Category: Legal issues

Improving the auditability of access to data requests

Data is increasingly collected and shared, with potential benefits for both individuals and society as a whole, but people cannot always be confident that their data will be shared and used appropriately. Decisions made with the help of sensitive data can greatly affect lives, so there is a need for ways to hold data processors accountable. This requires not only ways to audit these data processors, but also ways to verify that the reported results of an audit are accurate, while protecting the privacy of individuals whose data is involved.

We (Alexander Hicks, Vasilios Mavroudis, Mustafa Al-Basam, Sarah Meiklejohn and Steven Murdoch) present a system, VAMS, that allows individuals to check accesses to their sensitive personal data, enables auditors to detect violations of policy, and allows publicly verifiable and privacy-preserving statistics to be published. VAMS has been implemented twice, as a permissioned distributed ledger using Hyperledger Fabric and as a verifiable log-backed map using Trillian. The paper and the code are available.

Use cases and setting

Our work is motivated by two scenarios: controlling the access of law-enforcement personnel to communication records and controlling the access of healthcare professionals to medical data.

The UK Home Office states that 95% of serious and organized criminal cases make use of communications data. Annual reports published by the IOCCO (now under the IPCO name) provide some information about the request and use of communications data. There were over 750 000 requests for data in 2016, a portion of which were audited to provide the usage statistics and errors that can be found in the published report.

Not only is it important that requests are auditable, the requested data can also be used as evidence in legal proceedings. In this case, it is necessary to ensure the integrity of the data or to rely on representatives of data providers and expert witnesses, the latter being more expensive and requiring trust in third parties.

In the healthcare case, individuals usually consent for their GP or any medical professional they interact with to have access to relevant medical records, but may have concerns about the way their information is then used or shared.  The NHS regularly shares data with researchers or companies like DeepMind, sometimes in ways that may reduce the trust levels of individuals, despite the potential benefits to healthcare.

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Incentives in Security Protocols

The 2018 edition of the International Security Protocols Workshop took place last week. The theme this year was “fail-safe and fail-deadly concepts in protocol design”.

One common theme at this year’s workshop is that of threat models and incentives, which is covered by the majority of accepted papers. One of these is our (Sarah Azouvi, Alexander Hicks and Steven Murdoch) submission – Incentives in Security Protocols. The aim of the paper is to discuss how incentives can be considered and incorporated in the security of systems. In line with the given theme, the focus is on fail-safe and fail-deadly cases which we look at for the cases of the EMV protocol, consensus in cryptocurrencies, and non-economic systems such as Tor. This post will summarise the main ideas laid out in the paper.

Fail safe, fail deadly and people

Systems can fail, which requires some thought by system designers to account for these failures. From this setting comes the idea behind fail safe protocols which are such that even if the protocol fails, the failure can be dealt with or the protocol can be aborted to limit damage. The idea of a fail deadly setting is an extension of this where failure is defended against through deterrence, as in the case of nuclear deterrence (sometimes a realistic case).

Human input often plays a role in the use of the system, particularly when decisions are required as in fail safe and fail deadly instances. These decisions are then made according to incentives which can aligned to make the system robust to failure. For a fail deadly alignment, this means that a person in position to prevent system failure will be harmed by the failure. In the fail safe case, the innocent parties should be protected from the consequences of system failure. The two concepts are really two sides of the same coin that assigns liability.

It is often said that people are the weakest link in security, but that is an easy excuse for broken protocols. If security incentives are aligned properly, then humans are the strongest link.

The EMV protocol, adding incentives after the fact

As a first example, we consider the case of the EMV protocol, which is used for the majority of smart card payments worldwide, as well as smartphone and card-based contactless payment. Over the years, many vulnerabilities have been identified and removed. Fraud still exists however, due not to unexpected protocol vulnerabilities but to decisions made by banks (e.g., omitting the ability for cards to produce digital signatures), merchants (e.g., omitting PIN verification) and payment networks not sending transactions details back to banks. These are intentional choices, aiming to saves costs and cut transaction times but make fraud harder to detect.

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An investigation of online censorship in Cyprus

The island of Cyprus, situated in the east of the Mediterranean sea, has always been an important commercial and information exchange hub. Today, this is reflected on the large number of submarine cables that facilitate telecommunications with neighboring countries (Greece, Turkey, Egypt, Israel, Syria, and Lebanon) and with the rest of the world (reaching as far as India, South Korea, and Australia). Nevertheless, the Republic of Cyprus (RoC) is officially regarded as a freedom of expression safe haven, where “Internet is completely free of any specific regulation”. Unfortunately, Cypriot netizens claim that such statements couldn’t be further from the truth.

In recent years, Internet Service Providers (ISPs) in RoC have implemented an Internet filtering infrastructure to comply with the laws and regulations implied by the National Betting Authority (NBA). In an effort to understand the capacity of this infrastructure, a multi-disciplinary group of volunteers from the hack66 Observatory in Nicosia has collected and analyzed connectivity measurements from end-user connections on a variety of websites and services. Their report was presented at the 7th International Conference on e-Democracy.

For their experiments, the hack66 Observatory team put together a testlist comprising of domains from the National Betting Authority blocklist, the CitizenLab lists for Greece and Turkey, and WordPress blogs banned in Turkey as reported at the Lumen Database. The analysis was based on over 45,000 measurements from four residential ISPs operating in the Republic of Cyprus, that were anonymously submitted using a custom OONI probe during the months of March to May 2017. In addition, the team collected data using open DNS resolvers in Cyprus. Early findings suggest that the most common blocking method is DNS hijacking. Furthermore, the measurements indicate that some of the ISPs have deployed middle-boxes – network components capable of performing censorship, traffic manipulation or surveillance.

A closer inspection on the variations of the censorship mechanism implementations among ISPs raised concerns with regard to transparency and privacy: some ISPs do not inform users why a blocked website is not accessible; while others redirect requests to a web server controlled by the NBA, that could in turn log user identifiers such as their IP address. Similarly, the hack66 Observatory team was able to identify a number of unreported Internet censorship cases, entries in the NBA blocklist that either are invalid or that require sophisticated blocking techniques, and collateral damage due to blocking of email delivery to the regulated domains.

Understanding the case of Internet freedom in Cyprus becomes more complicated when the geopolitical situation is taken into consideration. Apart from the Republic of Cyprus, the island of Cyprus is divided into three other segments: the self-declared Turkish Republic of Northern Cyprus; the United Nations-controlled Green Line buffer zone; and the Sovereign Base Areas of Akrotiri and Dhekelia that remain under British control for military purposes. Measurements from the Multimax ISP operating in the area occupied by Turkey indicate network interference practices similar to those of mainland Turkey. This could be interpreted as the existence of two distinct regimes in terms of information policy on the island of Cyprus. No volunteers submitted measurements from the UN buffer zone or the British Sovereign bases. However, it is known via the Snowden revelations that GCHQ is operating a wiretap base in Cyprus codenamed “SOUNDER”, jointly funded by the NSA.

The purpose of the hack66 Observatory is to “to collect and analyze data, and routes of data through EMEA, […] in order to promote evidence based policy making”. The timing is just right, given the recent RoC government announcement of a new bill in the making, to regulate media operations and stop fake news. With their report, the hack66 Observatory aims to provide policy makers with a valuable asset for understanding the limitations and implications of the existing censorship infrastructure, and to start a debate around Internet freedom on the entirety of the island of Cyprus.

Liability for push payment fraud pushed onto the victims

This morning, BBC Rip Off Britain focused on push payment fraud, featuring an interview with me (starts at 34:20). The distinction between push and pull payments should be a matter for payment system geeks, and certainly isn’t at the front of customers’ minds when they make a payment. However, there’s a big difference when there’s fraud – for online pull payments (credit and debit card)  the bank will give the victim the money back in many situations; for online push payments (Faster Payment System and Standing Orders) the full liability falls on the party least able to protect themselves – the customer.

The banking industry doesn’t keep good statistics about push payment fraud, but it appears to be increasing, with Which receiving reports from over 650 victims in the first two weeks of November 2016, with losses totalling over £5.5 million. Today’s programme puts a human face to these statistics, by presenting the case of Jane and Steven Caldwell who were defrauded of over £100,000 from their Nationwide and NatWest accounts.

They were called up at the weekend by someone who said he was working for NatWest. To verify that this was the case, Jane used three methods. Firstly, she checked caller-ID to confirm that the number was indeed the bank’s own customer helpline – it was. Secondly, she confirmed that the caller had access to Jane’s transaction history – he did. Thirdly, she called the bank’s customer helpline, and the caller knew this was happening despite the original call being muted.

Convinced by these checks, Jane transferred funds from her own accounts to another in her own name, having been told by the caller that this was necessary to protect against fraud. Unfortunately, the caller was a scammer. Experts featured on the programme suspect that caller-ID was spoofed (quite easy, due to lack of end-to-end security for phone calls), and that malware on Jane’s laptop allowed the scammer to see transaction history on her screen, as well as to listen to and see her call to the genuine customer helpline through the computer’s microphone and webcam. The bank didn’t check that the name Jane gave (her own) matched that of the recipient account, so the scammer had full access to the transferred funds, which he quickly moved to other accounts. Only Nationwide was able to recover any money – £24,000 – leaving Jane and Steven over £75,000 out of pocket.

Neither bank offered Jane and Steven a refund, because they classed the transaction as “authorised” and so falling into one of the exceptions to the EU Payment Services Directive requirement to refund victims of fraud (the other exception being if the bank believed the customer acted either with gross negligence or fraudulently). The banks argued that their records showed that the customer’s authentication device was used and hence the transaction was “authorised”. In the original draft of the Payment Services Directive this argument would not be sufficient, but as a result of concerted lobbying by Barclays and other UK banks for their records to be considered conclusive, the word “necessarily” was inserted into Article 72, and so removing this important consumer protection.

“Where a payment service user denies having authorised an executed payment transaction, the use of a payment instrument recorded by the payment service provider, including the payment initiation service provider as appropriate, shall in itself not necessarily be sufficient to prove either that the payment transaction was authorised by the payer or that the payer acted fraudulently or failed with intent or gross negligence to fulfil one or more of the obligations under Article 69.”

Clearly the fraudulent transactions do not meet any reasonable definition of “authorised” because Jane did not give her permission for funds to be transferred to the scammer. She carried out the transfer because the way that banks commonly authenticate themselves to customers they call (proving that they know your account details) was unreliable, because the recipient bank didn’t check the account name, because bank fraud-detection mechanisms didn’t catch the suspicious nature of the transactions, and because the bank’s authentication device is too confusing to use safely. When the security of the payment system is fully under control of the banks, why is the customer held liable when a person acting with reasonable care could easily do the same as Jane?

Another question is whether banks do enough to recover funds lost through scams such as this. The programme featured an interview with barrister Gideon Roseman who quickly obtained court orders allowing him to recover most of his funds lost through a similar scam. Interestingly a side-effect of the court orders was that he discovered that his bank, Barclays, waited more than 24 hours after learning about the fraud before they acted to stop the stolen money being transferred out. After being caught out, Barclays refunded Gideon the affected funds, but in cases where the victim isn’t a barrister specialising in exactly these sorts of disputes, do the banks do all they could to recover stolen money?

In order to give banks proper incentives to prevent push payment fraud where possible and to recover stolen funds in the remainder of cases, Which called for the Payment Systems Regulator to make banks liable for push payment fraud, just as they are for pull payments. I agree, and expect that if this were the case banks would implement innovative fraud prevention mechanisms against push payment fraud that we currently only see for credit and debit transactions. I also argued that in implementing the revised Payment Service Directive, the European Banking Authority should require banks provide evidence that a customer was aware of the nature of the transaction and gave informed consent before they can hold the customer liable. Unfortunately, both the Payment Systems Regulator, and the European Banking Authority conceded to the banking industry’s request to maintain the current poor state of consumer protection.

The programme concluded with security advice, as usual. Some was actively misleading, such as the claim by NatWest that banks will never ask customers to transfer money between their accounts for security reasons. My bank called me to transfer money from my current account to savings account, for precisely this reason (I called them back to confirm it really was them). Some advice was vague and not actionable (e.g. “be vigilant” – in response to a case where the victim was extremely cautious and still got caught out). Probably the most helpful recommendation is that if a bank supposedly calls you, wait 5 minutes and call them back using the number on a printed statement or card, preferably from a different phone. Alternatively stick to using cheques – they are slow and banks discourage their use (because they are expensive for them to process), but are much safer for the customer. However, such advice should not be considered an alternative to pushing liability back where it belongs – the banks – which will not only reduce fraud but also protect vulnerable customers.

Preventing phishing won’t stop ransomware spreading

Ransomware is in the news again, with Reckitt Benckiser reporting that disruption caused by the NotPetya ransomware could have cost them up to £100 million. In response to this news, just as every previous ransomware incident, the security industry started giving out advice – almost universally emphasising the importance of not opening phishing emails.

The problem is that this advice won’t work. Putting aside the fact that such advice is often so vague as to be impossible to put into action, the cause of recent ransomware outbreaks is not people opening phishing emails:

  • WannaCry, which notably caused severe disruption to the NHS, spread by automated scanning of computers vulnerable to an NSA-developed exploit. Although the starting point was initially assumed to be a phishing email, this was later debunked – only network scanning was used.
  • The Mole Ransomware attack that hit many organisations, including UCL, was initially thought to be spread by employees clicking on links in phishing emails. Subsequent analysis found this was incorrect and most likely the malware spread through malicious advertisements on legitimate websites.
  • NotPetya was initially thought to have been spread through Russian or Ukrainian phishing emails (explaining why that part of the world was so badly affected). It turned out to have not involved phishing at all, but the outbreak started through a tampered software update to the MEDoc tax accounting software mandated by the Ukranian government. Once inside an organisation, NotPetya then spread using the same exploit as WannaCry or by compromising administrative credentials.

Here are three major incidents, making international news, and the standard advice to “be vigilant” when opening emails or clicking links would have been useless. Is it any surprise that security advice gets ignored?

Not only is common anti-phishing advice unhelpful but it shifts blame to individuals (who are not in a position to prevent or mitigate most attacks) away from the IT industry and staff (who are). It also misleads management into thinking that they can “blame-and-train” their employees rather than investing in well engineered preventative security mechanisms and IT systems that can recover from compromise.

And there are things that can be done which have been shown to be effective, not just against the current outbreaks but many in the past and likely future. WannaCry would have been prevented by applying software updates, but the NotPetya outbreak was caused by a software update. The industry needs to act promptly to ensure that software updates are safe and reliable before customers become even more wary about installing them.

The spread of WannaCry and NotPetya within companies could have been prevented or slowed through better operational practices such as segmenting networks and limiting the use of administrative privilege. We’ve known this approach to be effective, but better tools and practices are needed to avoid enhanced security mechanisms being a drag on an organisation’s productivity.

Mole could have been prevented by ad-blocking browser extensions. The advertising industry is in open war against ad-blocking because it harms their income stream, but while they keep on spreading malware through their networks I have limited sympathy.

Well maintained and protected backups are essential to allow recovery, whether from ransomware, purely destructive attacks, or hardware failure. The security techniques above are effective, but these measures will not prevent every attack so mechanisms are needed to efficiently deal with the aftermath.

Most importantly we need to move away from security being a set of traditions passed from generation to generation with little or no reason to believe they are effective (so called “best practice”) to well engineered systems following rigorous, evidence-based guidance on state of the art cybersecurity principles, standards and practices.

Underground abraCARDabra: Understanding carding forums

Paying for dinner? A taxi ride? A tropical drink? Sure. Swipe or tap your card and it is done. Convenient. Payment cards make it easy for us to make payments at “brick-and-mortar” locations and online marketplaces. However, they are also attractive targets for cybercriminals seeking to steal funds from the accounts linked to payment cards, as seen in this recent high-profile theft of credit cards affecting more than 1,000 hotels, for instance.

Theft of payment card information via phishing, skimming, or hacking, is usually the first step in the chain of payment card fraud. Other steps include sales, validation, and monetisation of the stolen data. These illicit deals are aided by underground online forums where cybercriminals actively trade stolen credit card information. To tackle payment card fraud, it is therefore important to understand the characteristics of these forums and the activity of miscreants using them. In our paper, presented at the 2017 APWG Symposium on Electronic Crime Research (eCrime2017), we analyse and discuss the characteristics of underground carding forums. We focus on the available products and prices, characteristics of sellers, and features of the forums. We won the Best Paper Award at eCrime2017.

Products

The main products available on carding forums are credit card numbers, dumps, and fullz. Credit card numbers comprise the information actually printed on credit cards, that is, cardholder name, card number (16 digits on most cards), expiry date, and the security code on the back of the card (usually 3 digits).

Dumps comprise stolen information from the tracks of magnetic stripe of a credit card. Dumps are usually obtained via skimmers. Skimmers are devices attached to Automated Teller Machines (ATMs) and Point of Sale (POS) terminals by miscreants to steal data from unsuspecting victims. Afterwards, the miscreants create clones of the skimmed credit cards and monetise the clones, for instance, by making illicit purchases with them.

Fullz contain further information about the cardholder. In other words, fullz usually comprise information printed on the card plus additional information such as bank account information, cardholder’s date of birth, Social Security number, etc.

Sellers

Generally, there are several types of participants on carding forums: sellers, buyers, intermediaries, mules, administrators, and others. These roles are not mutually exclusive; sellers may simultaneously be buyers. In this study, we focus on sellers since they come before buyers in the fraud chain.

Our approach

We studied previous work on underground marketplaces and forums, and derived the following hypotheses from the insights gained. We then searched for names of carding forums, found 25 names, and collected data from 5 active forums. We then tested the hypotheses on the data.

Hypothesis 1. Prices of fullz (credit card numbers and additional cardholder information) are higher than prices of credit card numbers.
Hypothesis 2. A small number of traders are responsible for a large
proportion of traffic.
Hypothesis 3. Most traders sell only one product type (that is, they are specialised).
Hypothesis 4. Specialised traders sell their products at lower prices than unspecialised traders.
Hypothesis 5. Carding forums have working reputation systems that are as sophisticated as those of legal marketplaces (for instance, eBay).
Hypothesis 6. The vast majority of actors do not operate on more than
one forum.

Summary of findings

Our analyses confirmed Hypothesis 1, Hypothesis 2, and Hypothesis 6. In other words, prices of fullz are indeed higher than prices of credit card numbers (credit card numbers: mean = $10.08, median = $10.00; fullz: mean = $31.82, median = $30.00). Also, a small number of traders are responsible for a large proportion of traffic. Finally, most sellers focus their efforts on a single forum, as expected.

Hypothesis 4 was partially rejected, while Hypothesis 3 and Hypothesis 5 were completely rejected. In other words, specialised sellers do not always sell their products at lower prices than the unspecialised ones, most sellers advertise more than one type of product, and most of the carding forums under study do not have working reputation systems that are as elaborate as those of legitimate online marketplaces.

In conclusion, dumps and fullz are relatively expensive; they are more than three times as expensive as credit card numbers. This may be due to the effort needed to obtain or monetise the data, the amount of available information, or differing supply and demand. Sellers have varying success. Even though some sellers complete hundreds of transactions, most sellers do not succeed in selling anything. This means that the trading sections of the forums are profitable distribution channels for high-profile actors. Finally, specialisation is not a key characteristic of sellers, not even of high-profile sellers.

Further details can be found in the full paper All Your Cards Are Belong To Us: Understanding Online Carding Forums, by Andreas Haslebacher, Jeremiah Onaolapo, and Gianluca Stringhini.

Online security won’t improve until companies stop passing the buck to the customer

It’s normally in the final seconds of a TV or radio interview that security experts get asked for advice for the general public – something simple, unambiguous, and universally applicable. It’s a fair question, and what the public want. But simple answers are usually wrong, and can do more harm than good.

For example, take the UK government’s Cyber Aware scheme to educate the public in cybersecurity. It recommends individuals choose long and complex passwords made out of three words. The problem with this advice is that the resulting passwords are hard to remember, especially as people have many passwords and use some infrequently. Consequently, they will be tempted to use the same password on multiple websites.

Password re-use is far more of a security problem than insufficiently complex passwords, so advice that doesn’t help people manage multiple passwords does more harm than good. Instead, I would recommend remembering your most important passwords (like banking and email), and store the rest in a password manager. This approach isn’t perfect or suitable for everyone, but for most people, it will improve their security.

Advice unfit for the real world

Cyber Aware also tells people not to write down their passwords, or let anyone else know them – banks require the same thing. But we know that people commonly share their banking credentials with family, for legitimate reasons. People also realise that writing down passwords is a pretty good approach if you’re only worried about internet hackers, rather than people who can get close to you to see the written notes. Security advice that doesn’t stand up to scrutiny or doesn’t fit with people’s lives will be ignored – and will discredit the organisation offering it.

Because everyone’s situation is different, good security advice should include helping people to understand what risks they should be worried about, and to take steps that mitigate these risks. This advice doesn’t have to be complicated. Teen Vogue published a tutorial on how to select and configure a secure messaging tool, which very sensibly explains that if you are more worried about invasions of privacy from people who can get their hands on your phone, you should make different choices than if you are just concerned about, for example, companies spying on you.

The Teen Vogue article was widely praised by security experts, in stark contrast to an article in The Guardian that made the eye-catching claim that encrypted messaging service WhatsApp is insecure, without making clear that this only applies in an obscure and extremely unlikely set of circumstances.

Zeynep Tufekci, a researcher studying the effects of technology on society, reported that the article was exploited to legitimise misleading advice given by the Turkish government that WhatsApp is unsafe, resulting in human rights activists using SMS instead – which is far easier for the government to censor and monitor.

The Turkish government’s “security advice” to move from WhatsApp to less secure SMS was clearly aimed more at assisting its surveillance efforts than helping the activists to whom the advice was directed. Another case where the advice is more for the benefit of the organisation giving it is that of banks, where the terms and conditions small print gives incomprehensible security advice that isn’t true security advice, instead merely a legal technique to allow the banks wiggle room to refuse to refund victims of fraud.

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What the CIA hack and leak teaches us about the bankruptcy of current “Cyber” doctrines

Wikileaks just published a trove of documents resulting from a hack of the CIA Engineering Development Group, the part of the spying agency that is in charge of developing hacking tools. The documents seem genuine and catalog, among other things, a number of exploits against widely deployed commodity devices and systems, including Android, iPhone, OS X and Windows. Also smart TVs. This hack, with appropriate background, teaches us a lesson or two about the direction of public policy related to “cyber” in the US and the UK.

Routine proliferation of weaponry and tactics

The CIA hack is in many ways extraordinary, in that it allowed the attackers to gain access to the source code of the hacking tools of the agency – an extraordinary act of proliferation of attack technologies. In other ways, it is mundane in that it is neither the first, nor probably the last hack or leak of catastrophic proportions to occur to a US/UK government department in charge of offensive cyber operations.

This list of leaks of government attack technologies, illustrates that when it comes to cyber-weaponry the risk of proliferation is not merely theoretical, but very real. In fact it seems to be happening all the time.

I find it particularly amusing – and those in charge of those agencies should probably find it embarrassing – that NSA and GCHQ go around presenting themselves as national technical authorities in assurance; they provide advice to others on how to not get hacked; they keep asserting that they can be trusted to operate extremely dangerous spying infrastructures; and handle in secret extremely dangerous zero-day exploits. Yet, they seem to be routinely hacked and have their secret documents leaked. Instead of chasing whistleblowers and journalists, policy makers should probably take note that there is not a high-enough level of assurance to secure cyber-weaponry, and for sure it is not to be found within those agencies.

In fact the risk of proliferation is at the very heart of cyber attack, and integral to it, even without hacking or leaking from inside government. Many of us quietly laughed at the bureaucratic nightmare discussed in the recent CIA leak, describing the difficulty of classifying the cyber attack techniques while at the same time deploying them on target system. As the press release summarizes:

To attack its targets, the CIA usually requires that its implants communicate with their control programs over the internet. If CIA implants, Command & Control and Listening Post software were classified, then CIA officers could be prosecuted or dismissed for violating rules that prohibit placing classified information onto the Internet. Consequently the CIA has secretly made most of its cyber spying/war code unclassified.

This illustrates very clearly a key dynamic in hacking: once a hacker uses an exploit against an adversary system, there is a very real risk the exploit is captured by monitoring and intrusion detection systems of the target, and then weponized to hack other computers, at a low cost. This is very well established and researched, and such “honey pot” infrastructures have been used in the academic and commercial community for some time to detect and study potentially new attacks. This is not the premise of sophisticated defenders, the explanation of how honeypots work is on Wikipedia! The Flame malware, and Stuxnet before, were in fact found in the wild.

In that respect cyber-war is not like war at all. The weapons you use will be turned against you immediately, and your effective use of weapons relies on your very own infrastructures being utterly vulnerable to them.

What “Cyber” doctrine?

The constant leaks and hacks, leading to proliferation of exploits and hacking tools from the heart of government, as well through operations, should deeply inform policy makers when making choices about “cyber” doctrines. First, it is probably time to ditch the awkward term “Cyber”.

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Strong Customer Authentication in the Payment Services Directive 2

Within the European Union, since 2007, banks are regulated by the Payment Services Directive. This directive sets out which types of institutions can offer payment services, and what rules they must follow. Importantly for customers, these rules include in what circumstances a fraud victim is entitled to a refund. In 2015 the European Parliament adopted a substantial revision to the directive, the Payment Services Directive 2 (PSD2), and it will soon be implemented by EU member states. One of the major changes in PSD2 is the requirement for banks to implement Strong Customer Authentication (SCA) for transactions, more commonly known as two-factor authentication – authentication codes based on two or more elements selected from something only the user knows, something only the user possesses, and something the user is. Moreover, the authentication codes must be linked to the recipient and amount of the transaction, which the customer must be made aware of.

The PSD2 does not detail the requirements of Strong Customer Authentication, nor the permitted exemptions to this rule. Instead, these decisions are to be made by the European Banking Authority (EBA) through Regulatory Technical Standards (RTS). As part of the development of these technical standards the EBA opened an initial discussion, to which we submitted a response based on our research on the security usability of banking authentication. Based on the discussion, the EBA produced a consultation paper incorporating a set of draft technical standards. In our response to this consultation paper, included below, we detailed how research both on security usability and banking authentication more broadly should guide the assessment of Strong Customer Authentication. Specifically we point out that there is an incorrect assumption of an inherent tradeoff between security and usability, that for a system to be secure it must be usable, and that evaluation of Strong Customer Authentication systems should be independent, transparent, and follow principles developed from latest research.

False trade-off between security and usability

In the reasoning presented in the consultation paper there is an assumption that a trade-off must be made between security and usability, e.g. paragraph 6 “Finally, the objective of ensuring a high degree of security and safety would suggest that the [European Banking Authority’s] Technical Standards should be onerous in terms of authentication, whereas the objective of user-friendliness would suggest that the [Regulatory Technical Standards] should rather promote the competing aim of customer convenience, such as one-click payments.”

This security/usability trade-off is not inherent to Strong Customer Authentication (SCA), and in fact the opposite is more commonly true: in order for SCA to be secure it must also be usable “because if the security is usable, users will do the security tasks, rather than ignore or circumvent them”. Also, SCA that is usable will make it more likely that customers will detect fraud because they will not have to expend their limited attention on just performing the actions required to make the SCA work. A small subset (10–15%) of participants in some studies reasoned that the fact that a security mechanism required a lot of effort from them meant it was secure. But that is a misconception that must not be used as an excuse for effortful authentication procedures.

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Steven Murdoch – Privacy and Financial Security

Probably not too many academic researchers can say this: some of Steven Murdoch’s research leads have arrived in unmarked envelopes. Murdoch, who has moved to UCL from the University of Cambridge, works primarily in the areas of privacy and financial security, including a rare specialty you might call “crypto for the masses”. It’s the financial security aspect that produces the plain, brown envelopes and also what may be his most satisfying work, “Trying to help individuals when they’re having trouble with huge organisations”.

Murdoch’s work has a twist: “Usability is a security requirement,” he says. As a result, besides writing research papers and appearing as an expert witness, his past includes a successful start-up. Cronto, which developed a usable authentication device, was acquired by VASCO, a market leader in authentication and is now used by banks such as Commerzbank and Rabobank.

Developing the Cronto product was, he says, an iterative process that relied on real-world testing: “In research into privacy, if you build unusable system two things will go wrong,” he says. “One, people won’t use it, so there’s a smaller crowd to hide in.” This issue affects anonymising technologies such as Mixmaster and Mixminion. “In theory they have better security than Tor but no one is using them.” And two, he says, “People make mistakes.” A non-expert user of PGP, for example, can’t always accurately identify which parts of the message are signed and which aren’t.

The start-up experience taught Murdoch how difficult it is to get an idea from research prototype to product, not least because what works in a small case study may not when deployed at scale. “Selling privacy remains difficult,” he says, noting that Cronto had an easier time than some of its forerunners since the business model called for sales to large institutions. The biggest challenge, he says, was not consumer acceptance but making a convincing case that the predicted threats would materialise and that a small company could deliver an acceptable solution.

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