RiskPundit

Phishing emails have become more convincing

The "quality" of phishing emails continues to improve. In other words, the attackers continue to make their phishing emails seem legitimate and thus trick more people into taking the emails' suggested actions. An article in Dark Reading this week discusses research done by F-Secure about new, more convincing, phishing attacks generated by the Zbot botnet which attempts to infect victims with the Zeus trojan. I wrote about how the Zeus trojan is used as a keylogger to steal banking credentials which enable funds transfer fraud. 

While one might have considered the Dark Reading article a public relations piece for F-Secure, its validity was increased for me by Rich Mogull at Securosis who wrote about  "the first phishig email I almost fell for," i.e. one of these Zbot phishing emails.

If a security person like Rich Mogull, who has the requisite security "paranoia DNA" can almost be fooled, then the phishing attackers are indeed improving their social engineering craft.

URLZone - Funds Transfer Fraud innovation accelerates

Web security firm, Finjan, published a report (Issue 2, 2009) this week on a more advanced funds transfer fraud trojan called URLZone. It basically follows the now well understood process I blogged about previously, where:

1. Cybercriminals infect Web sites using, for example, Cross Site Scripting.
2. Web site visitors are infected with a trojan, in this case URLZone.
3. The trojan is used to collect bank credentials.
4. Cybercrirminals transfer money from the victims to mules.
5. The money is transferred from the mules to the cybercriminals.

URLZone is a more advanced trojan because of the level of automation of the funds transfer fraud  (direct quotes from the Finjan report):

• It hides its fraudulent transaction(s) in the report screen of the compromised account.
• Its C&C [Command and Control] server sends instructions over HTTP about the amount to be stolen and where the stolen money should be deposited.
• It logs and reports on other web accounts (e.g., Facebook, PayPal, Gmail) and banks from other countries.

In the past, the trojan was merely a keylogger that sent credentials back to the cybercriminal. These exploits were mostly against small businesses and schools where relatively large amounts of money could be stolen. But the URLZone trojan has much more sophisticated command and control which enables a much higher volume of transactions. Finjan reports 6,400 victims in 22 days losing 300,000 Euros. So far all the victims have been in Germany.

London TimeOnLine report on Clampi thin on facts

The London-based Times OnLine had a story today entitled, "New Trojan virus poses online banking threat." With all due respect, Mike Harvey, their Technology Correspondent, appears to have gotten a few things wrong as follows:

• The headline is referring to the Clampi Trojan, which is not new. It was first discovered in 2006 according to McAfee and 2008 according to Symantec. In fact as late as July 23rd, Symantec classified Clampi as "Very Low" risk. Since then, Symantec has raised the risk level to "High."
• The Clampi Trojan is just one of many trojans that cyber criminals are using to steal people's online banking credentials. What these trojans have in common is the keylogging capability, i.e. the ability to capture all of your keyboard clicks.
• The real story is that sophisticated cyber criminals are focusing on stealing money directly out of small and medium business accounts.

For more details on Clampi and funds transfer fraud, see my earlier blog posts here and here respectively.

Court allows bank customer to sue bank for "negligent" security practices

Computerworld reported last week that a judge in Illinois ruled that a couple who lost $26,500 when their bank account was breached can sue the bank for negligence for not implementing "state-of-the-art" security measures which would have prevented the breach.

While bank credit card issuers have been suing credit card processors and retailers regularly to recoup losses due to breaches, this is the first time that I am aware of that a judge has ruled that a customer can sue the bank for negligence.

The more detailed blog post by attorney David Johnson, upon which the Computerworld article is based, discusses some really interesting details of this case.

The plaintiffs sued Citizens Financial Bank for negligence because it had not implemented multifactor authentication. The timeline is important here. The Federal Financial Institutions Examination Council (FFIEC) issued multifactor authentication guidelines in 2005. By 2007, when the plaintiffs' breach occurred, the bank had still not implemented multifactor authentication. The judge, Rebecca Pallmeyer of the District Court of Northern Illinois, found this two year delay unacceptable. 

Two interesting complications - (1) The account from which the money was stolen was from a home equity line of credit account, not a deposit or consumer asset account. (2) This credit account was linked to the plaintiffs' business checking account. I discussed the differences between consumer and business account liability here. Fortunately for the plaintiffs, the judge brushed these issues aside and focused on the lack of multifactor authentication.

One issue that was not addressed - where was Fiserv in all of this? They are the provider of the online banking software used by Citizens Financial Bank. Were they offering some type of multifactor authentication? I would assume yes, although I have not been able to confirm this.

In conclusion, attorney David Johnson makes clear that this ruling increases the risk to banks (and possibly other organizations responsible for protecting money and/or other assets of value) if they do not implement state-of-the-art security measures.

PCI compliance program good but needs improvement

Controversy around the PCI DSS compliance program increased recently when Robert Carr, the CEO of Heartland Payment Systems, in an article in CSO Online, attacked his QSAs saying, "The audits done by our QSAs (Qualified Security Assessors) were of no value whatsoever. To the extent that they were telling us we were secure beforehand, that we were PCI compliant, was a major problem."

Mike Rothman, Senior VP of eIQNetworks responded to Mr. Carr's comments not so much to defend PCI but to place PCI in perspective, i.e. compliance does not equal security. I discussed this myself in my post about the 8 Dirty Secrets of IT Security, specifically in my comments on Dirty Secret #6 - Compliance Threatens Security. 

Eric Ogren, a security industry analyst, continued the attack on PCI in his article in SearchSecurity last week where he said, "The federal indictment this week of three men for their roles in the largest data security breach in U.S. history also serves as an indictment of sorts against the fraud conducted by PCI – placing the burden of security costs onto retailers and card processors when what is really needed is the payment card industry investing in a secure business process."

The federal indictment to which Eric Ogren referred was that of Albert Gonzalez and others for the breaches at Heartland Payment Services, 7-Eleven, Hannaford, and two national retailers referred to as Company A and Company B. Actually this is the second federal indictment of Albert Gonzalez that I am aware of. The first, filed in Massachusetts in August 2008, was for the breaches at BJ's Wholesale Club, DSW, OfficeMax, Boston Market, Barnes & Noble, Sport Authority, and TJX.

Bob Russo, the general manager of the PCI Security Standards Council disagreed with Eric Ogren's characterizations of PCI, saying that retailers and credit card processors must take responsibility for protecting cardholder information.

Rich Mogull, CEO and Analyst at Securosis, responded to Bob Russo's article with recommendations to improve the PCI compliance program which he characterized as an "overall positive development for the state of security." He went on to say, "In other words, as much as PCI is painful, flawed, and ineffective, it has also done more to improve security than any other regulation or industry initiative in the past 10 years. Yes, it's sometimes a distraction; and the checklist mentality reduces security in some environments, but overall I see it as a net positive."

Rich Mogull seems to agree with Eric Ogren that the credit card companies have the responsibility and the power to improve the technical foundations of credit card transactions. In addition, he calls the PCI Council to task for such issues as:

• incomplete and/or weak compliance requirements
• QSA shopping
• the conflict of interest they created by allowing QSA's to perform audits and then sell security services based on the findings of the audits.

Clearly organizations have no choice but to comply with mandatory regulations. But the compliance process must be part of an overall risk management process. In other words, the compliance process is not equal to the risk management process but a component of it.

Finally, and most importantly, the enterprise risk management process must be more agile and responsive to new security threats than a bureaucratic regulatory body can be. For example, it may be some time before the PCI standards are updated to specify that firewalls must be able to work at the application level so all the the Web 2.0 applications traversing the enterprise network can be controlled. This is an important issue today as this has been a major vector for compromising systems that are then used for funds transfer fraud.

Funds transfer fraud against midsize U.S. businesses on the rise

The Washington Post reported yesterday that there is an increase in "funds transfer fraud" being perpetrated by organized crime groups from Eastern Europe against small and medium U.S. businesses. 

It's hard to know the extent of this type of crime because there is no breach notification requirement since no customer information is disclosed. However, many companies are reporting these crimes to the FBI and of course to their banks.

The risk of funds transfer fraud to businesses is much higher than to consumers for the following reasons:

• Dollar amounts are higher.
• Under the Uniform Commercial Code, businesses only have two days to dispute charges they feel are unauthorized. Consumers have 60 days from the time they receive their statements.
• Because banks are liable for the consumer losses and less so for the business losses, they invest more resources in protecting consumers.

The complete article in the Washington Post is well worth reading.

In a previous post, I highlighted one of the techniques used by cyber criminals where they surreptitiously install the Clampi trojan on a PC in order to get the login credentials needed for online banking.

Recommended actions:

• Install anti-virus/anti-malware agents on all workstations and keep them up-to-date
• Use an end-point configuration management system to discover all workstations, to assure the above mentioned agents are installed and up-to-date, and to assure that unauthorized software is not installed
• Implement firewall policies to (1) assure that only authorized people (i.e. people in authorized roles) using only authorized workstations can connect to financial institutions to perform funds transfer transactions, (2) assure that people not authorized cannot connect to financial institutions, (3) generate alerts when there are attempts to violate these policies
• Implement a process where funds transfer transactions are reviewed on a daily basis by someone other than the person or people who perform the transactions