the use of cloud technology in Canada with a focus on third-party risk management and operational resilience.

Dave Trieu

Dave Trieu

Dave is an AWS Solutions Architect Manager with over two decades in the tech industry. He excels in guiding organizations through modernization and using cloud technologies for transformation. Dave helps businesses navigate the digital landscape and maintain a competitive edge by crafting and implementing cutting-edge solutions that address immediate business needs while anticipating future trends.

CFPB’s Proposed Data Rules

Post Syndicated from Bruce Schneier original https://www.schneier.com/blog/archives/2024/01/cfpbs-proposed-data-rules.html

In October, the Consumer Financial Protection Bureau (CFPB) proposed a set of rules that if implemented would transform how financial institutions handle personal data about their customers. The rules put control of that data back in the hands of ordinary Americans, while at the same time undermining the data broker economy and increasing customer choice and competition. Beyond these economic effects, the rules have important data security benefits.

The CFPB’s rules align with a key security idea: the decoupling principle. By separating which companies see what parts of our data, and in what contexts, we can gain control over data about ourselves (improving privacy) and harden cloud infrastructure against hacks (improving security). Officials at the CFPB have described the new rules as an attempt to accelerate a shift toward “open banking,” and after an initial comment period on the new rules closed late last year, Rohit Chopra, the CFPB’s director, has said he would like to see the rule finalized by this fall.

Right now, uncountably many data brokers keep tabs on your buying habits. When you purchase something with a credit card, that transaction is shared with unknown third parties. When you get a car loan or a house mortgage, that information, along with your Social Security number and other sensitive data, is also shared with unknown third parties. You have no choice in the matter. The companies will freely tell you this in their disclaimers about personal information sharing: that you cannot opt-out of data sharing with “affiliate” companies. Since most of us can’t reasonably avoid getting a loan or using a credit card, we’re forced to share our data. Worse still, you don’t have a right to even see your data or vet it for accuracy, let alone limit its spread.

The CFPB’s simple and practical rules would fix this. The rules would ensure people can obtain their own financial data at no cost, control who it’s shared with and choose who they do business with in the financial industry. This would change the economics of consumer finance and the illicit data economy that exists today.

The best way for financial services firms to meet the CFPB’s rules would be to apply the decoupling principle broadly. Data is a toxic asset, and in the long run they’ll find that it’s better to not be sitting on a mountain of poorly secured financial data. Deleting the data is better for their users and reduces the chance they’ll incur expenses from a ransomware attack or breach settlement. As it stands, the collection and sale of consumer data is too lucrative for companies to say no to participating in the data broker economy, and the CFPB’s rules may help eliminate the incentive for companies to buy and sell these toxic assets. Moreover, in a free market for financial services, users will have the option to choose more responsible companies that also may be less expensive, thanks to savings from improved security.

Credit agencies and data brokers currently make money both from lenders requesting reports and from consumers requesting their data and seeking services that protect against data misuse. The CFPB’s new rules—and the technical changes necessary to comply with them—would eliminate many of those income streams. These companies have many roles, some of which we want and some we don’t, but as consumers we don’t have any choice in whether we participate in the buying and selling of our data. Giving people rights to their financial information would reduce the job of credit agencies to their core function: assessing risk of borrowers.

A free and properly regulated market for financial services also means choice and competition, something the industry is sorely in need of. Equifax, Transunion and Experian make up a longstanding oligopoly for credit reporting. Despite being responsible for one of the biggest data breaches of all time in 2017, the credit bureau Equifax is still around—illustrating that the oligopolistic nature of this market means that companies face few consequences for misbehavior.

On the banking side, the steady consolidation of the banking sector has resulted in a small number of very large banks holding most deposits and thus most financial data. Behind the scenes, a variety of financial data clearinghouses—companies most of us have never heard of—get breached all the time, losing our personal data to scammers, identity thieves and foreign governments.

The CFPB’s new rules would require institutions that deal with financial data to provide simple but essential functions to consumers that stand to deliver security benefits. This would include the use of application programming interfaces (APIs) for software, eliminating the barrier to interoperability presented by today’s baroque, non-standard and non-programmatic interfaces to access data. Each such interface would allow for interoperability and potential competition. The CFPB notes that some companies have tried to claim that their current systems provide security by being difficult to use. As security experts, we disagree: Such aging financial systems are notoriously insecure and simply rely upon security through obscurity.

Furthermore, greater standardization and openness in financial data with mechanisms for consumer privacy and control means fewer gatekeepers. The CFPB notes that a small number of data aggregators have emerged by virtue of the complexity and opaqueness of today’s systems. These aggregators provide little economic value to the country as a whole; they extract value from us all while hindering competition and dynamism. The few new entrants in this space have realized how valuable it is for them to present standard APIs for these systems while managing the ugly plumbing behind the scenes.

In addition, by eliminating the opacity of the current financial data ecosystem, the CFPB is able to add a new requirement of data traceability and certification: Companies can only use consumers’ data when absolutely necessary for providing a service the consumer wants. This would be another big win for consumer financial data privacy.

It might seem surprising that a set of rules designed to improve competition also improves security and privacy, but it shouldn’t. When companies can make business decisions without worrying about losing customers, security and privacy always suffer. Centralization of data also means centralization of control and economic power and a decline of competition.

If this rule is implemented it will represent an important, overdue step to improve competition, privacy and security. But there’s more that can and needs to be done. In time, we hope to see more regulatory frameworks that give consumers greater control of their data and increased adoption of the technology and architecture of decoupling to secure all of our personal data, wherever it may be.

This essay was written with Barath Raghavan, and was originally published in Cyberscoop.

PIN-Stealing Android Malware

Post Syndicated from Bruce Schneier original https://www.schneier.com/blog/archives/2024/01/pin-stealing-android-malware.html

This is an old piece of malware—the Chameleon Android banking Trojan—that now disables biometric authentication in order to steal the PIN:

The second notable new feature is the ability to interrupt biometric operations on the device, like fingerprint and face unlock, by using the Accessibility service to force a fallback to PIN or password authentication.

The malware captures any PINs and passwords the victim enters to unlock their device and can later use them to unlock the device at will to perform malicious activities hidden from view.

New York Increases Cybersecurity Rules for Financial Companies

Post Syndicated from Bruce Schneier original https://www.schneier.com/blog/archives/2023/11/new-york-increases-cybersecurity-rules-for-financial-companies.html

Another example of a large and influential state doing things the federal government won’t:

Boards of directors, or other senior committees, are charged with overseeing cybersecurity risk management, and must retain an appropriate level of expertise to understand cyber issues, the rules say. Directors must sign off on cybersecurity programs, and ensure that any security program has “sufficient resources” to function.

In a new addition, companies now face significant requirements related to ransom payments. Regulated firms must now report any payment made to hackers within 24 hours of that payment.

Credit Card Fraud That Bypasses 2FA

Post Syndicated from Bruce Schneier original https://www.schneier.com/blog/archives/2022/09/credit-card-fraud-that-bypasses-2fa.html

Someone in the UK is stealing smartphones and credit cards from people who have stored them in gym lockers, and is using the two items in combination to commit fraud:

Phones, of course, can be made inaccessible with the use of passwords and face or fingerprint unlocking. And bank cards can be stopped.

But the thief has a method which circumnavigates those basic safety protocols.

Once they have the phone and the card, they register the card on the relevant bank’s app on their own phone or computer. Since it is the first time that card will have been used on the new device, a one-off security passcode is demanded.

That verification passcode is sent by the bank to the stolen phone. The code flashes up on the locked screen of the stolen phone, leaving the thief to tap it into their own device. Once accepted, they have control of the bank account. They can transfer money or buy goods, or change access to the account.

A pathway to the cloud: Analysis of the Reserve Bank of New Zealand’s Guidance on Cyber Resilience

Post Syndicated from Julian Busic original https://aws.amazon.com/blogs/security/a-pathway-to-the-cloud-analysis-of-the-reserve-bank-of-new-zealands-guidance-on-cyber-resilience/

The Reserve Bank of New Zealand’s (RBNZ’s) Guidance on Cyber Resilience (referred to as “Guidance” in this post) acknowledges the benefits of RBNZ-regulated financial services companies in New Zealand (NZ) moving to the cloud, as long as this transition is managed prudently—in other words, as long as entities understand the risks involved and manage them appropriately. In this blog post, I analyze the RBNZ’s thinking as it developed the Guidance, and how the Guidance creates opportunities for NZ financial services customers to accelerate migration of workloads—including critical systems—to the Amazon Web Services (AWS) Cloud.

On page 14 of its Guidance, the RBNZ writes that “[i]f used prudently, third-party services may reduce an entity’s cyber risk, especially for those entities that lack cyber expertise.” This open regulatory stance towards the cloud enables our NZ financial services customers to consider a cloud first strategy for both new and existing systems, including critical workloads. Customers must, however, manage the transition to the cloud prudently, working closely with both their cloud service provider and their regulators.

This blog post is aimed at boards, management, and technology decision-makers, for whom understanding regulatory thinking is a useful input when developing an enterprise cloud strategy.

Operational technology staff and risk practitioners seeking detailed guidance on how AWS helps you align with the RBNZ’s Guidance can download our New Zealand Financial Services whitepaper from our public website and the AWS Reserve Bank of New Zealand Guidance on Cyber Resilience (RBNZ-GCR) Workbook from AWS Artifact, a self-service portal for you to access AWS compliance reports.

Overview and applicability

The RBNZ’s Guidance sets out the RBNZ’s expectations for management of cyber resilience. It’s aimed at all registered banks, licensed non-bank deposit takers, licensed insurers, and designated financial market infrastructures that are regulated by the RBNZ. The Guidance makes a series of non-binding recommendations across four domains—Governance, Capability Building, Information Sharing, and Third-Party Management.

Each section of the Guidance has a short preamble, summarizing the RBNZ’s expectations for effective risk management in each domain and providing insights into why the RBNZ is making specific recommendations.

The Guidance can be tailored to an entity’s individual needs, technology choices, and risk appetite. Boards, management, and technology decision-makers should familiarize themselves with the RBNZ’s Guidance, ascertain how closely their own organization aligns to it, and work to remediate any identified gaps.

Why non-binding guidance and not an enforceable standard?

The RBNZ gives several reasons (see RBNZ Summary of submissions, paragraphs 9-16) for choosing to publish non-binding recommendations rather than legally binding requirements. The RBNZ declares an intent to monitor adoption of its recommendations by industry, and indicates that future policy settings might include developing legally binding standards for cyber resilience. In this respect, the RBNZ’s approach is similar to that of the Australian Prudential Regulation Authority (APRA), which first issued non-binding guidance on management of IT security risk in 2013, before moving to a legally binding standard in 2019.

The RBNZ gives the following reasons for choosing guidance over a standard:

  • The RBNZ’s policy stance of being moderately active in respect to cyber resilience
  • A previous light-touch approach regarding cyber resilience
  • Providing sufficient time for industry to adjust to new policy settings, given the wide range of maturity within financial services organizations in New Zealand
  • The gap between New Zealand’s and other jurisdictions’ cyber readiness
  • The RBNZ’s current ability to effectively monitor and ensure compliance

The RBNZ indicates that it will “work together with the industry to operationalise the finalised Guidance” (RBNZ Summary of submissions, paragraph 10) and that it is “looking to strengthen [its] cyber resilience expertise in [its] financial stability function” although this will “take time to achieve” (RBNZ Summary of submissions, paragraph 9).

RBNZ-regulated entities should already be self-assessing against the Guidance and working to address gaps as a matter of priority. This is not just because the Guidance could become a legally binding standard in the next 3–5 years, but because the RBNZ has created a practical and flexible framework for the management of cyber risk, which will greatly enhance the NZ financial sector’s resilience to cyber incidents. Non–RBNZ-regulated entities looking for a benchmark to measure themselves against can also use the RBNZ’s Guidance to assess and improve the effectiveness of their own control environments.

Comparing rules-based frameworks and principles-based frameworks

There are two main ways that regulators communicate their risk management expectations to their regulated entities. These are a rules-based approach (sometimes called a compliance-based approach) and a principles-based approach. The RBNZ’s Guidance takes a principles-based approach towards the management of cyber risk.

With a rules-based approach, the regulator takes responsibility for identifying risks and lays out explicit and granular controls that regulated entities are required to implement. A rules-based approach is highly prescriptive, meaning that regulated entities can adopt a checklist approach in meeting their regulators’ requirements. This approach, although it gives certainty to regulated entities regarding the controls they are expected to adopt, can have disadvantages for regulators:

  • Creating and maintaining detailed technical rules can be challenging, given the pace at which technology and the threat environment evolve.
  • Regulators have a diverse population of regulated entities, so a rules-based approach can be inflexible or have blind spots.
  • A rules-based approach doesn’t encourage entities to actively identify and manage their own unique set of risks.

By contrast, a principles-based approach describes a set of desired regulatory or risk-management outcomes, but it isn’t prescriptive in how regulated entities achieve these goals. Regulators act in a vendor- and technology-neutral manner, and regulated entities are expected to interpret regulatory requirements or guidance in the context of their individual business models, technology choices, threat environments, and risk appetites.

Under a principles-based approach, an entity must be able to demonstrate to its regulators’ satisfaction that it both understands the current and emerging risks it faces, and that it is managing these risks appropriately. For example, the principle that entities “[…] should develop and maintain a programme for continuing cyber resilience training for staff at all levels” (Guidance, section A3.3 page 6) gives clear direction, but leaves it up to the entity to decide on the approach to take, and how the entity will demonstrate to the RBNZ that this principle is being met.

A principles-based approach avoids the issues with the rules-based approach that I outlined previously—this approach is significantly longer-lived than a rules-based approach, it moves responsibility for effective risk identification and management from the regulator to the entity (which better understands its own risk profile and appetite), and the framework can be applied to a regulated entity population that varies in size, nature, and complexity.

Freedom to innovate under a principles-based approach

The RBNZ says that its Guidance should be employed in a manner “[…] proportionate to the size, structure and operational environment of an entity, as well as the nature, scope, complexity and risk profile of its products and services” (Guidance, page 2).

You can therefore meet the RBNZ’s Guidance in many different ways, as long as you can demonstrate to the RBNZ that your organization understands the risks it is facing and is managing them appropriately. A principles-based approach creates opportunities for innovation, because there are many different ways to meet a set of regulatory principles.

If you are an NZ financial services customer who also operates in Australia, you might note that the RBNZ’s approach aligns to that of the principal financial services regulator in Australia—the Australian Prudential Regulation Authority (APRA). APRA also takes a principles-based approach to its prudential framework, “avoiding excessive prescription where possible to allow for the diversity of practice according to the size, business activity, and sophistication of the institutions being supervised” (APRA’s objectives, Chapter 1).

A cautious green light to the cloud for New Zealand financial services

“If used prudently, third-party services may reduce an entity’s cyber risk, especially for those entities that lack cyber expertise” (Guidance, page 14).

In my view, this statement represents a (cautious) green light for financial services customers in NZ who wish to migrate systems to the AWS Cloud, although as the RBNZ makes clear, you “should be fully aware of the cyber risk associated with third parties and act appropriately to mitigate that risk” (Guidance, page 14). The RBNZ also requests that for critical functions, entities “[…] should inform the Reserve Bank about their outsourcing of critical functions to cloud service providers early in their decision-making process” (Guidance, Section D8.1, page 17).

The RBNZ defines a critical function as “[a]ny activity, function, process, or service, the loss of which (for even a short period of time) would materially affect the continued operation of an entity, the market it serves and the broader financial system, and/or materially affect the data integrity, reputation of an entity and confidence in the financial system” (Guidance, page 19).

Although the RBNZ doesn’t elaborate further on why it requests early notification about outsourcing of critical functions to the cloud, it’s likely that early engagement is requested so that the RBNZ has the opportunity to provide early feedback on any areas of potential concern, before the initiative is significantly progressed and a large amount of resources are committed.

Migration of higher-risk workloads to the cloud will naturally attract higher levels of regulatory scrutiny, but this doesn’t change the RBNZ’s open regulatory stance on cloud security. This stance is further emphasized by the RBNZ’s comment that “If managed prudently, migrating to the cloud presents a number of benefits including geographically dispersed infrastructures, agility to scale more quickly, improved automation, sufficient redundancy, and reduced initial investment costs for individual financial institutions” (Guidance, page 15).

Building innovative, secure, and highly resilient solutions on AWS, and using the high levels of visibility that you have into your environments that are running on AWS, can help you demonstrate to your regulators how you are identifying and managing your cyber resilience risks in line with the RBNZ’s Guidance.

A note on regulatory myths

In conversations with customers, I occasionally encounter “regulatory myths,” such as “certain types of workloads are prohibited in the cloud,” or “my regulator won’t allow me to use multi-region architectures.”

To date, the RBNZ has not made specific recommendations or set specific requirements regarding technology solutions. This includes, but is not limited to, choice of vendors or technology platforms, prescription of particular architectures, or the types of workload that may or may not be migrated to the cloud. Remember, the RBNZ’s Guidance is a principles-based framework, and is vendor-, technology-, and solution-neutral.

We have many examples of financial services companies all over the world successfully running critical workloads in the AWS Cloud, but regulatory myths and misunderstandings can inhibit our customers’ ability to “think big” when developing their cloud strategies. If you believe that you must implement specific technical patterns to meet regulatory expectations, we encourage you to contact the RBNZ to discuss any aspects of the Guidance that require clarification. We also encourage you to contact your AWS account team, who can arrange support from internal AWS risk and regulatory specialists, particularly if critical systems are proposed for migration to AWS.

Conclusion

The RBNZ’s Guidance on Cyber Resilience is an important first step for financial services regulation of cybersecurity in NZ. The Guidance can be considered cloud friendly because it acknowledges that prudent use of third parties (such as AWS) can reduce cyber risk, especially for entities that lack cyber expertise, and outlines several benefits of the cloud over traditional on-premises infrastructure, including resilience and redundancy, ability to scale, and reduced initial investment costs.

The principles-based nature of the RBNZ’s Guidance creates opportunities for you to develop innovative solutions in the AWS Cloud, because there are many different ways to meet the principles contained in the RBNZ’s Guidance. The key consideration is that you demonstrate to your regulators that you both understand the cyber risks you face in moving to the AWS Cloud, and manage them appropriately.

The launch of the AWS Asia Pacific (Auckland) Region in 2024, our wide range of products and services, and the visibility that you have into the AWS control environment (through AWS Artifact) and your own environment (through services like Amazon GuardDuty and AWS Security Hub) can all help you demonstrate to the RBNZ that you are managing cyber risk in accordance with the RBNZ’s expectations.

Next steps

Boards, executives, and technology decision-makers should familiarize themselves with the RBNZ’s Guidance, and if they aren’t already doing so, conduct a self-assessment and initiate a body of work to address identified gaps.

In view of the RBNZ’s cautious green light for prudent migration to the cloud—including for critical systems—NZ financial services customers should review their existing cloud strategies and identify areas where they can both broaden and accelerate their cloud journeys. The AWS Cloud Adoption Framework (AWS CAF) offers guidance and best practices to help organizations develop an efficient and effective plan for their cloud adoption journey. The AWS C-suite Guide to Shared Responsibility for Cloud Security and Data Safe Cloud eBook inform boards and senior management about both the benefits and risks of operating in the cloud.

Operational technology staff and risk practitioners can download our New Zealand Financial Service whitepaper from our public website and the AWS Reserve Bank of New Zealand Guidance on Cyber Resilience (RBNZ-GCR) Workbook from AWS Artifact. The RBNZ-GCR is particularly useful for operational IT staff and risk practitioners because it provides prescriptive guidance on which controls to implement on your side of the shared responsibility model and which AWS controls you inherit from the service.

Finally, contact your AWS representative to discuss how the AWS Partner Network, AWS solution architects, AWS Professional Services teams, and AWS Training and Certification can assist with your cloud adoption journey. If you don’t have an AWS representative, contact us at https://aws.amazon.com/contact-us.

 
If you have feedback about this post, submit comments in the Comments section below. If you have questions about this post, contact AWS Support.

Want more AWS Security news? Follow us on Twitter.

Author

Julian Busic

Julian is a Security Solutions Architect with a focus on regulatory engagement. He works with our customers, their regulators, and AWS teams to help customers raise the bar on secure cloud adoption and usage. Julian has over 15 years of experience working in risk and technology across the financial services industry in Australia and New Zealand.

New AWS whitepaper: AWS User Guide to Financial Services Regulations and Guidelines in New Zealand

Post Syndicated from Julian Busic original https://aws.amazon.com/blogs/security/new-aws-whitepaper-aws-user-guide-to-financial-services-regulations-and-guidelines-in-new-zealand/

Amazon Web Services (AWS) has released a new whitepaper to help financial services customers in New Zealand accelerate their use of the AWS Cloud.

The new AWS User Guide to Financial Services Regulations and Guidelines in New Zealand—along with the existing AWS Workbook for the RBNZ’s Guidance on Cyber Resilience—continues our efforts to help AWS customers navigate the regulatory expectations of the Reserve Bank of New Zealand (RBNZ) in a shared responsibility environment.

This whitepaper is intended for RBNZ-regulated institutions that are looking to run material workloads in the AWS Cloud, and is particularly useful for leadership, security, risk, and compliance teams that need to understand RBNZ requirements and guidance.

The whitepaper summarizes RBNZ requirements and guidance related to outsourcing, cyber resilience, and the cloud. It also gives RBNZ-regulated institutions information they can use to commence their due diligence and assess how to implement the appropriate programs for their use of AWS cloud services.

This document joins existing guides for other jurisdictions in the Asia Pacific region, such as Australia, India, Singapore, and Hong Kong. As the regulatory environment continues to evolve, we’ll provide further updates on the AWS Security Blog and the AWS Compliance page. You can find more information on cloud-related regulatory compliance at the AWS Compliance Center. You can also reach out to your AWS account manager for help finding the resources you need.

 
If you have feedback about this post, submit comments in the Comments section below. If you have questions about this post, contact AWS Support.

Want more AWS Security news? Follow us on Twitter.

Author

Julian Busic

Julian is a Security Solutions Architect with a focus on regulatory engagement. He works with our customers, their regulators, and AWS teams to help customers raise the bar on secure cloud adoption and usage. Julian has over 15 years of experience working in risk and technology across the financial services industry in Australia and New Zealand.

Fraud on Zelle

Post Syndicated from Bruce Schneier original https://www.schneier.com/blog/archives/2022/03/fraud-on-zelle.html

Zelle is rife with fraud:

Zelle’s immediacy has also made it a favorite of fraudsters. Other types of bank transfers or transactions involving payment cards typically take at least a day to clear. But once crooks scare or trick victims into handing over money via Zelle, they can siphon away thousands of dollars in seconds. There’s no way for customers — and in many cases, the banks themselves — to retrieve the money.

[…]

It’s not clear who is legally liable for such losses. Banks say that returning money to defrauded customers is not their responsibility, since the federal law covering electronic transfers — known in the industry as Regulation E ­– requires them to cover only “unauthorized” transactions, and the fairly common scam that Mr. Faunce fell prey to tricks people into making the transfers themselves. Victims say because they were duped into sending the money, the transaction is unauthorized. Regulatory guidance has so far been murky.

When swindled customers, already upset to find themselves on the hook, search for other means of redress, many are enraged to find out that Zelle is owned and operated by banks.

[…]

The Zelle network is operated by Early Warning Services, a company created and owned by seven banks: Bank of America, Capital One, JPMorgan Chase, PNC, Truist, U.S. Bank and Wells Fargo. Early Warning, based in Scottsdale, Ariz., manages the system’s technical infrastructure. But the 1,425 banks and credit unions that use Zelle can customize the app and add their own security settings.

New AWS workbook for New Zealand financial services customers

Post Syndicated from Julian Busic original https://aws.amazon.com/blogs/security/new-aws-workbook-for-new-zealand-financial-services-customers/

We are pleased to announce a new AWS workbook designed to help New Zealand financial services customers align with the Reserve Bank of New Zealand (RBNZ) Guidance on Cyber Resilience.

The RBNZ Guidance on Cyber Resilience sets out the RBNZ expectations for its regulated entities regarding cyber resilience, and aims to raise awareness and promote the cyber resilience of the financial sector, especially at board and senior management level. The guidance applies to all entities regulated by the RBNZ, including registered banks, licensed non-bank deposit takers, licensed insurers, and designated financial market infrastructures.

While the RBNZ describes its guidance as “a set of recommendations rather than requirements” which are not legally enforceable, it also states that it expects regulated entities to “proactively consider how their current approach to cyber risk management lines up with the recommendations in [the] guidance and look for [opportunities] for improvement as early as possible.”

Security and compliance is a shared responsibility between AWS and the customer. This differentiation of responsibility is commonly referred to as the AWS Shared Responsibility Model, in which AWS is responsible for security of the cloud, and the customer is responsible for their security in the cloud. The new AWS Reserve Bank of New Zealand Guidance on Cyber Resilience (RBNZ-GCR) Workbook helps customers align with the RBNZ Guidance on Cyber Resilience by providing control mappings for the following:

  • Security in the cloud by mapping RBNZ Guidance on Cyber Resilience practices to the five pillars of the AWS Well-Architected Framework.
  • Security of the cloud by mapping RBNZ Guidance on Cyber Resilience practices to control statements from the AWS Compliance Program.

The downloadable AWS RBNZ-GCR Workbook contains two embedded formats:

  • Microsoft Excel – Coverage includes AWS responsibility control statements and Well-Architected Framework best practices.
  • Dynamic HTML – Coverage is the same as in the Microsoft Excel format, with the added feature that the Well-Architected Framework best practices are mapped to AWS Config managed rules and Amazon GuardDuty findings, where available or applicable.

The AWS RBNZ-GCR Workbook is available for download in AWS Artifact, a self-service portal for on-demand access to AWS compliance reports. Sign in to AWS Artifact in the AWS Management Console, or learn more at Getting Started with AWS Artifact.

If you have feedback about this post, submit comments in the Comments section below.

Want more AWS Security how-to content, news, and feature announcements? Follow us on Twitter.

Author

Julian Busic

Julian is a Security Solutions Architect with a focus on regulatory engagement. He works with our customers, their regulators, and AWS teams to help customers raise the bar on secure cloud adoption and usage. Julian has over 15 years of experience working in risk and technology across the financial services industry in Australia and New Zealand.

Disaster recovery compliance in the cloud, part 2: A structured approach

Post Syndicated from Dan MacKay original https://aws.amazon.com/blogs/security/disaster-recovery-compliance-in-the-cloud-part-2-a-structured-approach/

Compliance in the cloud is fraught with myths and misconceptions. This is particularly true when it comes to something as broad as disaster recovery (DR) compliance where the requirements are rarely prescriptive and often based on legacy risk-mitigation techniques that don’t account for the exceptional resilience of modern cloud-based architectures. For regulated entities subject to principles-based supervision such as many financial institutions (FIs), the responsibility lies with the FI to determine what’s necessary to adequately recover from a disaster event. Without clear instructions, FIs are susceptible to making incorrect assumptions regarding their compliance requirements for DR.

In Part 1 of this two-part series, I provided some examples of common misconceptions FIs have about compliance requirements for disaster recovery in the cloud. In Part 2, I outline five steps you can take to avoid these misconceptions when architecting DR-compliant workloads for deployment on Amazon Web Services (AWS).

1. Identify workloads planned for deployment

It’s common for FIs to have a portfolio of workloads they are considering deploying to the cloud and often want to know that they can be compliant across the board. But compliance isn’t a one-size-fits-all domain—it’s based on the characteristics of each workload. For example, does the workload contain personally identifiable information (PII)? Will it be used to store, process, or transmit credit card information? Compliance is dependent on the answers to questions such as these and must be assessed on a case-by-case basis. Therefore, the first step in architecting for compliance is to identify the specific workloads you plan to deploy to the cloud. This way, you can assess the requirements of these specific workloads and not be distracted by aspects of compliance that might not be relevant.

2. Define the workload’s resiliency requirements

Resiliency is the ability of a workload to recover from infrastructure or service disruptions. DR is an important part of your resiliency strategy and concerns how your workload responds to a disaster event. DR strategies on AWS range from simple, low cost options such as backup and restore, to more complex options such as multi-site active-active, as shown in Figure 1.
 

For more information, I encourage you to read Seth Eliot’s blog series on DR Architecture on AWS as well as the AWS whitepaper Disaster Recovery of Workloads on AWS: Recovery in the Cloud.

The DR strategy you choose for a particular workload is dependent on your organization’s requirements for avoiding loss of data—known as the recovery point objective (RPO)—and reducing downtime where the workload isn’t available —known as the recovery time objective (RTO). RPO and RTO are key factors for determining the minimum architectural specifications necessary to meet the workload’s resiliency requirements. For example, can the workload’s RPO and RTO be achieved using a multi-AZ architecture in a single AWS Region, or do the resiliency requirements necessitate deploying the workload across multiple AWS Regions? Even if your workload is not subject to explicit compliance requirements for resiliency, understanding these requirements is necessary for assessing other aspects of DR compliance, including data residency and geodiversity.

3. Confirm the workload’s data residency requirements

As I mentioned in Part 1, data residency requirements might restrict which AWS Region or Regions you can deploy your workload to. Therefore, you need to confirm whether the workload is subject to any data residency requirements within applicable laws and regulations, corporate policies, or contractual obligations.

In order to properly assess these requirements, you must review the explicit language of the requirements so as to understand the specific constraints they impose. You should also consult legal, privacy, and compliance subject-matter specialists to help you interpret these requirements based on the characteristics of the workload. For example, do the requirements specifically state that the data cannot leave the country, or can the requirement be met so long as the data can be accessed from that country? Does the requirement restrict you from storing a copy of the data in another country—for example, for backup and recovery purposes? What if the data is encrypted and can only be read using decryption keys kept within the home country? Consulting subject-matter specialists to help interpret these requirements can help you avoid making overly restrictive assumptions and imposing unnecessary constraints on the workload’s architecture.

4. Confirm the workload’s geodiversity requirements

A single Region, multiple-AZ architecture is often sufficient to meet a workload’s resiliency requirements. However, if the workload is subject to geodiversity requirements, the distance between the AZs in an AWS Region might not conform to the minimum distance between individual data centers specified by the requirements. Therefore, it’s critical to confirm whether any geodiversity requirements apply to the workload.

Like data residency, it’s important to assess the explicit language of geodiversity requirements. Are they written down in a regulation or corporate policy, or are they just a recommended practice? Can the requirements be met if the workload is deployed across three or more AZs even if the minimum distance between those AZs is less than the specified minimum distance between the primary and backup data centers? If it’s a corporate policy, does it allow for exceptions if an alternative method provides equal or greater resiliency than asynchronous replication between two geographically distant data centers? Or perhaps the corporate policy is outdated and should be revised to reflect modern risk mitigation techniques. Understanding these parameters can help you avoid unnecessary constraints as you assess architectural options for your workloads.

5. Assess architectural options to meet the workload’s requirements

Now that you understand the workload’s requirements for resiliency, data residency, and geodiversity, you can assess the architectural options that meet these requirements in the cloud.

As per AWS Well-Architected best practices, you should strive for the simplest architecture necessary to meet your requirements. This includes assessing whether the workload can be accommodated within a single AWS Region. If the workload is constrained by explicit geographic diversity requirements or has resiliency requirements that cannot be accommodated by a single AWS Region, then you might need to architect the workload for deployment across multiple AWS Regions. If the workload is also constrained by explicit data residency requirements, then it might not be possible to deploy to multiple AWS Regions. In cases such as these, you can work with our AWS Solution Architects to assess hybrid options that might meet your compliance requirements, such as using AWS Outposts, Amazon Elastic Container Service (Amazon ECS) Anywhere, or Amazon Elastic Kubernetes Service (Amazon EKS) Anywhere. Another option may be to consider a DR solution in which your on-premises infrastructure is used as a backup for a workload running on AWS. In some cases, this might be a long-term solution. In others, it might be an interim solution until certain constraints can be removed—for example, a change to corporate policy or the introduction of additional AWS Regions in a particular country.

Conclusion

Let’s recap by summarizing some guiding principles for architecting compliant DR workloads as outlined in this two-part series:

  • Avoid assumptions; confirm the facts. If it’s not written down, it’s unlikely to be considered a mandatory compliance requirement.
  • Consult the experts. Legal, privacy, and compliance, as well as AWS Solution Architects, AWS security and compliance specialists, and other subject-matter specialists.
  • Avoid generalities; focus on the specifics. There is no one-size-fits-all approach.
  • Strive for simplicity, not zero risk. Don’t use multiple AWS Regions when one will suffice.
  • Don’t get distracted by exceptions. Focus on your current requirements, not workloads you’re not yet prepared to deploy to the cloud.

If you have feedback about this post, submit comments in the Comments section below.

Want more AWS Security how-to content, news, and feature announcements? Follow us on Twitter.

Author

Dan MacKay

Dan is the Financial Services Compliance Specialist for AWS Canada. As a member of the Worldwide Financial Services Security & Compliance team, Dan advises financial services customers on best practices and practical solutions for cloud-related governance, risk, and compliance. He specializes in helping AWS customers navigate financial services and privacy regulations applicable to the use of cloud technology in Canada.

Disaster recovery compliance in the cloud, part 1: Common misconceptions

Post Syndicated from Dan MacKay original https://aws.amazon.com/blogs/security/disaster-recovery-compliance-in-the-cloud-part-1-common-misconceptions/

Compliance in the cloud can seem challenging, especially for organizations in heavily regulated sectors such as financial services. Regulated financial institutions (FIs) must comply with laws and regulations (often in multiple jurisdictions), global security standards, their own corporate policies, and even contractual obligations with their customers and counterparties. These various compliance requirements may impose constraints on how their workloads can be architected for the cloud, and may require interpretation on what FIs must do in order to be compliant. It’s common for FIs to make assumptions regarding their compliance requirements, which can result in unnecessary costs and increased complexity, and might not align with their strategic objectives. A modern, rationalized approach to compliance can help FIs avoid imposing unnecessary constraints while meeting their mandatory requirements.

In my role as an Amazon Web Services (AWS) Compliance Specialist, I work with our financial services customers to identify, assess, and determine solutions to address their compliance requirements as they move to the cloud. One of the most common challenges customers ask me about is how to comply with disaster recovery (DR) requirements for workloads they plan to run in the cloud. In this blog post, I share some of the typical misconceptions FIs have about DR compliance in the cloud. In Part 2, I outline a structured approach to designing compliant architectures for your DR workloads. As my primary market is Canada, the examples in this blog post largely pertain to FIs operating in Canada, but the principles and best practices are relevant to regulated organizations in any country.

“Why isn’t there a checklist for compliance in the cloud?”

Compliance requirements are sometimes prescriptive: “if X, then you must do Y.” When requirements are prescriptive, it’s usually clear what you must do in order to be compliant. For example, the Payment Card Industry Data Security Standard (PCI DSS) requirement 8.2.4 obliges companies that process, store, or transmit credit card information to “change user passwords/passphrases at least once every 90 days.” But in the financial services sector, compliance requirements for managing operational risks can be subjective. When regulators take what is known as a principles-based approach to setting regulatory expectations, each FI is required to assess their specific risks and determine the mitigating controls necessary to conform with the organization’s tolerance for operational risk. Because the rules aren’t prescriptive, there is no “checklist for achieving compliance.” Instead, principles-based requirements are guidelines that FIs are expected to consider as they design and implement technology solutions. They are, by definition, subject to interpretation and can be prone to myths and misconceptions among FIs and their service providers. To illustrate this, let’s look at two aspects of DR that are frequently misunderstood within the Canadian financial services industry: data residency and geodiversity.

“My data has to stay in country X”

Data residency or data localization is a requirement for specific data-sets processed and stored in an IT system to remain within a specific jurisdiction (for example, a country). As discussed in our Policy Perspectives whitepaper, contrary to historical perspectives, data residency doesn’t provide better security. Most cyber-attacks are perpetrated remotely and attackers aren’t deterred by the physical location of their victims. In fact, data residency can run counter to an organization’s objectives for security and resilience. For example, data residency requirements can limit the options our customers have when choosing the AWS Region or Regions in which to run their production workloads. This is especially challenging for customers who want to use multiple Regions for backup and recovery purposes.

It’s common for FIs operating in Canada to assume that they’re required to keep their data—particularly customer data—in Canada. In reality, there’s very little from a statutory perspective that imposes such a constraint. None of the private sector privacy laws include data residency requirements, nor do any of the financial services regulatory guidelines. There are some place of records requirements in Canadian federal financial services legislation such as The Bank Act and The Insurance Companies Act, but these are relatively narrow in scope and apply primarily to corporate records. For most Canadian FIs, their requirements are more often a result of their own corporate policies or contractual obligations, not externally imposed by public policies or regulations.

“My data centers have to be X kilometers apart”

Geodiversity—short for geographic diversity—is the concept of maintaining a minimum distance between primary and backup data processing sites. Geodiversity is based on the principle that requiring a certain distance between data centers mitigates the risk of location-based disruptions such as natural disasters. The principle is still relevant in a cloud computing context, but is not the only consideration when it comes to planning for DR. The cloud allows FIs to define operational resilience requirements instead of limiting themselves to antiquated business continuity planning and DR concepts like physical data center implementation requirements. Legacy disaster recovery solutions and architectures, and lifting and shifting such DR strategies into the cloud, can diminish the potential benefits of using the cloud to improve operational resilience. Modernizing your information technology also means modernizing your organization’s approach to DR.

In the cloud, vast physical distance separation is an anti-pattern—it’s an arbitrary metric that does little to help organizations achieve availability and recovery objectives. At AWS, we design our global infrastructure so that there’s a meaningful distance between the Availability Zones (AZs) within an AWS Region to support high availability, but close enough to facilitate synchronous replication across those AZs (an AZ being a cluster of data centers). Figure 1 shows the relationship between Regions, AZs, and data centers.
 

Synchronous replication across multiple AZs enables you to minimize data loss (defined as the recovery point objective or RPO) and reduce the amount of time that workloads are unavailable (defined as the recovery time objective or RTO). However, the low latency required for synchronous replication becomes less achievable as the distance between data centers increases. Therefore, a geodiversity requirement that mandates a minimum distance between data centers that’s too far for synchronous replication might prohibit you from taking advantage of AWS’s multiple-AZ architecture. A multiple-AZ architecture can achieve RTOs and RPOs that aren’t possible with a simple geodiversity mitigation strategy. For more information, refer to the AWS whitepaper Disaster Recovery of Workloads on AWS: Recovery in the Cloud.

Again, it’s a common perception among Canadian FIs that the disaster recovery architecture for their production workloads must comply with specific geodiversity requirements. However, there are no statutory requirements applicable to FIs operating in Canada that mandate a minimum distance between data centers. Some FIs might have corporate policies or contractual obligations that impose geodiversity requirements, but for most FIs I’ve worked with, geodiversity is usually a recommended practice rather than a formal policy. Informal corporate guidelines can have some value, but they aren’t absolute rules and shouldn’t be treated the same as mandatory compliance requirements. Otherwise, you might be unintentionally restricting yourself from taking advantage of more effective risk management techniques.

“But if it is a compliance requirement, doesn’t that mean I have no choice?”

Both of the previous examples illustrate the importance of not only confirming your compliance requirements, but also recognizing the source of those requirements. It might be infeasible to obtain an exception to an externally-imposed obligation such as a regulatory requirement, but exceptions or even revisions to corporate policies aren’t out of the question if you can demonstrate that modern approaches provide equal or greater protection against a particular risk—for example, the high availability and rapid recoverability supported by a multiple-AZ architecture. Consider whether your compliance requirements provide for some level of flexibility in their application.

Also, because many of these requirements are principles-based, they might be subject to interpretation. You have to consider the specific language of the requirement in the context of the workload. For example, a data residency requirement might not explicitly prohibit you from storing a copy of the content in another country for backup and recovery purposes. For this reason, I recommend that you consult applicable specialists from your legal, privacy, and compliance teams to aid in the interpretation of compliance requirements. Once you understand the legal boundaries of your compliance requirements, AWS Solutions Architects and other financial services industry specialists such as myself can help you assess viable options to meet your needs.

Conclusion

In this first part of a two-part series, I provided some examples of common misconceptions FIs have about compliance requirements for disaster recovery in the cloud. The key is to avoid making assumptions that might impose greater constraints on your architecture than are necessary. In Part 2, I show you a structured approach for architecting compliant DR workloads that can help you to avoid these preventable missteps.

If you have feedback about this post, submit comments in the Comments section below.

Want more AWS Security how-to content, news, and feature announcements? Follow us on Twitter.

Author

Dan MacKay

Dan is the Financial Services Compliance Specialist for AWS Canada. As a member of the Worldwide Financial Services Security & Compliance team, Dan advises financial services customers on best practices and practical solutions for cloud-related governance, risk, and compliance. He specializes in helping AWS customers navigate financial services and privacy regulations applicable to the use of cloud technology in Canada.

Check Washing

Post Syndicated from Bruce Schneier original https://www.schneier.com/blog/archives/2020/11/check-washing.html

I can’t believe that check washing is still a thing:

“Check washing” is a practice where thieves break into mailboxes (or otherwise steal mail), find envelopes with checks, then use special solvents to remove the information on that check (except for the signature) and then change the payee and the amount to a bank account under their control so that it could be deposited at out-state-banks and oftentimes by a mobile phone.

The article suggests a solution: stop using paper checks.

North Korea ATM Hack

Post Syndicated from Bruce Schneier original https://www.schneier.com/blog/archives/2020/09/north_korea_atm.html

The US Cybersecurity and Infrastructure Security Agency (CISA) published a long and technical alert describing a North Korea hacking scheme against ATMs in a bunch of countries worldwide:

This joint advisory is the result of analytic efforts among the Cybersecurity and Infrastructure Security Agency (CISA), the Department of the Treasury (Treasury), the Federal Bureau of Investigation (FBI) and U.S. Cyber Command (USCYBERCOM). Working with U.S. government partners, CISA, Treasury, FBI, and USCYBERCOM identified malware and indicators of compromise (IOCs) used by the North Korean government in an automated teller machine (ATM) cash-out scheme­ — referred to by the U.S. Government as “FASTCash 2.0: North Korea’s BeagleBoyz Robbing Banks.”

The level of detail is impressive, as seems to be common in CISA’s alerts and analysis reports.

North Korea ATM Hack

Post Syndicated from Bruce Schneier original https://www.schneier.com/blog/archives/2020/09/north_korea_atm.html

The US Cybersecurity and Infrastructure Security Agency (CISA) published a long and technical alert describing a North Korea hacking scheme against ATMs in a bunch of countries worldwide:

This joint advisory is the result of analytic efforts among the Cybersecurity and Infrastructure Security Agency (CISA), the Department of the Treasury (Treasury), the Federal Bureau of Investigation (FBI) and U.S. Cyber Command (USCYBERCOM). Working with U.S. government partners, CISA, Treasury, FBI, and USCYBERCOM identified malware and indicators of compromise (IOCs) used by the North Korean government in an automated teller machine (ATM) cash-out scheme­ — referred to by the U.S. Government as “FASTCash 2.0: North Korea’s BeagleBoyz Robbing Banks.”

The level of detail is impressive, as seems to be common in CISA’s alerts and analysis reports.