Tag Archives: cyber fraud

Client’s Card Security

Our Chapter recently got a question from a reader of this blog about data privacy; specifically she asked about the Payment Card Industry Data Security Standard (PCI DSS) and whether compliance with that standard’s requirements by a client would provide reasonable assurance that the client organization’s customer data privacy controls and procedures are adequate. The question came up in the course of a credit card fraud examination in which our reader’s small CPA firm was involved. A very good question indeed! The short answer, in my opinion, is that, although PCI DSS compliance audits cover some aspects of data privacy, because they’re limited to credit cards, PCI DSS audits would not, in themselves be sufficient to convince a jury that data privacy is adequately protected throughout a whole organization. The question is interesting because of its bearing on the fraud risk assessments CFE’s routinely conduct. The question is important because CFE’s should understand the scope (and limitations) of PCI DSS compliance activities within their client organizations and communicate the differences when reviewing corporate-wide data privacy for fraud prevention purposes. This understanding will also tend to prevent any potential misunderstandings over duplication of review efforts with business process owners and fraud examination clients.

Given all the IT breeches and intrusions happening daily, consumers are rightly cynical these days about businesses’ ability to protect their personal data. They report that they’re much more willing to do business with companies that have independently verified privacy policies and procedures. In-depth privacy fraud risk assessments can help organizations assess their preparedness for the outside review that inevitably follows a major customer data privacy breach. As I’m sure all the readers of this blog know, data privacy generally applies to information that can be associated with a specific individual or that has identifying characteristics that might be combined with other information to indicate a specific person. Such personally identifiable information (PII) is defined as any piece of data that can be used to uniquely identify, contact, or locate a single person. Information can be considered private without being personally identifiable. Sensitive personal data includes individual preferences, confidential financial or health information, or other personal information. An assessment of data privacy fraud risk encompasses the policy, controls, and procedures in place to protect PII.

In planning a fraud risk assessment of data privacy, CFE’s auditors should evaluate or consider based on risk:

–The consumer and employee PII that the client organization collects, uses, retains, discloses, and discards.
–Privacy contract requirements and risk liabilities for all outsourcing partners, vendors, contractors, and other third parties involving sharing and processing of the organization’s consumer and employee data.
–Compliance with privacy laws and regulations impacting the organization’s specific business and industry.
–Previous privacy breaches within the organization and its third-party service providers, and reported breaches for similar organizations noted by clearing houses like Dunn &
Bradstreet and in the client industry’s trade press.
–The CFE should also consult with the client’s corporate legal department before undertaking the review to determine whether all or part of the assessment procedure should be performed at legal direction and protected as “attorney-client privileged” work products.

The next step in a privacy fraud risk assessment is selecting a framework for the review.
Two frameworks to consider are the American Institute of Certified Public Accountants (AICPA) Privacy Framework and The IIA’s Global Audit Technology Guide: Managing and Auditing Privacy Risks. For ACFE training purposes, one CFE working for a well know on-line retailer reported organizing her fraud assessment report based on the AICPA framework. The CFE chose that methodology because it would be understood and supported easily by management, external auditors, and the audit committee. The AICPA’s ten component framework was useful in developing standards for the organization as well as for an assessment framework:

–Management. The organization defines, documents, communicates, and assigns accountability for its privacy policies and procedures.
–Notice. The organization provides notice about its privacy policies and procedures and identifies the purposes for which PII is collected, used, retained, and disclosed.
–Choice and Consent. The organization describes the choices available to the individual customer and obtains implicit or explicit consent with respect to the collection, use, and disclosure of PII.
–Collection. The organization collects PII only for the purposes identified in the Notice.
–Use, Retention, and Disposal. The organization limits the use of PII to the purposes identified in the Notice and for which the individual customer has provided implicit or explicit consent. The organization retains these data for only as long as necessary to fulfill the stated purposes or as required by laws or regulations, and thereafter disposes of such information appropriately.
–Access. The organization provides individual customers with access to their PII for review and update.
–Disclosure to Third Parties. The organization discloses PII to third parties only for the purposes identified in the Notice and with the implicit or explicit consent of the individual.
–Security for Privacy. The organization protects PII against unauthorized physical and logical access.
–Quality. The organization maintains accurate, complete, and relevant PII for the purposes identified in the Notice.
–Monitoring and Enforcement. The organization monitors compliance with its privacy policies and procedures and has procedures to address privacy complaints and disputes.

Using the detailed assessment procedures in the framework, the CFE, working with internal client staff, developed specific testing procedures for each component, which were performed over a two-month period. Procedures included traditional walkthroughs of processes, interviews with individuals responsible for IT security, technical testing of IT security and infrastructure controls, and review of physical storage facilities for documents with PII. Technical scanning was performed independently by the retailer’s IT staff, which identified PII on servers and some individual personal computers erroneously excluded from compliance monitoring. Facilitated sessions with the CFE and individuals responsible for PII helped identify problem areas. The fraud risk assessment dramatically increased awareness of data privacy and identified several opportunities to strengthen ownership, accountability, controls, procedures, and training. As a result of the assessment, the retailer implemented a formal data classification scheme and increased IT security controls. Several of the vulnerabilities and required enhancements involved controls over hard-copy records containing PII. Management reacted to the overall report positively and requested that the CFE schedule future recurring views of fraudulent privacy breech vulnerability.

Fraud risk assessments of client privacy programs can help make the business case within any organization for focusing on privacy now, and for promoting organizational awareness of privacy issues and threats. This is one of the most significant opportunities for fraud examiners to help assess risks and identify potential gaps that are daily proving so devastating if left unmanaged.

The Critical Twenty Percent

According to the Pareto Principle, for many phenomena, 80 percent of the consequences stem from 20 percent of the causes. Application of the principle to fraud prevention efforts related particularly to automated systems seems increasingly apropos given the deluge of intrusions, data thefts, worms and other attacks which continue unabated, with organizations of all kinds losing productivity, revenue and more customers every month. ACFE members report having asked the IT managers of numerous victimized organizations over the years what measures their organization took prior to an experienced fraud to secure their networks, systems, applications and data, and the answer has typically involved a combination of traditional perimeter protection solutions (such as firewalls, intrusion detection, antivirus and antispyware) together with patch management, business continuance strategies, and access control methods and policies. As much sense as these traditional steps make at first glance, they clearly aren’t proving sufficiently effective in preventing or even containing many of today’s most sophisticated attacks.

The ACFE has determined that not only are some organizations vastly better than the rest of their industries at preventing and responding to cyber-attacks, but also that the difference between these and other organizations’ effectiveness boils down to just a few foundational controls. And the most significant within these foundational controls are not rooted in standard forms of access control, but, surprisingly, in monitoring and managing change. It turns out that for the best performing organizations there are six important control categories – access, change, resolution, configuration, version release and service levels. There are performance measures involving each of the categories defining audit, operations and security performance measures. These include security effectiveness, audit compliance disruption levels, IT user satisfaction and unplanned work. By analyzing relationships between control objectives and corresponding performance indicators, numerous researchers have been able to differentiate which controls are actually most effective for consistently predictable service delivery, as well as for preventing and responding to security incidents and fraud related exploits.

Of the twenty-one most important foundational controls used by the most effective organizations at controlling intrusions, there were two used by virtually all of them. Both of these controls revolve around change management:

• Are systems monitored for unauthorized changes in real time?
• Are there defined consequences for intentional unauthorized changes?

These controls are supplemented by 1) a formal process for IT configuration management; 2) an automated process for configuration management; 3) a process to track change success rates (the percentage of changes that succeed without causing an incident, service outage or impairment); 4) a process that provides relevant personnel with correct and accurate information on all current IT infrastructure configurations. Researchers found that these top six controls help organizations help manage risks and respond to security incidents by giving them the means to look forward, averting the riskiest changes before they happen, and to look backward, identifying definitively the source of outages, fraud associated abnormalities or service issues. Because they have a process that tracks and records all changes to their infrastructure and their associated success rates, the most effective organizations have a more informed understanding of their production environments and can rule out change as a cause very early in the incident response process. This means they can easily find the changes that caused the abnormal incident and remediate them quickly.

The organizations that are most successful in preventing and responding to fraud related security incidents are those that have mastered change management, thereby documenting and knowing the ‘normal’ state of their systems in the greatest possible detail. The organization must cultivate a ‘culture’ of change management and causality throughout, with zero tolerance for any unauthorized changes. As with any organizational culture, the culture of change management should start at the top, with leaders establishing a tone that all change must follow an explicit change management policy and process from the highest to the lowest levels of the organization, with zero tolerance for unauthorized change. These same executives should establish concrete, well-publicized consequences for violating change management procedures, with a clear, written change management policy. One of the components of an effective change management policy is the establishment of a governing body, such as a change advisory board that reviews and evaluates all changes for risk before approving them. This board reinforces the written policy, requiring mandatory testing tor each and every change, and an explicit rollback plan for each in the case of an unexpected result.

ACFE studies stress that post incident reviews are also crucial, so that the organization protects itself from repeating past mistakes. During these reviews, change owners should document their findings and work to integrate lessons learned into future anti-fraud operational practices.
Perhaps most important for responding to changes is having clear visibility into all change activities, not just those that are authorized. Automated controls that can maintain a change history reduce the risk of human error in managing and controlling the overall process.

So organizations that focus solely on access and reactive resolution controls at the expense of real time change management process controls are almost guaranteed to experience in today’s environment more security incidents, more damage from security incidents, and dramatically longer and less-effective resolution times. On the other hand, organizations that foster a culture of disciplined change management and causality, with full support from senior management, and have zero tolerance for unauthorized change and abnormalities, will have a superior security posture with fewer incidents, dramatically less damage to the business from security breaches and much faster incident identification and resolution of incidents when they happen.

In conducting a cyber-fraud post-mortem, CFE’s and other assurance professionals should not fail to focus on strengthening controls related to reducing 1) the amount of overall time the IT department devotes to unplanned work; 2) a high volume of emergency system changes; 3) and the number and nature of a high volume of failed system changes. All these are red-flags for cyber fraud risk and indicative of a low level of real time system knowledge on the part of the client organization.

Analytic Reinforcements

Rumbi’s post of last week on ransomware got me thinking on a long drive back from Washington about what an excellent tool the AICPA’s new Cybersecurity Risk Management Reporting Framework is, not only for CPAs but for CFEs as well as for all our client organizations. As the seemingly relentless wave of cyberattacks continues with no sign of let up, organizations are under intense pressure from key stakeholders and regulators to implement and enhance their cyber security and fraud prevention programs to protect customers, employees and all the types of valuable information in their possession.

According to research from the ACFE, the average total cost per company, per event of a data breach is $3.62 million. Initial damage estimates of a single breach, while often staggering, may not take into account less obvious and often undetectable threats such as the theft of intellectual property, espionage, destruction of data, attacks on core operations or attempts to disable critical infrastructure. These effects can knock on for years and have devastating financial, operational and brand impact ramifications.

Given the present broad regulatory pressures to tighten cyber security controls and the visibility surrounding cyberrisk, a number of proposed regulations focused on improving cyber security risk management programs have been introduced in the United States over the past few years by our various governing bodies. One of the more prominent is a regulation by the New York Department of Financial Services (NYDFS) that prescribes certain minimum cyber security standards for those entities regulated by the NYDFS. Based on an entity’s risk assessment, the NYDFS law has specific requirements around data encryption and including data protection and retention, third-party information security, application security, incident response and breach notification, board reporting, and required annual re-certifications.

However, organizations continue to report to the ACFE regarding their struggle to systematically report to stakeholders on the overall effectiveness of their cyber security risk management programs. In response, the AICPA in April of last year released a new cyber security risk management reporting framework intended to help organizations expand cyberrisk reporting to a broad range of internal and external users, to include management and the board of directors. The AICPA’s new reporting framework is designed to address the need for greater stakeholder transparency by providing in-depth, easily consumable information about the state of an organization’s cyberrisk management program. The cyber security risk management examination uses an independent, objective reporting approach and employs broader and more flexible criteria. For example, it allows for the selection and utilization of any control framework considered suitable and available in establishing the entity’s basic cyber security objectives and in developing and maintaining controls within the entity’s cyber security risk management program irregardless of whether the standard is the US National Institute of Standards and Technology (NIST)’s Cybersecurity Framework, the International Organization for standardization (ISO)’s ISO 27001/2 and related frameworks, or even an internally developed framework based on a combination of sources. The examination is voluntary, and applies to all types of entities, but should be considered by CFEs as a leading practice that provides management, boards and other key stakeholders with clear insight into the current state of an organization’s cyber security program while identifying gaps or pitfalls that leave organizations vulnerable to cyber fraud and other intrusions.

What stakeholders might benefit from a client organization’s cyber security risk management examination report? Clearly, we CFEs as we go about our routine fraud risk assessments; but such a report, most importantly, can be vital in helping an organization’s board of directors establish appropriate oversight of a company’s cyber security risk program and credibly communicate its effectiveness to stakeholders, including investors, analysts, customers, business partners and regulators. By leveraging this information, boards can challenge management’s assertions around the effectiveness of their cyberrisk management and fraud prevention programs and drive more effective decision making. Active involvement and oversight from the board can help ensure that an organization is paying adequate attention to cyberrisk management and displaying due diligence. The board can help shape expectations for reporting on cyberthreats while also advocating for greater transparency and assurance around the effectiveness of the program.

The cyber security risk management report in its initial and follow-up iterations can be invaluable in providing overview guidance to CFEs and forensic accountants in targeting both fraud prevention and fraud detection/investigative analytics. We know from our ACFE training that data analytics need to be fully integrated into the investigative process. Ensuring that data analytics are embedded in the detection/investigative process requires support from all levels, starting with the managing CFE. It will be an easier, more coherent process for management to support such a process if management is already supporting cyber security risk management reporting. Management will also have an easier time reinforcing the use of analytics generally, although the data analytics function supporting fraud examination will still have to market its services, team leaders will still be challenged by management, and team members will still have to be trained to effectively employ the newer analytical tools.

The presence of a robust cyber security risk management reporting process should also prove of assistance to the lead CFE in establishing goals for the implementation and use of data analytics in every investigation, and these goals should be communicated to the entire investigative team. It should be made clear to every level of the client organization that data analytics will support the investigative planning process for every detected fraud. The identification of business processes, IT systems, data sources, and potential analytic routines should be discussed and considered not only during planning, but also throughout every stage of the entire investigative engagement. Key in obtaining the buy-in of all is to include investigative team members in identifying areas or tests that the analytics group will target in support of the field work. Initially, it will be important to highlight success stories and educate managers and team leaders about what is possible. Improving on the traditional investigative approach of document review, interviewing, transaction review, etc. investigators can benefit from the implementation of data analytics to allow for more precise identification of the control deficiencies, instances of noncompliance with policies and procedures, and mis-assessment of areas of high risk that contributed to the development of the fraud in the first place. These same analytics can then be used to ensure that appropriate post-fraud management follow-up has occurred by elevating the identified deficiencies to the cyber security risk management reporting process and by implementing enhanced fraud prevention procedures in areas of higher fraud risk. This process would be especially useful in responding to and following up data breaches.

Once patterns are gathered and centralized, analytics can be employed to measure the frequency of occurrence, the bit sizes, the quantity of files executed and average time of use. The math involved allows an examiner to grasp the big picture. Individuals, including examiners, are normally overwhelmed by the sheer volume of information, but automation of pattern recognizing techniques makes big data a tractable investigative resource. The larger the sample size, the easier it is to determine patterns of normal and abnormal behavior. Network haystacks are bombarded by algorithms that can notify the CFE information archeologist about the probes of an insider threat for example.

Without analytics, enterprise-level fraud examination and risk assessment is a diminished discipline, limited in scope and effectiveness. Without an educated investigative workforce, armed with a programing language for automation and an accompanying data-mining philosophy and skill set, the control needs of management leaders at the enterprise level will go unmet; leaders will not have the data needed for fraud prevention on a large scale nor a workforce that is capable of getting them that data in the emergency following a breach or penetration.

The beauty of analytics, from a security and fraud prevention perspective, is that it allows the investigative efforts of the CFE to align with the critical functions of corporate business. It can be used to discover recurring risks, incidents and common trends that might otherwise have been missed. Establishing numerical baselines on quantified data can supplement a normal investigator’s tasks and enhance the auditor’s ability to see beneath the surface of what is presented in an examination. Good communication of analyzed data gives decision makers a better view of their systems through a holistic approach, which can aid in the creation of enterprise-level goals. Analytics and data mining always add dimension and depth to the CFE’s examination process at the enterprise level and dovetail with and are supported beautifully by the AICPA’s cyber security risk management reporting initiative.

CFEs should encourage the staffs of client analytics support functions to possess …

–understanding of the employing enterprise’s data concepts (data elements, record types, database types, and data file formats).
–understanding of logical and physical database structures.
–the ability to communicate effectively with IT and related functions to achieve efficient data acquisition and analysis.
–the ability to perform ad hoc data analysis as required to meet specific fraud examiner and fraud prevention objectives.
–the ability to design, build, and maintain well-documented, ongoing automated data analysis routines.
–the ability to provide consultative assistance to others who are involved in the application of analytics.

Taken Hostage

by Rumbi Petrozzello
2019 Vice President – Central Virginia ACFE Chapter

On March 22, 2018, I flew into the Atlanta Airport and stopped by the airport’s EMS offices to request an incident report. The gentleman who greeted me at the entrance to the offices was very kind and asked me to wait while he pulled up the details of the report for me. He called over to his coworker, who was sitting in front of a computer, and asked him for help. I heard the coworker clicking on his mouse a few times and then he said that his machine didn’t seem to be working. “It hasn’t been working all morning,” he added. The gentleman then gave me a phone number to call for assistance and apologized for not being more helpful. After I called the number, got voicemail and left a message, I became concerned because I was leaving the country the next day for a week and a half and so hoped that someone would get back to me that day.

Unfortunately, no one had called me back by the time I left. When I returned, I found no voicemail. I called again and left a message. A week after that, the airport EMS Chief returned my call with apologies for the delay – their computers had been down, and he was only now able to start getting back to people. Because I had been out of the country and not really following the news, it was only after a couple of months that I put two and two together. At that point I was working on Eye on Fraud, a publication of the AICPA’s Fraud Task Force. The edition was on Ransomware and as I looked at the information concerning Atlanta, I noticed the dates and realized that the day that I flew into Atlanta and visited the EMS office was the same day that the city of Atlanta was struck by a ransomware attack that crippled the city for over a week and resulted in costs to the city exceeding $2.6 million; a lot more than the $52,000 that was demanded in ransom by the attackers. In late November, two Iranians were indicted for the Atlanta and other attacks. The Atlanta ransomware attack featured many characteristics shared by such attacks, be they on individuals, companies, or governments.

Ransomware attacks have been a problem for decades; the first such documented attack took place in 1989. At that time the malicious code was delivered to victims’ computers via floppy disk and the whole exploit was very easy for victims to reverse. 2006 saw a big uptick in ransomware attacks and, today, ransomware is big business for individual cyber criminals and for organized gangs alike, earning them about a billion dollars in 2016.

Ransomware is a form of malware (malicious software), and works in one of two general ways:

1. Crypto-ransomware encrypts hard drives or files and folders.
2. Locker-ransomware locks users out of their machines, without employing encryption.

As time has gone on, ransomware has become more complex and ransomware attacks more sophisticated. One way in which cyber criminals break into computer systems is via human engineering. This can take the form of an email with a malicious attachment or a link to a compromised website. Cyber criminals also take advantage of known weaknesses in computer operating systems. The WannaCry ransomware, which swept the globe several years ago, took advantage of a flaw in Microsoft Windows. This underscores how essential it is to provide cyber training to employees and to update this training often. Employees must be taught to always be vigilant and on the lookout for such attacks, and to maintain awareness of how such threats are constantly changing and migrating. All it takes is a single employee lapse in judgment and attention for malware to get into a business’s computer system. It’s also essential to keep computers and software up to date with the latest patches. WannaCry was successful in part because Microsoft had discontinued its support of some versions of Windows, including for Windows XP and Windows Server 2003. The amount of money companies thought they were saving by continuing to use old unsupported software was dwarfed by the cost of recovery from malware attacks specifically targeting that software.

When CFEs and forensic accountants dialogue with clients about ransomware attack scenarios, we should remind them that cyber criminals are equal opportunity offenders when it comes to such exploits. Employees should be alert to this whether they are working on an employer’s machine or on a personal one. Ransomware has now made its way into the smartphone space, so employees should be made aware that heightened vigilance should extend even to their smartphones. CFEs should additionally work with clients to fund penetration and phishing tests to determine how effective staff training has been and to highlight areas for improvement.

Both individuals and companies should have a plan on how they will deal with a possible ransomware attack. A well-thought out plan can minimize the effects of an attack and can also mean that the reaction to the attack is measured and not mounted on the basis of uncoordinated panic. For example, when LabCorp was attacked in July 2018, the company contained the spread of the malware in less than an hour. Its, therefore, doubly important that we CFEs and forensic accountants work with IT specialists to formulate an advance plan in case of a ransomware or other malware, attack.

Experts recommend that ransom should not be paid. Clients need to be made to understand that when their systems are taken hostage, they are dealing with criminals and criminals are, more often than not, not to be trusted. When the city of Leeds, Alabama, was attacked, the city paid the cyber criminals $12,000 in ransom. Despite making this payment, the hackers restored only a limited number of files. The city was then faced with the expenditure of additional funds in the attempt to recover or rebuild the remaining files. Sometimes hackers will disappear with ransom and restore nothing. In the face of this, companies and individuals should be encouraged to have back up and restoration plans. To be useful, backups must be made regularly and kept physically separate from the machine or network being protected. The recovery plan should be tested at least annually.

Ransomware exploits are not going away any time soon. Ransomware attacks are a way to get money, not only through the ransom demanded itself but also through access to other sensitive information belonging to employees and clients. Often the hacker will demand a nominal amount in ransom and sell the information stolen by access to the company’s network for a lot more.

We, as CFEs and forensic accountants, can help our client address the ballooning threat in a number of ways:

• by performing a risk assessments of clients’ systems and processes, to identify weaknesses and areas for control improvement.
• by providing staff training on security best practices. This training should be updated at least once a year; in addition to updating staff on changes, this will also serve to remind employees to be vigilant. This training must include everyone in a company, even top management and the board.
• by reminding clients to keep software up to date and to consider upgrades or total changes when an application is no longer supported. Encourage management to have software updates automated on employees’ machines.
• by working with clients to create a backup and recovery system, that features off-site backups. This program should be tested regularly, and backups should be reviewed to ensure their integrity.
• by working with IT and third-party vendors on annual penetration and social engineering testing at client locations. The third-party vendors used should be rotated ever three years.

CSO Online predicts that ransomware attacks will rise to one every 14 seconds by the end of 2019. We CFEs and forensic accountants should work with our clients to innovate effective ways to protect themselves and to mitigate the effects of the future attacks that certainly will occur. The key is to ensure that clients remain educated, vigilant and prepared.

Regulating the Financial Data Breach

During several years of my early career, I was employed as a Manager of Operations Research by a mid-sized bank holding company. My small staff and I would endlessly discuss issues related to fraud prevention and develop techniques to keep our customer’s checking and savings accounts safe, secure and private. A never ending battle!

It was a simpler time back then technically but since a large proportion of fraud committed against banks and financial institutions today still involves the illegal use of stolen customer or bank data, some of the newest and most important laws and regulations that management assurance professionals, like CFEs, must be aware of in our practice, and with which our client banks must comply, relate to the safeguarding of confidential data both from internal theft and from breaches of the bank’s information security defenses by outside criminals.

As the ACFE tells us, there is no silver bullet for fully protecting any organization from the ever growing threat of information theft. Yet full implementation of the measures specified by required provisions of now in place federal banking regulators can at least lower the risk of a costly breach occurring. This is particularly true since the size of recent data breaches across all industries have forced Federal enforcement agencies to become increasingly active in monitoring compliance with the critical rules governing the safeguarding of customer credit card data, bank account information, Social Security numbers, and other personal identifying information. Among these key rules are the Federal Reserve Board’s Interagency Guidelines Establishing Information Security Standards, which define customer information as any record containing nonpublic personal information about an individual who has obtained a financial product or service from an institution that is to be used primarily for personal, family, or household purposes and who has an ongoing relationship with the institution.

Its important to realize that, under the Interagency Guidelines, customer information refers not only to information pertaining to people who do business with the bank (i.e., consumers); it also encompasses, for example, information about (1) an individual who applies for but does not obtain a loan; (2) an individual who guarantees a loan; (3) an employee; or (4) a prospective employee. A financial institution must also require, by contract, its own service providers who have access to consumer information to develop appropriate measures for the proper disposal of the information.

The FRB’s Guidelines are to a large extent drawn from the information protection provisions of the Gramm Leach Bliley Act (GLBA) of 1999, which repealed the Depression-era Glass-Steagall Act that substantially restricted banking activities. However, GLBA is best known for its formalization of legal standards for the protection of private customer information and for rules and requirements for organizations to safeguard such information. Since its enactment, numerous additional rules and standards have been put into place to fine-tune the measures that banks and other organizations must take to protect consumers from the identity-related crimes to which information theft inevitably leads.

Among GLBA’s most important information security provisions affecting financial institutions is the so-called Financial Privacy Rule. It requires banks to provide consumers with a privacy notice at the time the consumer relationship is established and every year thereafter.

The notice must provide details collected about the consumer, where that information is shared, how that information is used, and how it is protected. Each time the privacy notice is renewed, the consumer must be given the choice to opt out of the organization’s right to share the information with third-party entities. That means that if bank customers do not want their information sold to another company, which will in all likelihood use it for marketing purposes, they must indicate that preference to the financial institution.

CFEs should note , that most pro-privacy advocacy groups strongly object to this and other privacy related elements of GLBA because, in their view, these provisions do not provide substantive protection of consumer privacy. One major advocacy group has stated that GLBA does not protect consumers because it unfairly places the burden on the individual to protect privacy with an opt-out standard. By placing the burden on the customer to protect his or her data, GLBA weakens customer power to control their financial information. The agreement’s opt-out provisions do not require institutions to provide a standard of protection for their customers regardless of whether they opt-out of the agreement. This provision is based on the assumption that financial companies will share information unless expressly told not to do so by their customers and, if customers neglect to respond, it gives institutions the freedom to disclose customer nonpublic personal information.

CFEs need to be aware, however, that for bank clients, regardless of how effective, or not, GLBA may be in protecting customer information, noncompliance with the Act itself is not an option. Because of the current explosion in breaches of bank information security systems, the privacy issue has to some degree been overshadowed by the urgency to physically protect customer data; for that reason, compliance with the Interagency Guidelines concerning information security is more critical than ever. The basic elements partially overlap with the preventive measures against internal bank employee abuse of the bank’s computer systems. However, they go quite a bit further by requiring banks to:

—Design an information security program to control the risks identified through a security risk assessment, commensurate with the sensitivity of the information and the complexity and scope of its activities.
—Evaluate a variety of policies, procedures, and technical controls and adopt those measures that are found to most effectively minimize the identified risks.
—Application and enforcement of access controls on customer information systems, including controls to authenticate and permit access only to authorized individuals and to prevent employees from providing customer information to unauthorized individuals who may seek to obtain this information through fraudulent means.
—Access restrictions at physical locations containing customer information, such as buildings, computer facilities, and records storage facilities to permit access only to authorized individuals.
—Encryption of electronic customer information, including while in transit or in storage on networks or systems to which unauthorized individuals may gain access.
—Procedures designed to ensure that customer information system modifications are consistent with the institution’s information security program.
—Dual control procedures, segregation of duties, and employee background checks for employees with responsibilities for or access to customer information.
—Monitoring systems and procedures to detect actual and attempted attacks on or intrusions into customer information systems.
—Response programs that specify actions to be taken when the institution suspects or detects that unauthorized individuals have gained access to customer information systems, including appropriate reports to regulatory and law enforcement agencies.
—Measures to protect against destruction, loss, or damage of customer information due to potential environmental hazards, such as fire and water damage or technological failures.

The Interagency Guidelines require a financial institution to determine whether to adopt controls to authenticate and permit only authorized individuals access to certain forms of customer information. Under this control, a financial institution also should consider the need for a firewall to safeguard confidential electronic records. If the institution maintains Internet or other external connectivity, its systems may require multiple firewalls with adequate capacity, proper placement, and appropriate configurations.

Similarly, the institution must consider whether its risk assessment warrants encryption of electronic customer information. If it does, the institution must adopt necessary encryption measures that protect information in transit, in storage, or both. The Interagency Guidelines do not impose specific authentication or encryption standards, so it is advisable for CFEs to consult outside experts on the technical details applicable to your client institution’s security requirements especially when conducting after the fact fraud examinations.

The financial institution also must consider the use of an intrusion detection system to alert it to attacks on computer systems that store customer information. In assessing the need for such a system, the institution should evaluate the ability, or lack thereof, of its staff to rapidly and accurately identify an intrusion. It also should assess the damage that could occur between the time an intrusion occurs and the time the intrusion is recognized and action is taken.

The regulatory agencies have also provided our clients with requirements for responding to information breaches. These are contained in a related document entitled Interagency Guidance on Response Programs for Unauthorized Access to Customer Information and Customer Notice (Incident Response Guidance). According to the Incident Response Guidance, a financial institution should develop and implement a response program as part of its information security program. The response program should address unauthorized access to or use of customer information that could result in substantial harm or inconvenience to a customer.

Finally, the Interagency Guidelines require financial institutions to train staff to prepare and implement their information security programs. The institution should consider providing specialized training to ensure that personnel sufficiently protect customer information in accordance with its information security program.

For example, an institution should:

—Train staff to recognize and respond to schemes to commit fraud or identity theft, such as guarding against pretext spam calling.
—Provide staff members responsible for building or maintaining computer systems and local and wide area networks with adequate training, including instruction about computer security.
—Train staff to properly dispose of customer information.

Targeting the Blockchain

Both the blockchain and its digital engineering support structures underlying the digital currencies that are fast becoming the financial and transactional media of choice for the nefarious, are now increasingly finding themselves under various modes of fraudster attack.

Bitcoins, the most familiar blockchain application, were invented in 2009 by a mysterious person (or group of people) using the alias Satoshi Nakamoto, and the coins are created or ‘mined’ by solving increasingly difficult mathematical equations, requiring extensive computing power. The system is designed to ensure no more than twenty-one million Bitcoins are ever generated, thereby preventing a central authority from flooding the market with new Bitcoins. Most Bitcoins are purchased on third-party exchanges with traditional currencies, such as dollars or euros, or with credit cards. The exchange rates against the dollar for Bitcoin fluctuate wildly and have ranged from fifty cents per coin around the time of its introduction to over $1,240 in 2013 to around $600 today.

The whole point of using a blockchain is to let people, in particular, people who don’t trust one another, share valuable data in a secure, tamper-proof way. That’s because blockchains store data using sophisticated math and innovative software rules that are extremely difficult for attackers to manipulate. But as cases like the Mount Gox Bitcoin hack demonstrate, the security of even the best designed blockchain and associated support systems can fail in places where the fancy math and software rules come into contact with humans; humans who are skilled fraudsters, in the real world, where things quickly get messy. For CFEs to understand why, start with what makes blockchains “secure” in principle. Bitcoin is a good example. In Bitcoin’s blockchain, the shared data is the history of every Bitcoin transaction ever made: it’s a plain old accounting ledger. The ledger is stored in multiple copies on a network of computers, called “nodes:’ Each time someone submits a transaction to the ledger, the nodes check to make sure the transaction is valid, that whoever spent a bitcoin had a bitcoin to spend. A subset of the nodes competes to package valid transactions into “blocks” and add them to a chain of previous blocks. The owners of these nodes are called miners. Miners who successfully add new blocks to the chain earn bitcoins as a reward.

What makes this system theoretically tamperproof is two things: a cryptographic fingerprint unique to each block, and a consensus protocol, the process by which the nodes in the network agree on a shared history. The fingerprint, called a hash, takes a lot of computing time and energy to generate initially. It thus serves as proof that the miner who added the block to the blockchain did the computational work to earn a bitcoin reward (for this reason, Bitcoin is said to employ a proof-of-work protocol). It also serves as a kind of seal, since altering the block would require generating a new hash. Verifying whether or not the hash matches its block, however, is easy, and once the nodes have done so they update their respective copies of the blockchain with the new block. This is the consensus protocol.

The final security element is that the hashes also serve as the links in the blockchain: each block includes the previous block’s unique hash. So, if you want to change an entry in the ledger retroactively, you have to calculate a new hash not only for the block it’s in but also for every subsequent block. And you have to do this faster than the other nodes can add new blocks to the chain. Consequently, unless you have computers that are more powerful than the rest of the nodes combined (and even then, success isn’t guaranteed), any blocks you add will conflict with existing ones, and the other nodes will automatically reject your alterations. This is what makes the blockchain tamperproof, or immutable.

The reality, as experts are increasingly pointing out, is that implementing blockchain theory in actual practice is difficult. The mere fact that a system works like Bitcoin, as many copycat cryptocurrencies do, doesn’t mean it’s just as secure as Bitcoin. Even when developers use tried and true cryptographic tools, it’s easy to accidentally put them together in ways that are not secure. Bitcoin has been around the longest, so it’s just the most thoroughly battle-tested.

As the ACFE and others have indicated, fraudsters have also found creative ways to cheat. Its been shown that there is a way to subvert a blockchain even if you have less than half the mining power of the other miners. The details are somewhat technical, but essentially a “selfish miner” can gain an unfair advantage by fooling other nodes into wasting time on already-solved crypto-puzzles.

The point is that no matter how tamperproof a blockchain protocol is, it does not exist in a vacuum. The cryptocurrency hacks driving recent headlines are usually failures at places where blockchain systems connect with the real world, for example, in software clients and third-party applications. Hackers can, for instance, break into hot wallets, internet-connected applications for storing the private cryptographic keys that anyone who owns cryptocurrency requires in order to spend it. Wallets owned by online cryptocurrency exchanges have become prime targets. Many exchanges claim they keep most of their users’ money in cold hardware wallets, storage devices disconnected from the internet. But as the recent heist of more than $500 million worth of cryptocurrency from a Japan based exchange showed, that’s not always the case.

Perhaps the most complicated touchpoints between blockchains and the real world are smart contracts, which are computer programs stored in certain kinds of blockchain that can automate financial and other contract related business transactions. Several years ago, hackers exploited an unforeseen quirk in a smart contract written on Ethereum’s blockchain to steal 3.6 million Ether, worth around $80 million at the time from a new kind of blockchain-based investment fund. Since the investment fund’s code lived on the blockchain, the Ethereum community had to push a controversial software upgrade called a hard fork to get the money back, essentially creating a new version of history in which the money was never stolen. According to a number of experts, researchers are scrambling to develop other methods for ensuring that smart contracts won’t malfunction.

An important supposed security guarantee of a blockchain system is decentralization. If copies of the blockchain are kept on a large and widely distributed network of nodes, there’s no one weak point to attack, and it’s hard for anyone to build up enough computing power to subvert the network. But recent reports in the trade press indicate that neither Bitcoin nor Ethereum is as decentralized as the public has been led to believe. The reports indicate that the top four bitcoin-mining operations had more than 53 percent of the system’s average mining capacity per week. By the same measure, three Ethereum miners accounted for 61 percent of Ethereum transactions.

Some experts say alternative consensus protocols, perhaps ones that don’t rely on mining, could be more secure. But this hypothesis hasn’t been tested at a large scale, and new protocols would likely have their own security problems. Others see potential in blockchains that require permission to join, unlike in Bitcoin’s case, where anyone who downloads the software can join the network.

Such consensus systems are anathema to the antihierarchical ethos of cryptocurrencies, but the approach appeals to financial and other institutions looking to exploit the advantages of a shared cryptographic database. Permissioned systems, however, raise their own questions. Who has the authority to grant permission? How will the system ensure that the validators are who they say they are? A permissioned system may make its owners feel more secure, but it really just gives them more control, which means they can make changes whether or not other network participants agree, something true believers would see as violating the very idea of blockchain.

So, in the end, for CFEs, the word ‘secure’ ends up being very hard to define in the context of blockchains. Secure from whom? Secure for what?

A final thought for CFEs and forensic accountants. There are no real names stored on the Bitcoin blockchain, but it records every transaction made by your user client; every time the currency is used the user risks exposing information that can tie his or her identity to those actions. It is known from documents leaked by Edward Snowden that the US National Security Agency has sought ways of connecting activity on the Bitcoin blockchain to people in the physical world. Should governments seek to create and enforce blacklists, they will find that the power to decide which transactions to honor may lie in the hands of just a few Bitcoin miners.

Fraud Prevention Oriented Data Mining

One of the most useful components of our Chapter’s recently completed two-day seminar on Cyber Fraud & Data Breaches was our speaker, Cary Moore’s, observations on the fraud fighting potential of management’s creative use of data mining. For CFEs and forensic accountants, the benefits of data mining go much deeper than as just a tool to help our clients combat traditional fraud, waste and abuse. In its simplest form, data mining provides automated, continuous feedback to ensure that systems and anti-fraud related internal controls operate as intended and that transactions are processed in accordance with policies, laws and regulations. It can also provide our client managements with timely information that can permit a shift from traditional retrospective/detective activities to the proactive/preventive activities so important to today’s concept of what effective fraud prevention should be. Data mining can put the organization out front of potential fraud vulnerability problems, giving it an opportunity to act to avoid or mitigate the impact of negative events or financial irregularities.

Data mining tests can produce “red flags” that help identify the root cause of problems and allow actionable enhancements to systems, processes and internal controls that address systemic weaknesses. Applied appropriately, data mining tools enable organizations to realize important benefits, such as cost optimization, adoption of less costly business models, improved program, contract and payment management, and process hardening for fraud prevention.

In its most complex, modern form, data mining can be used to:

–Inform decision-making
–Provide predictive intelligence and trend analysis
–Support mission performance
–Improve governance capabilities, especially dynamic risk assessment
–Enhance oversight and transparency by targeting areas of highest value or fraud risk for increased scrutiny
–Reduce costs especially for areas that represent lower risk of irregularities
–Improve operating performance

Cary emphasized that leading, successful organizational implementers have tended to take a measured approach initially when embarking on a fraud prevention-oriented data mining initiative, starting small and focusing on particular “pain points” or areas of opportunity to tackle first, such as whether only eligible recipients are receiving program funds or targeting business processes that have previously experienced actual frauds. Through this approach, organizations can deliver quick wins to demonstrate an early return on investment and then build upon that success as they move to more sophisticated data mining applications.

So, according to ACFE guidance, what are the ingredients of a successful data mining program oriented toward fraud prevention? There are several steps, which should be helpful to any organization in setting up such an effort with fraud, waste, abuse identification/prevention in mind:

–Avoid problems by adopting commonly used data mining approaches and related tools.

This is essentially a cultural transformation for any organization that has either not understood the value these tools can bring or has viewed their implementation as someone else’s responsibility. Given the cyber fraud and breach related challenges faced by all types of organizations today, it should be easier for fraud examiners and forensic accountants to convince management of the need to use these tools to prevent problems and to improve the ability to focus on cost-effective means of better controlling fraud -related vulnerabilities.

–Understand the potential that data mining provides to the organization to support day to day management of fraud risk and strategic fraud prevention.

Understanding, both the value of data mining and how to use the results, is at the heart of effectively leveraging these tools. The CEO and corporate counsel can play an important educational and support role for a program that must ultimately be owned by line managers who have responsibility for their own programs and operations.

–Adopt a version of an enterprise risk management program (ERM) that includes a consideration of fraud risk.

An organization must thoroughly understand its risks and establish a risk appetite across the enterprise. In this way, it can focus on those area of highest value to the organization. An organization should take stock of its risks and ask itself fundamental questions, such as:

-What do we lose sleep over?
-What do we not want to hear about us on the evening news or read about in the print media or on a blog?
-What do we want to make sure happens and happens well?

Data mining can be an integral part of an overall program for enterprise risk management. Both are premised on establishing a risk appetite and incorporating a governance and reporting framework. This framework in turn helps ensure that day-to-day decisions are made in line with the risk appetite, and are supported by data needed to monitor, manage and alleviate risk to an acceptable level. The monitoring capabilities of data mining are fundamental to managing risk and focusing on issues of importance to the organization. The application of ERM concepts can provide a framework within which to anchor a fraud prevention program supported by effective data mining.

–Determine how your client is going to use the data mined information in managing the enterprise and safeguarding enterprise assets from fraud, waste and abuse.

Once an organization is on top of the data, using it effectively becomes paramount and should be considered as the information requirements are being developed. As Cary pointed out, getting the right data has been cited as being the top challenge by 20 percent of ACFE surveyed respondents, whereas 40 percent said the top challenge was the “lack of understanding of how to use analytics”. Developing a shared understanding so that everyone is on the same page is critical to success.

–Keep building and enhancing the application of data mining tools.

As indicated above, a tried and true approach is to begin with the lower hanging fruit, something that will get your client started and will provide an opportunity to learn on a smaller scale. The experience gained will help enable the expansion and the enhancement of data mining tools. While this may be done gradually, it should be a priority and not viewed as the “management reform initiative of the day. There should be a clear game plan for building data mining capabilities into the fiber of management’s fraud and breach prevention effort.

–Use data mining as a tool for accountability and compliance with the fraud prevention program.

It is important to hold managers accountable for not only helping institute robust data mining programs, but for the results of these programs. Has the client developed performance measures that clearly demonstrate the results of using these tools? Do they reward those managers who are in the forefront in implementing these tools? Do they make it clear to those who don’t that their resistance or hesitation are not acceptable?

–View this as a continuous process and not a “one and done” exercise.

Risks change over time. Fraudsters are always adjusting their targets and moving to exploit new and emerging weaknesses. They follow the money. Technology will continue to evolve, and it will both introduce new risks but also new opportunities and tools for management. This client management effort to protect against dangers and rectify errors is one that never ends, but also one that can pay benefits in preventing or managing cyber-attacks and breaches that far outweigh the costs if effectively and efficiently implemented.

In conclusion, the stark realities of today’s cyber related challenges at all levels of business, private and public, and the need to address ever rising service delivery expectations have raised the stakes for managing the cost of doing business and conducting the on-going war against fraud, waste and abuse. Today’s client-managers should want to be on top of problems before they become significant, and the strategic use of data mining tools can help them manage and protect their enterprises whilst saving money…a win/win opportunity for the client and for the CFE.

Every Seat Taken!

Our Chapter’s thanks to all our attendees and to our partners, the Virginia State Police and national ACFE for the unqualified success of our May training event, Cyberfraud and Data Breaches! Our speaker, Cary Moore, CFE, CISSP, conducted a fully interactive, two-day session on one of the most challenging and relevant topics confronting practicing fraud examiners and forensic accountants today.

The event examined the potential avenues of data loss and guided attendees through the crucial strategies needed to mitigate the threat of malicious data theft and the risk of inadvertent data loss, recognizing that information is a valuable asset, and that management must take proactive steps to protect the organization’s intellectual property. As Cary forcefully pointed out, the worth of businesses is no longer based solely on tangible assets and revenue-making potential; the information the organization develops, stores, and collects accounts for a large share of its value.

A data breach occurs when there is a loss or theft of, or unauthorized access to, proprietary information that could result in compromising the data. It is essential that management understand the crisis its organization might face if its information is lost or stolen. Data breaches incur not only high financial costs but can also have a lasting negative effect on an organization’s brand and reputation.

Protecting information assets is especially important because the threats to such assets are on the rise, and the cost of a data breach increases with the number of compromised records. According to a 2017 study by the Ponemon Institute, data breaches involving fewer than 10,000 records caused an average loss of $1.9 million, while beaches with more than 50,000 compromised records caused an average loss of $6.3 million. However, before determining how to protect information assets, it is important to understand the nature of these assets and the many methods by which they can be breached.

Intellectual property is a catchall phrase for knowledge-based assets and capital, but it’s helpful to think of it as intangible proprietary information. Intellectual property (IP) is protected by law. IP law grants certain exclusive rights to owners of a variety of intangible assets. These rights incentivize individuals, company leaders, and investors to allocate the requisite resources to research, develop, and market original technology and creative works.

A trade secret is any idea or information that gives its owner an advantage over its competitors. Trade secrets are particularly susceptible to theft because they provide a competitive advantage. What constitutes a trade secret, however, depends on the organization, industry, and jurisdiction, but generally, to be classified as a trade secret, information must:

• Be secret: The information is not generally known to the relevant portion of the public.
• Confer some sort of economic benefit on its holder: The idea or information must give its owner an advantage over its competitors. The benefit conferred from the information, however, must stem from not being generally known, not just from the value of the information itself. The best test for determining what is confidential information is to determine whether the information would provide an advantage to the competition.
• Be the subject of reasonable efforts to maintain its secrecy: The owner must take reasonable steps to protect its trade secrets from disclosure. That is, a piece of information will not receive protection as a trade secret if the owner does not take adequate steps to protect it from disclosure.

Cary presented in-depth information on the various types of threats to data security including:

–Insiders
–Hackers
–Competitors
–Organized criminal groups
–Government-sponsored groups

Protecting proprietary information is a timely issue, but it is difficult. The event presented a list of common challenges faced when protecting information assets:

–Proprietary information is among the most valuable commodities, and attackers are doing everything in their power to steal as much of this information as possible.
–The risk of data breaches for organizations is high.
–New and emerging technologies create new risks and vulnerabilities.
— IT environments are becoming increasingly complex, making the management of them more expensive, difficult, and time consuming.
–There is a wider range of devices and access points, so businesses must proactively seek ways to combat the effects of this complexity.
–The rise in portable devices is creating more opportunities for data to “leak” from the business.
–The rise in Bring Your Own Device (BYOD) initiatives is generating new operational challenges and security problems.
–The rapidly expanding Internet of Things (IoT) has significantly increased the number of network connected things (e.g., HVAC systems, MRI machines, coffeemakers) that pose data security threats, many of which were inconceivable only a short time ago.
–The number of threats to corporate IT systems is on the rise.
–Malware is becoming more sophisticated.
–There is an increasing number of laws in this area, making information security an urgent priority.

Cary covered the entire gamut of challenges related to cyber fraud and data breaches ranging from legal issues, corporate espionage, social engineering, the use of social media, the bring-your-own-devices phenomenon, and the impact of cloud computing. The remaining portion of the event was devoted to addressing how enterprises can effectively respond when confronted by the challenges posed by these issues including breach response team building and breach prevention techniques like conducting security risk assessments, staff awareness training and the incident response plan.

When an organization experiences a data breach, management must respond in an appropriate and timely manner. During the initial response, time is critical. To help ensure that an organization responds to data breaches timely and efficiently, management should have an incident response plan in place that outlines how to respond to such issues. Timely responses can help prevent further data loss, fines, and customer backlash. An incident response plan outlines the actions an organization will take when data breaches occur. More specifically, a response plan should guide the necessary action when a data breach is reported or identified. Because every breach is different, a response plan should not outline how an organization should respond in every instance. Instead, a response plan should help the organization manage its response and create an environment to minimize risk and maximize the potential for success. In short, a response plan should describe the plan fundamentals that the organization can deploy on short notice.

Again, our sincere thanks go out to all involved in the success of this most worthwhile training event!

Cyberfraud & Data Breaches – May 2018 Training Event

On May 16th and 17th, our Chapter, supported by our partners, national ACFE and the Virginia State Police, will present our sixteenth Spring training event, this time on the subject of CYBERFRAUD AND DATA BREACHES.  Our presenter will be CARY E. MOORE, CFE, CISSP, MBA; ACFE Presenter Board member and internationally renowned author and authority on every aspect of cybercrime.  CLICK HERE  to see an outline of the training, the agenda and Cary’s bio.  If you decide to do so, you may REGISTER HERE.  Attendees will receive 16 CPE credits, and a printed manual of over 300 pages detailing every subject covered in the training.  In addition, as a door prize, we will be awarding, by drawing, a printed copy of the 2017 Fraud Examiners Manual, a $200 value!

As the relentless wave of cyberattacks continues, all our client organizations are under intense pressure from key stakeholders and regulators to implement and enhance their anti-fraud programs to protect customers, employees and the valuable information in their possession. According to research from IBM Security and the Ponemon Institute, the average total cost per company, per event of a data breach is US $3.62 million. Initial damage estimates of a single breach, while often staggering, may not consider less obvious and often undetectable threats such as theft of intellectual property, espionage, destruction of data, attacks on core operations or attempts to disable critical infrastructure. These knock-on effects can last for years and have devastating financial, operational and brand ramifications.

Given the broad regulatory pressures to tighten anti-fraud cyber security controls and the visibility surrounding cyber risk, a number of proposed regulations focused on improving cyber security risk management programs have been introduced in the United States over the past few years by various governing bodies of which CFEs need to be aware. One of the more prominent is a regulation issued by the New York Department of Financial Services (NYDFS) that prescribes certain minimum cyber security standards for those entities regulated by the NYDFS. Based on the entity’s risk assessment, the NYDFS law has specific requirements around data encryption, protection and retention, third party information security, application security, incident response and breach. notification, board reporting, and annual certifications.

However, organizations continue to struggle to report on the overall effectiveness of their cyber security risk management and anti-fraud programs. The American Institute of Certified Public Accountants (AICPA) has released a cyber security risk management reporting framework intended to help organizations expand cyber risk reporting to a broad range of internal and external users, including the C-suite and the board of directors (BoD). The AICPA’s reporting framework is designed to address the need for greater stakeholder transparency by providing in-depth, easily consumable information about an organization’s cyber risk management  program. The cyber security risk management examination uses an independent, objective reporting approach and employs broader and more flexible criteria. For example, it allows for the selection and utilization of any control framework considered suitable and available in establishing the entity’s cyber security objectives and developing and maintaining controls within the entity’s cyber security risk management program, whether it is the US National Institute of Standards and Technology (NIST)’s Cybersecurity Framework, the International Organization for Standardization (ISO)’s ISO 27001/2 and related frameworks, or internally developed frameworks based on a combination of sources. The examination is voluntary, and applies to all types of entities, but should be considered a leading practice that provides the C-suite, boards and other key stakeholders clear insight into an organization’s cyber security program and identifies gaps or pitfalls that leave organizations vulnerable.

Cyber security risk management examination reports are vital to the fraud control program of any organization doing business on-line.  Such reports help an organization’s BoD establish appropriate oversight of a company’s cyber security risk program and credibly communicate its effectiveness to stakeholders, including investors, analysts, customers, business partners and regulators. By leveraging this information, boards can challenge management’s assertions around the effectiveness of their cyber risk management programs and drive more effective decision making. Active involvement and oversight from the BoD can help ensure that an organization is paying adequate attention to cyber risk management. The board can help shape expectations for reporting on cyber threats and fraud attempts while also advocating for greater transparency and assurance around the effectiveness of the program.

Organizations that choose to utilize the AICPA’s cyber security attestation reporting framework and perform an examination of their cyber security program may be better positioned to gain competitive advantage and enhance their brand in the marketplace. For example, an outsource retail service provider (OSP) that can provide evidence that a well-developed and sound cyber security risk management program is in place in its organization can proactively provide the report to current and potential customers, evidencing that it has implemented appropriate controls to protect the sensitive IT assets and valuable data over which it maintains access. At the same time, current and potential retailor customers of an OSP want the third parties with whom they engage to also place a high level of importance on cyber security. Requiring a cyber security examination report as part of the selection criteria would offer transparency into  outsourcers’ cyber security programs and could be a determining factor in the selection process.

The value of addressing cyber security related fraud concerns and questions by CFEs before regulatory mandates are established or a crisis occurs is quite clear. The knowledgeable CFE can help our client organizations view the new cyber security attestation reporting frameworks as an opportunity to enhance their existing cyber security and anti-fraud programs and gain competitive advantage. The attestation reporting frameworks address the needs of a variety of key stakeholder groups and, in turn, limit the communication and compliance burden. CFE client organizations that view the cyber security reporting landscape as an opportunity can use it to lead, navigate and disrupt in today’s rapidly evolving cyber risk environment.

Please decide to join us for our May Training Event on this vital and timely topic!  YOU MAY REGISTER 0N-LINE HERE.  You can pay with PayPal (you don’t need a PayPal account; you can use any credit card) or just print an invoice and submit your payment by snail mail!

The Anti-Fraud Blockchain

Blockchain technology, the series of interlocking algorithms powering digital currencies like BitCoin, is emerging as a potent fraud prevention tool.  As every CFE knows, technology is enabling new forms of money and contracting, and the growing digital economy holds great promise to provide a full range of new financial tools, especially to the world’s poor and unbanked. These emerging virtual currencies and financial techniques are often anonymous, and none have received quite as much press as Bitcoin, the decentralized peer-to-peer digital form of money.

Bitcoins were invented in 2009 by a mysterious person (or group of people) using the alias Satoshi Nakamoto, and the coins are created or “mined” by solving increasingly difficult mathematical equations, requiring extensive computing power. The system is designed to ensure no more than twenty-one million Bitcoins are ever generated, thereby preventing a central authority from flooding the market with new Bitcoins. Most people purchase Bitcoins on third-party exchanges with traditional currencies, such as dollars or euros, or with credit cards. The exchange rates against the dollar for Bitcoin fluctuate wildly and have ranged from fifty cents per coin around the time of its introduction to over $16,0000 in December 2017. People can send Bitcoins, or percentages of bitcoin, to each other using computers or mobile apps, where coins are stored in digital wallets. Bitcoins can be directly exchanged between users anywhere in the world using unique alphanumeric identifiers, akin to e-mail addresses, and there are no transaction fees in the basic system, absent intermediaries.

Anytime a purchase takes place, it is recorded in a public ledger known as the “blockchain,” which ensures no duplicate transactions are permitted. Crypto currencies are called such because they use cryptography to regulate the creation and transfer of money, rather than relying on central authorities. Bitcoin acceptance continues to grow rapidly, and it is possible to use Bitcoins to buy cupcakes in San Francisco, cocktails in Manhattan, and a Subway sandwich in Allentown.

Because Bitcoin can be spent online without the need for a bank account and no ID is required to buy and sell the crypto currency, it provides a convenient system for anonymous, or more precisely pseudonymous, transactions, where a user’s true name is hidden. Though Bitcoin, like all forms of money, can be used for both legal and illegal purposes, its encryption techniques and relative anonymity make it strongly attractive to fraudsters and criminals of all kinds. Because funds are not stored in a central location, accounts cannot readily be seized or frozen by police, and tracing the transactions recorded in the blockchain is significantly more complex than serving a subpoena on a local bank operating within traditionally regulated financial networks. As a result, nearly all the so-called Dark Web’s illicit commerce is facilitated through alternative currency systems. People do not send paper checks or use credit cards in their own names to buy meth and pornography. Rather, they turn to anonymous digital and virtual forms of money such as Bitcoin.

A blockchain is, essentially, a way of moving information between parties over the Internet and storing that information and its transaction history on a disparate network of computers. Bitcoin, and all the other digital currencies, operates on a blockchain: as transactions are aggregated into blocks, each block is assigned a unique cryptographic signature called a “hash.” Once the validating cryptographic puzzle for the latest block has been solved by a coin mining computer, three things happen: the result is timestamped, the new block is linked irrevocably to the blocks before and after it by its unique hash, and the block and its hash are posted to all the other computers that were attempting to solve the puzzle involved in the mining process for new coins. This decentralized network of computers is the repository of the immutable ledger of bitcoin transactions.  If you wanted to steal a bitcoin, you’d have to rewrite the coin’s entire history on the blockchain in broad daylight.

While bitcoin and other digital currencies operate on a blockchain, they are not the blockchain itself. It’s an insight of many computer scientists that in addition to exchanging digital money, the blockchain can be used to facilitate transactions of other kinds of digitized data, such as property registrations, birth certificates, medical records, and bills of lading. Because the blockchain is decentralized and its ledger immutable, all these types of transactions would be protected from hacking; and because the blockchain is a peer-to-peer system that lets people and businesses interact directly with each other, it is inherently more efficient and  cheaper than current systems that are burdened with middlemen such as lawyers and regulators.

A CFE’s client company that aims to reduce drug counterfeiting could have its CFE investigator use the blockchain to follow pharmaceuticals from provenance to purchase. Another could use it to do something similar with high-end sneakers. Yet another, a medical marijuana producer, could create a blockchain that registers everything that has happened to a cannabis product, from seed to sale, letting consumers, retailers and government regulators know where everything came from and where it went. The same thing can be done with any normal crop so, in the same way that a consumer would want to know where the corn on her table came from, or the apple that she had at lunch originated, all stake holders involved in the medical marijuana enterprise would know where any batch of product originated and who touched it all along the way.

While a blockchain is not a full-on solution to fraud or hacking, its decentralized infrastructure ensures that there are no “honeypots” of data available, like financial or medical records on isolated company servers, for criminals to exploit. Still, touting a bitcoin-derived technology as an answer to cybercrime may seem a stretch considering the high-profile, and lucrative, thefts of cryptocurrency over the past few years. Its estimated that as of March 2015, a full third of  all Bitcoin exchanges, (where people store their bitcoin), up to then had been hacked, and nearly half had closed. There was, most famously, the 2014 pilferage of Mt. Gox, a Japanese based digital coin exchange, in which 850,000 bitcoins worth $460,000,000 disappeared. Two years later another exchange, Bitfinex, was hacked and around $60 million in bitcoin was taken; the company’s solution was to spread the loss to all its customers, including those whose accounts had not been drained.

Unlike money kept in a bank, cryptocurrencies are uninsured and unregulated. That is one of the consequences of a monetary system that exists, intentionally, beyond government control or oversight. It may be small consolation to those who were affected by these thefts that the bitcoin network itself and the blockchain has never been breached, which perhaps proves the immunity of the blockchain to hacking.

This security of the blockchain itself demonstrates how smart contracts can be written and stored on it. These are covenants, written in code, that specify the terms of an agreement. They are smart because as soon as its terms are met, the contract executes automatically, without human intervention. Once triggered, it can’t be amended, tampered with, or impeded. This is programmable money. Such smart contracts are a tool with the potential to change how business in done. The concept, as with digital currencies, is based on computers synced together. Now imagine that rather than syncing a transaction, software is synced. Every machine in the network runs the same small program. It could be something simple, like a loan: A sends B some money, and B’s account automatically pays it back, with interest, a few days later. All parties agree to these terms, and it’s locked in using the smart contract. The parties have achieved programmable money!

There is no doubt that smart contracts and the blockchain itself will augment the trend toward automation, though it is automation through lines of code, not robotics. For businesses looking to cut costs and reduce fraud, this is one of the main attractions of blockchain technology. The challenge is that, if contracts are automated, what will happen to traditional firm control structures, processes, and intermediaries like lawyers and accountants? And what about managers? Their roles would all radically change. Most blockchain advocates imagine them changing so radically as to disappear altogether, taking with them many of the costs currently associated with doing business. According to a recent report in the trade press, the blockchain could reduce banks’ infrastructure costs attributable to cross-border payments, securities trading, and regulatory compliance by $15-20 billion per annum by 2022.  Whereas most technologies tend to automate workers on the periphery, blockchain automates away the center. Instead of putting the taxi driver out of a job, blockchain puts Uber out of a job and lets the taxi drivers work with the customer directly.

Whether blockchain technology will be a revolution for good or one that continues what has come to seem technology’s inexorable, crushing ascendance will be determined not only by where it is deployed, but how. The blockchain could be used by NGOs to eliminate corruption in the distribution of foreign aid by enabling funds to move directly from giver to receiver. It is also a way for banks to operate without external oversight, encouraging other kinds of corruption. Either way, we as CFEs would be wise to remember that technology is never neutral. It is always endowed with the values of its creators. In the case of the blockchain and crypto-currency, those values are libertarian and mechanistic; trust resides in algorithmic rules, while the rules of the state and other regulatory bodies are often viewed with suspicion and hostility.