Steven J. Murdoch

Dr Steven J. Murdoch is a Royal Society University Research Fellow in the Information Security Research Group of University College London, working on banking security, authentication and developing metrics for security and privacy. His research interests also include anonymous communications, censorship resistance and covert channels. He has worked with the OpenNet Initiative, investigating Internet censorship, and for the Tor Project, on improving the security and usability of the Tor anonymity system. He is Innovation Security Architect at OneSpan, an online security technology provider.

Resolving disputes through computer evidence: lessons from the Post Office Trial

On Monday, the final judgement in the Post Office trial was handed down, finding in favour of the claimants on all counts. The outcome will be of particular interest to the group of 587 claimants who brought the case against Post Office Limited, but the judgement also illustrates problems handling evidence generated by computers that have much broader applicability. I think this trial demonstrates that the way such disputes are resolved is not fit for purpose and that changes are needed in both in how computers generate evidence and how such evidence is reasoned about in litigation.

This case centres around disputes between Post Office Limited and sub-postmasters who operate Post Office branches on its behalf. Post Office Limited supplies these sub-postmasters with products to sell, and the computer accounting system – Horizon – for managing the branch. The claimants contend that shortfalls between the money that was in their branch and what Horizon says result from bugs in Horizon or someone maliciously accessing it. The Post Office instead claims that the shortfalls are real, and it is the responsibility of the sub-postmaster to reimburse the Post Office.

Such disputes have resulted in sub-postmasters being bankrupted, and others have even been jailed because the Post Office contends that evidence produced by Horizon demonstrates fraud by the sub-postmaster. The judgement vindicates the sub-postmasters, concluding that Horizon “was not remotely robust”.

This trial is actually the second in this case, with the prior one also finding in favour of the sub-postmasters – that the contractual terms set by Post Office regarding how they investigate and handle shortfalls are unfair. There would have been at least two more trials, had the parties not settled last week with Post Office Limited offering an apology and £58m in compensation. Of this, the vast majority will go towards legal costs and to the fund which bankrolled the litigation – leaving claimants lucky to get much more than £10k on average. Disappointing, sure, but better than nothing and that is what they could have got had the trials and inevitable appeals continued.

As would be expected for a trial depending on highly technical arguments, expert evidence featured heavily. The Post Office expert took a quantitative approach, presenting a statistical argument that claimant’s losses were implausibly high. This argument went by making a rough approximation as to the total losses of all sub-postmasters resulting from bugs in Horizon. Then, by assuming that these losses were spread over all sub-postmasters equally, losses by the 587 claimants would be no more than £25,000 – far less than the £18.7 million claimed. On this basis, the Post Office said that it is implausible for Horizon bugs to be the cause of the losses, and instead they are the fault of the affected sub-postmasters.

This argument is fundamentally flawed; I said so at the time, as did others. The claimant group was selected specifically as people who thought they were victims of Horizon bugs so it’s quite reasonable to think this group might indeed be disproportionally affected by Horizon bugs. The judge agreed, saying, “The group has a bias, in statistical terms. They plainly cannot be treated, in statistical terms, as though they are a random group of 587 [sub-postmasters]”. This error can be corrected, but the argument becomes circular and a statistical approach adds little new information. As the judgement concludes, “probability theory only takes one so far in this case, and that is not very far”.

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UK Parliament on protecting consumers from economic crime

On Friday, the UK House of Commons Treasury Committee published their report on the consumer perspective of economic crime. I’ve frequently addressed this topic in my research, as well as here on Bentham’s Gaze, so I’m pleased to see several recommendations of the committee match what myself and colleagues have proposed. In other respects, the report could have gone further, so as well as discussing the positive aspects of the report, I would also like to suggest what more could be done to reduce economic crime and protect its victims.

Irrevocable payments are the wrong default

Transfers between UK bank accounts will generally use the Faster Payment System (FPS), where money will immediately show up in the recipient account. FPS transfers cannot be revoked, even in the case of fraud. This characteristic protects banks because if fraudulently obtained funds leave the banking system, the bank receiving the transfer has no obligation to reimburse the victim.

In contrast, the clearing system for paper cheques permits payments to be revoked for a few days after the funds appeared in the recipient account, should there have been a fraud. This period allows customers to quickly make use of funds they receive, while still giving a window of opportunity for banks and customers to identify and prevent fraud. There’s no reason why this same revocation window could not be applied to fully electronic payment systems like FPS.

In my submissions to consultations on how to prevent push payment scams, I argued that irrevocable payments are the wrong default, and transfers should be possible to reverse in cases of fraud. The same argument applies to consumer-oriented cryptocurrencies like Libra. I’m pleased to see that the Treasury Committee agrees and they have recommended that when a customer sends money to an account for the first time, that transfer be revocable for 24 hours.

Introducing Confirmation of Payee, finally

The banking industry has been planning on launching the Confirmation of Payee system to check if the name of the recipient of a transfer matches what the customer sending money thinks. The committee is clearly frustrated with delays on deploying this system, first promised for September 2018 but since slipped to March 2020. Confirmation of Payee will be a helpful tool for customers to help avoid certain frauds. Still, I’m pleased the committee also recognise it’s limitations and that the “onus will always be on financial firms to develop further methods and technologies to keep up with fraudsters.” It is for this reason that I argued that a bank showing a customer a Confirmation of Payee mismatch should not be a sufficient condition to hold customers liable for fraud, and the push-payment scam reimbursement scheme is wrong to do so. It doesn’t look like the committee is asking for the situation to be changed though.

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Forcing phone companies to secure SMS authentication would cause more harm than good

Food-writer and campaigner, Jack Monroe, has become the latest high-profile victim of a SIM-swap scam, losing over £5,000 from both her PayPal and bank accounts to a criminal who intercepted SMS authentication codes. The Payment Services Directive requires that fraud victims get their money back, but banks act slowly and sometimes push the blame onto the victims. When (as I hope it will) the money does eventually get reimbursed, she’s still unlikely to get compensation for any consequential losses, nor for the upset caused. It’s no surprise that this experience has been stressful for Jack, as it would be for most people in her situation.

I am, of course, very sympathetic to victims of SIM-swap fraud and recognise the substantial financial costs, as well as the sense of violation that results. Naturally, fingers are being pointed at the phone companies and followed up with calls for them to do better identity checks before transferring a phone number to a new SIM card. I think this isn’t entirely fair. The real problem is that banks and other payment service providers have outsourced authentication to phone companies, without ensuring that the level of security is appropriate for the sums of money at risk. Banks could have chosen to distribute authentication devices and find a secure way to re-issue ones that are lost. Instead, they have pushed this task to unwitting phone companies, and leave their customers to pick up the pieces when things go wrong, so don’t have an incentive to do better.

More secure SMS authentication

But what if phone companies did do a better job at handing out replacement SIM cards? Maybe the government could push them into doing so, or the phone companies might just get fed up with the bad press. Phone companies could, in principle, set up a process for re-issuing SIM cards which would meet the highest standards of the banking industry. Let’s put aside the issue that SMS was never designed to be secure, and that these processes would put up the cost of phone bills – would it fix the problem? I would argue that it does not. Processes good enough for banking authentication could lock people out of receiving phone calls, and disproportionately harm the most vulnerable members of society.

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Measuring mobility without violating privacy – a case study of the London Underground

In the run-up to this year’s Privacy Enhancing Technologies Symposium (PETS 2019), I noticed some decidedly non-privacy-enhancing behaviour. Transport for London (TfL) announced they will be tracking the wifi MAC addresses of devices being carried on London Underground stations. Before storing a MAC address it will be hashed with a key, but since this key will remain unchanged for an extended period (2 years), it will be possible to track the movements of an individual over this period through this pseudonymous ID. These traces are likely enough to link records back to the individual with some knowledge of that person’s distinctive travel plans. Also, for as long as the key is retained it would be trivial for TfL (or someone who stole the key) to convert the someone’s MAC address into its pseudonymised form and indisputably learn that that person’s movements.

TfL argues that under the General Data Protection Regulations (GDPR), they don’t need the consent of individuals they monitor because they are acting in the public interest. Indeed, others have pointed out the value to society of knowing how people typically move through underground stations. But the GDPR also requires that organisations minimise the amount of personal data they collect. Could the same goal be achieved if TfL irreversibly anonymised wifi MAC addresses rather than just pseudonymising them? For example, they could truncate the hashed MAC address so that many devices all have the same truncated anonymous ID. How would this affect the calculation of statistics of movement patterns within underground stations? I posed these questions in a presentation at the PETS 2019 rump session, and in this article, I’ll explain why a set of algorithms designed to violate people’s privacy can be applied to collect wifi mobility information while protecting passenger privacy.

It’s important to emphasise that TfL’s goal is not to track past Underground customers but to predict the behaviour of future passengers. Inferring past behaviours from the traces of wifi records may be one means to this end, but it is not the end in itself, and TfL creates legal risk for itself by holding this data. The inferences from this approach aren’t even going to be correct: wifi users are unlikely to be typical passengers and behaviour will change over time. TfL’s hope is the inferred profiles will be useful enough to inform business decisions. Privacy-preserving measurement techniques should be judged by the business value of the passenger models they create, not against how accurate they are at following individual passengers around underground stations in the past. As the saying goes, “all models are wrong, but some are useful”.

Simulating privacy-preserving mobility measurement

To explore this space, I built a simple simulation of Euston Station inspired by one of the TfL case studies. In my simulation, there are two platforms (A and B) and six types of passengers. Some travel from platform A to B; some from B to A; others enter and leave the station at one platform (A or B). Of the passengers that travel between platforms, they can take either the fast route (taking 2 minutes on average) or the slow route (taking 4 minutes on average). Passengers enter the station at a Poisson arrival rate averaging one per second. The probabilities that each new passenger is of a particular type are shown in the figure below. The goal of the simulation is to infer the number of passengers of each type from observations of wifi measurements taken at platforms A and B.

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Beyond Regulators’ Concerns, Facebook’s Libra Cryptocurrency Faces another Big Challenge: The Risk of Fraud

Facebook has attracted attention through the announcement of their blockchain-based payment network, Libra. This won’t be the first payment system Facebook has launched, but what makes Facebook’s Libra distinctive is that rather than transferring Euros or dollars, the network is designed for a new cryptocurrency, also called Libra. This currency is backed by a reserve of nationally-issued currencies, and so Facebook hopes it will avoid the high volatility of cryptocurrencies like Bitcoin. As a result, Libra won’t be attractive to currency speculators, but Facebook hopes that it will, therefore, be useful for its stated goal – to be a “simple global currency and financial infrastructure that empowers billions of people.”

Reducing currency volatility is only one step towards meeting this goal of scaling cryptocurrencies to billions of users. The Libra blockchain design addresses how the network can maintain the high throughput and low transaction fees needed to compete with existing payment networks like Visa or MasterCard. However, a question that is equally important but as yet unanswered is how Facebook will develop a secure authentication and fraud prevention system that can scale to billions of users while maintaining good usability and low cost.

Facebook designed the Libra network, but in contrast to traditional payment networks, the Libra network is open. Anyone can send transactions through the network, and anyone can write programs (known as “smart contracts”) that control how, and under what conditions, funds can move between Libra accounts. To comply with anti-money-laundering regulations, Know Your Customer (KYC) checks will be performed, but only when Libra enters or leaves the network through exchanges. Transactions moving funds within the network should be accepted if they meet the criteria set out in the applicable smart contract, regardless of who sent them.

The Libra network isn’t even restricted to transactions transferring the Libra currency. Facebook has explicitly designed the Libra blockchain to make it easy for anyone to implement their own currency and benefit from the same technical facilities that Facebook designed for its currency. Other blockchains have tried this. For example, Ethereum has spawned hundreds of special-purpose currencies. But programming a smart contract to implement a new currency is difficult, and errors can be costly. The programming language for smart contracts within the Libra network is designed to help developers avoid some of the most common mistakes.

Facebook’s Libra and Securing the Calibra Wallet

There’s more to setting up an effective currency than just the technology: regulatory compliance, a network of exchanges, and monetary policy are essential. Facebook, through setting up the Libra Association, is focusing its efforts here solely on the Libra currency. The widespread expectation is, therefore, at least initially, the Libra cryptocurrency will be the dominant usage of the network, and most users will send and receive funds through the Calibra wallet smartphone app, developed by a Facebook subsidiary. From the perspective of the vast majority of the world, the Calibra wallet will be synonymous with Facebook’s Libra, and so damage to trust in Calibra will damage the reputation of Libra as a whole.

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Confirmation of Payee is coming, but will it protect bank customers from fraud?

The Payment System Regulator (PSR) has just announced that the UK’s six largest banks must check whether the name of the recipient of a transfer matches what the sender thinks. This new feature should help address a security loophole in online payments: the name of the recipient of transfers is ignored, contrary to expectations and unlike cheques. This improved security should make some fraud more difficult, but banks must be prevented from exploiting the change to unfairly shift the liability of the remaining crime to the victims.

The PSR’s target is for checks to be fully implemented by March 2020, somewhat later than their initial promise to Parliament of September 2018 and subsequent target of July 2019. The new proposal, known as Confirmation of Payee, also only covers the six largest banking groups, but this should cover 90% of transfers. Its goal is to defend against criminals who trick victims into transferring funds under the false pretence that the money is going to the victim’s new account, whereas it is really going to the criminal. The losses from such fraud, known as push payment scams, are often life-changing, resulting in misery for the victims.

Checks on the recipient name will make this particular scam harder, so while unlikely to prevent all types of push payment scams they will hopefully force criminals to adopt strategies that are easier to prevent. The risk that consumer representatives and regulators will need to watch out for is that these new security measures could result in victims being unfairly held liable. This scenario is, unfortunately, likely because the voluntary consumer protection code for push payment scams excuses the bank from liability if they show the customer a Confirmation of Payee warning.

Warning fatigue and misaligned incentives

In my response to the consultation over this consumer protection code, I raised the issue of “warning fatigue” – that customers will be shown many irrelevant warnings while they do online banking and this reduces the likelihood that customers will notice important ones. Even Confirmation of Payee warnings will frequently be wrong, such as if the recipient’s bank account is under a different name to what the sender expects. If the two names are very dissimilar, the sender won’t be given more details but if the name entered is close to the name in bank records the sender should be told what the correct one is and asked to compare.

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Will dispute resolution be Libra’s Achilles’ heel?

Facebook’s new cryptocurrency, Libra, has the ambitious goal of being the “financial infrastructure that empowers billions of people”. This aspiration will only be achievable if the user-experience (UX) of Libra and associated technologies is competitive with existing payment channels. Now, Facebook has an excellent track record of building high-quality websites and mobile applications, but good UX goes further than just having an aesthetically pleasing and fast user interface. We can already see aspects of Libra’s design that will have consequences on the experience of its users making payments.

For example, the basket of assets that underly the Libra currency should ensure that its value should not be too volatile in terms of the currencies represented within the reserve, so easing international payments. However, Libra’s value will fluctuate against every other currency, creating a challenge for domestic payments. People won’t be paid their salary in Libra any time soon, nor will rents be denominated in Libra. If the public is expected to hold significant value in Libra, fluctuations in the currency markets could make the difference between someone being able to pay their rent or not – a certainly unwelcome user experience.

Whether the public will consider the advantages of Libra are worth the exposure to the foibles of market fluctuations is an open question, but in this post, I’m mostly going to discuss the consequences another design decision baked into the design of Libra: that transactions are irrevocable. Once a transaction is accepted by the validator network, the user may proceed “knowing that the transaction can never be changed or reversed“. This is a common design decision within cryptocurrencies because it ensures that companies, governments and regulators should be unable to revoke payments they dislike. When coupled with anonymity or decentralisation, to prevent blacklisted transactions being blocked beforehand, irrevocability creates a censorship-resistant payment system.

Mitigating the cost of irrevocable transactions

Libra isn’t decentralised, nor is it anonymous, so it is unlikely to be particularly resistant to censorship over matters when there is an international consensus. Irrevocability does, however, make fraud easier because once stolen funds are gone, they cannot be reinstated, even if the fraud is identified. Other cryptocurrencies share Libra’s irrevocability (at least in theory), but they are designed for technically sophisticated users, and their risk of theft can be balanced against the potentially substantial gains (and losses) that can be made from volatile cryptocurrencies. While irrevocability is common within cryptocurrencies, it is not within the broader payments industry. Exposing billions of people to the risk of their Libra holdings being stolen, without the potential for recourse, isn’t good UX. I’ve argued that irrevocable transactions protect the interests of financial institutions over those of the public, and are the wrong default for payments. Eventually, public pressure and regulatory intervention forced UK banks to revoke fraudulent transactions, and they take on the risk that they are unable to do so, rather than pass it onto the victims. The same argument applies to Libra, and if fraud becomes common, they will see the same pressures as UK banks.

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Digital Exclusion and Fraud – the Dark Side of Payments Authentication

Today, the Which? consumer rights organisation released the results from its study of how people are excluded from financial services as a result of banks changing their rules to mandate that customers use new technology. The research particularly focuses on banks now requiring that customers register a mobile phone number and be able to receive security codes in SMS messages while doing online banking or shopping. Not only does this change result in digital exclusion – customers without mobile phones or good network coverage will struggle to make payments – but as I discuss in this post, it’s also bad for security.

SMS-based security codes are being introduced to help banks meet their September 2019 deadline to comply with the Strong Customer Authentication requirements of the EU Payment Services Directive 2. These rules state that before making a payment from a customer’s account, the bank must independently verify that the customer really intended to make this payment. UK banks almost universally have decided to meet their obligation by sending a security code in an SMS message to the customer’s mobile phone and asking the customer to type this code into their web browser.

The problem that Which? identified is that some customers don’t have mobile phones, some that do have mobile phones don’t trust their bank with the number, and even those who are willing to share their mobile phone number with the bank might not have network coverage when they need to make a payment. A survey of Which? members found that nearly 1 in 5 said they would struggle to receive the security code they need to perform online banking transactions or online card payments. Remote locations have poorer network coverage than average and it is these areas that are likely to be disproportionately affected by the ongoing bank branch closure programmes.

Outsourcing security

The aspect of this scenario that I’m particularly interested in is why banks chose SMS messages as a security technology in the first place, rather than say sending out dedicated authentication devices to their customers or making a smartphone app. SMS has the advantage that customers don’t need to install an app or have the inconvenience of having to carry around an extra authentication device. The bank also saves the cost of setting up new infrastructure, other than hooking up their payment systems to the phone network. However, SMS has disadvantages – not only does it exclude customers in areas of poor network coverage, but it also effectively outsources security from the bank to the phone networks.

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Protecting human rights by avoiding regulatory capture within surveillance oversight

Regulation is in the news again as a result of the Home Office blocking surveillance expert Eric Kind from taking up his role as Head of Investigation at the Investigatory Powers Commissioner’s Office (IPCO) – the newly created agency responsible for regulating organisations managing surveillance, including the Home Office. Ordinarily, it would be unheard of for a regulated organisation to be able to veto the appointment of staff to their regulator, particularly one established through statute as being independent. However, the Home Office was able to do so here by refusing to issue the security clearance required for Kind to do his job. The Investigatory Powers Commissioner, therefore, can’t override this decision, the Home Office doesn’t have to explain their reasoning, nor is there an appeal process.

Behaviour like this can lead to regulatory capture – where the influence of the regulated organisation changes the effect of regulation to direct away from the public interest and toward the interests of the organisations being regulated. The mechanism of blocking security clearances is specific to activities relating to the military and intelligence, but the phenomenon of regulatory capture is more widespread. Consequently, regulatory capture has been well studied, and there’s a body of work describing tried and tested ways to resist it. If the organisations responsible for surveillance regulation were to apply these recommendations, it would improve both the privacy of the public and the trust in agencies carrying out surveillance. When we combine these techniques with advanced cryptography, we can do better still.

Regulatory capture is also a problem in finance – likely contributing to high-profile scandals like Libor manipulation, and payment-protection-insurance misselling. In previous articles, we’ve discussed how regulators’ sluggish response to new fraud techniques has led to their victims unfairly footing the bill. Such behaviour by regulators is rarely the result of clear corruption – regulatory capture is often more subtle. For example, the skills needed by the regulator may only be available by hiring staff from the regulated organisations, bringing their culture and mindset along with them. Regulators’ staff often find career opportunities within the regulator limited and so are reluctant to take a hard-line against the regulated organisation and so close off the option of getting a job there later – likely at a much higher salary. Regulatory capture resulting from sharing of staff and their corresponding culture is, I think, a key reason for surveillance oversight bodies having insufficient regard for the public interest.

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Exploring the multiple dimensions of Internet liveness through holographic visualisation

Earlier this year, Shehar Bano summarised our work on scanning the Internet and categorising IP addresses based on how “alive” they appear to be when probed through different protocols. Today it was announced that the resulting paper won the Applied Networking Research Prize, awarded by the Internet Research Task Force “to recognize the best new ideas in networking and bring them to the IETF and IRTF”. This occasion seems like a good opportunity to recall what more can be learned from the dataset we collected, but which couldn’t be included in the paper itself. Specifically, I will look at the multi-dimensional aspects to “liveness” and how this can be represented through holographic visualisation.

One of the most interesting uses of these experimental results was the study of correlations between responses to different combinations of network protocols. This application was only possible because the paper was the first to simultaneously scan multiple protocols and so give us confidence that the characteristics measured are properties of the hosts and the networks they are on, and not artefacts resulting from network disruption or changes in IP address allocation over time. These correlations are important because the combination of protocols responded to gives us richer information about the host itself when compared to the result of a scan of any one protocol. The results also let us infer what would likely be the result of a scan of one protocol, given the result of a scan of different ones.

In these experiments, 8 protocols were studied: ICMP, HTTP, SSH, HTTPS, CWMP, Telnet, DNS and NTP. The results can be represented as 28=256 values placed in a 8-dimensional space with each dimension indicating whether a host did or did not respond to a probe of that protocol. Each value is the number of IP addresses that respond to that particular combination of network protocols. Abstractly, this makes perfect sense but representing an 8-d space on a 2-d screen creates problems. The paper dealt with this issue through dimensional reduction, by projecting the 8-d space on to a 2-d chart to show the likelihood of a positive response to a probe, given a positive response to probe on another single protocol. This chart is useful and easy to read but hides useful information present in the dataset.

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