While this is termed “guidance”, the FFIEC does say “Examiners will review this area to determine a financial institution’s progress in complying with this guidance during upcoming examinations. Financial Institutions will be expected to achieve compliance with the guidance no later than year-end 2006.”
The FFIEC makes a strong point about single-factor authentication, saying “The agencies consider single-factor authentication, as the only control mechanism, to be inadequate for high-risk transactions involving access to customer information or the movement of funds to other parties.”
From the FFIEC document:
Existing authentication methodologies involve three basic “factors”:
• Something the user knows (e.g., password, PIN);
• Something the user has (e.g., ATM card, smart card); and
• Something the user is (e.g., biometric characteristic, such as a fingerprint).
Authentication methods that depend on more than one factor are more difficult to compromise than single-factor methods. Accordingly, properly designed and implemented multifactor authentication methods are more reliable and stronger fraud deterrents. For example, the use of a logon ID/password is single-factor authentication (i.e., something the user knows); whereas, an ATM transaction requires multifactor authentication: something the user possesses (i.e., the card) combined with something the user knows (i.e., PIN). A multifactor authentication methodology may also include “out–of–band”5 controls for risk mitigation.
…Financial institutions offering Internet-based products and services should have reliable and secure methods to authenticate their customers. The level of authentication used by the financial institution should be appropriate to the risks associated with those products and services. Financial institutions should conduct a risk assessment to identify the types and levels of risk associated with their Internet banking applications. Where risk assessments indicate that the use of single-factor authentication is inadequate, financial institutions should implement multifactor authentication, layered security, or other controls reasonably calculated to mitigate those risks. The agencies consider single-factor authentication, as the only control mechanism, to be inadequate in the case of high-risk transactions involving access to customer information or the movement of funds to other parties.
Related SunbetBlog posts: