Posts Tagged: cyberheist


28
Jan 13

Big Bank Mules Target Small Bank Businesses

A $170,000 cyberheist last month against an Illinois nursing home provider starkly illustrates how large financial institutions are being leveraged to target security weaknesses at small to regional banks and credit unions.

I have written about more than 80 organizations that were victims of cyberheists, and a few recurring themes have emerged from nearly all of these breaches. First, a majority of the victim organizations banked at smaller institutions. Second, virtually all of the money mules — willing or unwitting individuals recruited to help launder the stolen funds — used accounts at the top five largest U.S. banks.

The attack on Niles Nursing Inc. provides a textbook example. On Monday, Dec. 17, 2012, computer crooks logged into the company’s online banking accounts using the controller’s credentials and tunneling their connection through his hacked PC. At the beginning of the heist, the miscreants added 11 money mules to Niles’ payroll, sending them automated clearing house (ACH) payments totaling more than $58,000, asking each mule to withdraw their transfers in cash and wire the money to individuals in Ukraine and Russia.

nilesmulespartNiles’ financial institution — Ft. Lauderdale, Fla. based Optimum Bank — evidently saw nothing suspicious about 11 new employees scattered across five states being added to its customer’s payroll overnight. From the bank’s perspective, the user submitting the payroll batch logged in to the account with the proper credentials and with the same PC that was typically used to administer the account. The thieves would put through another two fraudulent payment batches over next two days (the bank blocked the last batch on the 19th).

In total, the attackers appear to have recruited at least two dozen money mules to help haul the stolen loot. All but two of the mules used or opened accounts at four out of five of the nation’s top U.S. banks, including Bank of America, Chase, Citibank, and Wells Fargo. No doubt these institutions together account for a huge percentage of the retail banking accounts in America today, but interviews with mules recruited by this crime gang indicate that they were instructed to open accounts at these institutions if they did not already have them.

ANALYSIS

I’ve spoken at numerous financial industry conferences over the past three years to talk about these cyberheists, and one question I am almost always asked is, “Is it safer for businesses to bank at larger institutions?” This is a tricky question to answer because banking online remains a legally and financially risky affair for any business, regardless of which bank it uses. Businesses do not enjoy the same fraud protections as consumers; if a Trojan lets the bad guys siphon an organization’s online accounts, that victim organization is legally responsible for the loss. The financial institution may decide to reimburse the victim for some or all of the costs of the fraud, but that is entirely up to the bank.

What’s more, it is likely that fewer cyberheists involving customers of Top 5 banks ever see the light of day, principally because the larger banks are in a better financial position to assume responsibility for some or all of the loss (provided, of course, that the victim in return agrees not to sue the bank or disclose the breach publicly).

I prefer to answer the question as if I were a modern cyberthief in charge of selecting targets. The organized crooks behind these attacks blast out tens of millions of booby-trapped emails daily, and undoubtedly have thousands of stolen online banking credentials to use at any one time. There are more than 7,000 financial institutions in the United States…should I choose a target at one of the top 10 banks? These institutions hold a majority of the financial industry’s assets, and they’re accustomed to moving huge sums of money around each day.

On the other hand, their potential for fraud is almost certainly orders of magnitude greater than at smaller institutions. That would suggest that it may be easier for these larger institutions to justify antifraud expenditures. That incentive to enact antifraud protections is even greater because these institutions have huge numbers of retail customers, a channel in which they legally eat the loss from unauthorized account activity.

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29
Nov 12

Online Service Offers Bank Robbers for Hire

An online service boldly advertised in the cyber underground lets miscreants hire accomplices in several major U.S. cities to help empty bank accounts, steal tax refunds and intercept fraudulent purchases of high-dollar merchandise.

The service, advertised on exclusive, Russian-language forums that cater to cybercrooks, claims to have willing and ready foot soldiers for hire in California, Florida, Illinois and New York. These associates are not mere “money mules,” unwitting and inexperienced Americans tricked and cajoled into laundering money after being hired for bogus work-at-home jobs. Rather, as the title of the ad for this service makes clear, the “foreign agents” available through this network are aware that they will be assisting in illegal activity (the ad refers to them as неразводные “nerazvodni” or “not deceived”). Put simply: These are mules that can be counted on not to freak out or disappear with the cash.

These complicit “foreign agents” in the U.S. can be hired to launder funds stolen through cyberheists and tax fraud.

The rest of the ad reads:

“We provide convenient service to our partners:

  • Unique administrative interface – fast response
  • We will react momentarily to any new task
  • Adapt every action of a money mule to client’s requirements
  • Timely payments via WebMoney/Liberty Reserve/Western Union, cash conversion with WU/MG
  • Cashout of tax return, D + P (dump & PIN, cashout of debit cards stolen via skimming)
  • Receive over mail or expensive merchandise pick up in a store
  • Mules are available for other interesting transactions

We work only by reference.”

The proprietors of this service say it will take 40-45 percent of the value of the theft, depending on the amount stolen. In a follow-up Q&A with potential buyers, the vendors behind this service say it regularly moves $30,000 – $100,000 per day for clients. Specifically, it specializes in cashing out high-dollar bank accounts belonging to hacked businesses, hence the mention high up in the ad of fraudulent wire transfers and automated clearinghouse or ACH payments (ACH is typically how companies execute direct deposit of payroll for their employees).

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19
Nov 12

MoneyGram Fined $100 Million for Wire Fraud

A week ago Friday, the U.S. Justice Department announced that MoneyGram International had agreed to pay a $100 million fine and admit to criminally aiding and abetting wire fraud and failing to maintain an effective anti-money laundering program. Loyal readers of this blog no doubt recognize the crucial role that MoneyGram and its competitors play in the siphoning of millions of dollars annually from hacked small- to mid-sized business, but incredibly this settlement appears to be unrelated to these cyber heists.

According to the DOJ, the scams – which generally targeted the elderly and other vulnerable groups – included posing as victims’ relatives in urgent need of money and falsely promising victims large cash prizes, various high-ticket items for sale over the Internet at deeply discounted prices or employment opportunities as ‘secret shoppers.’  In each case, the perpetrators required the victims to send them funds through MoneyGram’s money transfer system.”

The government found that the heart of the problems at MoneyGram stemmed from the age-old conflict between the security staff and the folks in sales & marketing (oh, and willful neglect of employee fraud).

“Despite thousands of complaints by customers who were victims of fraud, MoneyGram failed to terminate agents that it knew were involved in scams.  As early as 2003, MoneyGram’s fraud department would identify specific MoneyGram agents believed to be involved in fraud schemes and recommended termination of those agents to senior management.  These termination recommendations were rarely accepted because they were not approved by executives in the sales department and, as a result, fraudulent activity grew from 1,575 reported instances of fraud by customers in the United States and Canada in 2004 to 19,614 reported instances in 2008.  Cumulatively, from 2004 through 2009, MoneyGram customers reported instances of fraud totaling at least $100 million…To date, the U.S. Attorney’s Office for the Middle District of Pennsylvania has brought conspiracy, fraud and money laundering charges against 28 former MoneyGram agents.”

$100 million may seem like a painful fine, unless you take a look at MoneyGram’s company facts page, which states some fairly staggering figures: “MoneyGram has 293,000 agent locations in 197 countries and territories,” or, to put it another way, “more than twice the locations of McDonald’s, Starbucks, Subway and Wal-Mart combined.”

The company doesn’t say how much money it moved last year, but an older version of that page said that in 2010, approximately $19 billion was sent around the world using MoneyGram transfer services. The same page notes that MoneyGram is the second-largest money transfer company in the world. Second only to Western Union, no doubt, which has long struggled with many of the same anti-money laundering problems.

Each week, I reach out to or am contacted by organizations that are losing hundreds of thousands of dollars via cyber heists. In nearly every case, the sequence of events is virtually the same: The organization’s controller opens a malware-laced email attachment, and infects his or her PC with a Trojan that lets the attackers control the system from afar. The attackers then log in to the victim’s bank accounts, check the account balances – and assuming there are funds to be plundered — add dozens of money mules to the victim organization’s payroll. The money mules are then instructed to visit their banks and withdraw the fraudulent transfers in cash, and wire the money in smaller chunks via a combination of nearby MoneyGram and Western Union locations.

The latest example: On Nov. 16, 2012, attackers logged into accounts at Performance Autoplex II Ltd., a Honda dealer based in Midland, Texas, and began adding money mules to the company’s payroll. The thieves added at least nine mules, sending each a little more than $9,000. One of the mules used in this attack — a Louisa Lies (no kidding, that’s her real last name) — got two transfers totaling $9,220.58. She was instructed to visit two different Western Union locations, sending a total of $3,844 to two different recipients (one in Russia, the other Ukraine); Lies sent another pair of transfers (again, to two different people in Russia and Ukraine) totaling just over $5,000, via two separate MoneyGram locations. Lies said she paid $155 in fees to Western Union, and $136 in MoneyGram charges.
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6
Nov 12

Cyberheists ‘A Helluva Wake-up Call’ to Small Biz

The $180,000 robbery took the building security and maintenance system installer Primary Systems Inc. by complete surprise. More than two-dozen people helped to steal funds from the company’s coffers in an overnight heist in May 2012, but none of the perpetrators were ever caught on video. Rather, a single virus-laden email that an employee clicked on let the attackers open a digital backdoor, exposing security weaknesses that unfortunately persist between many banks and their corporate customers.

The St. Louis, Missouri-based firm first learned that things weren’t quite right on Wednesday, May 30, 2012, when the company’s payroll manager logged into her account at the local bank and discovered that an oversized payroll batch for approximately $180,000 had been sent through late Tuesday evening.

The money had been pushed out of Primary Systems’ bank accounts in amounts between $5,000 and $9,000 to 26 individuals throughout the United States who had no prior interaction with the firm, and who had been added to the firm’s payroll that very same day. The 26 were “money mules,” willing or unwitting participants who are hired through work-at-home job schemes to help cyber thieves move money abroad. Most of the mules hired in this attack were instructed to send the company’s funds to recipients in Ukraine.

“The payroll manager contacted me at 8:00 a.m. that day to ask if I’d authorized the payroll batch, and I said no, it must have been a bank error,” said Jim Faber, Primary Systems’ chief financial officer. “I called the bank and said they said no, they did not make an error. That was a helluva wake-up call.”

The company’s financial institution, St. Louis-based Enterprise Bank & Trust, declined to comment. But of course, mistakes were made all around. Primary Systems’ employees failed to be wary of virus-laden email attachments, and relied too heavily on its firewalls and antivirus software to block attacks. The bank failed to bat an eyelash before processing a $180,000 transfer marked as “payroll” on a Tuesday, even though the company has always processed its payroll batch on Friday mornings. It also failed to flag as strange the overnight addition to Primary’s payroll of 26 new employees located in nearly as many states, even though almost all of the victim firm’s legitimate employees are based in Missouri.

The only parties to this crime who didn’t make missteps were the thieves. According to Faber, investigators believe the crooks cased the joint virtually before launching the heist, which came in just below the $200,000 threshold that would have prompted the bank to obtain verbal permission from Primary Systems for the transfer.

“If it was over $200k, [the bank] wouldn’t have allowed the transfer to happen without confirming it with us,” Faber said. “But this just flew right under that kickout. Our payroll is a lot less than that. This was six times our normal payroll and was in mid-week.”

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8
Oct 12

‘Project Blitzkrieg’ Promises More Aggressive Cyberheists Against U.S. Banks

Last week, security firm RSA detailed a new cybecriminal project aimed at recruiting 100 botmasters to help launch a series of lucrative online heists targeting 30 U.S. banks. RSA’s advisory focused primarily on helping financial institutions prepare for an onslaught of more sophisticated e-banking attacks, and has already received plenty of media attention. I’m weighing in on the topic because their analysis seemed to merely scratch the surface of a larger enterprise that speaks volumes about why online attacks are becoming bolder and more brash toward Western targets.

RSA wasn’t specific about where it got its intelligence, but the report’s finding appear tied to a series of communications posted to exclusive Underweb forums by a Russian hacker who uses the nickname “vorVzakone,” which translates to “thief in law.” This is an expression in Russia and Eastern Europe that refers to an entire subculture of elite criminal gangs that operate beyond the reach of traditional law enforcement. The term is sometimes also used to refer to a single criminal kingpin.

A screen shot posted by vorVzakone, showing his Project Blitzkrieg malware server listing the number of online victims by bank.

In early September, vorVzakone posted a lengthy message announcing the beginning stages of a campaign he dubbed “Project Blitzkrieg.” This was envisioned as a collaborative effort designed to exploit the U.S. banking industry’s lack of anti-fraud mechanisms relative to European financial institutions, which generally require two-factor authentication for all wire transfers.

The campaign, purportedly to be rolled out between now and the Spring of 2013, proposes organizing hacker cells throughout the cybercriminal community to collaborate in exploiting these authentication weaknesses before U.S. banks erect more stringent controls. “The goal – together, en-masse and simultaneously process large amount of the given material before anti-fraud measures are increased,” vorVzakon wrote. A professionally translated version of his entire post is available here.

RSA said the project is being powered by a version of the Gozi Trojan called “Gozi Prinimalka.” The company believes this Trojan is part of family of malware used by a tight-knit crime gang that has stolen at least $5 million from banks already. From its analysis:

“In a boot camp-style process, accomplice botmasters will be individually selected and trained, thereby becoming entitled to a percentage of the funds they will siphon from victims’ accounts into mule accounts controlled by the gang. To make sure everyone is working hard, each botmaster will select their own ‘investor,’ who will put down the money required to purchase equipment for the operation (servers, laptops) with the incentive of sharing in the illicit profits. The gang and a long list of other accomplices will also reap their share of the spoils, including the money-mule herder and malware developers.

While the campaign is not revolutionary in technical terms, it will supposedly sport several noteworthy features. A novel virtual-machine-synching module announced by the gang, installed on the botmaster’s machine, will purportedly duplicate the victim’s PC settings, including the victim’s time zone, screen resolution, cookies, browser type and version, and software product IDs. Impersonated victims’ accounts will thus be accessed via a SOCKS proxy connection installed on their infected PCs, enabling the cloned virtual system to take on the genuine IP address when accessing the bank’s website.”

vorVzakone also says the operation will flood cyberheist victim phone lines while the victims are being robbed, in a bid to prevent account holders from receiving confirmation calls or text messages from their banks (I’ve covered this diversionary tactic in at least a couple of stories). Interestingly, this hacker started discussion threads on different forums in which he posts a video of this service in action. The video shows racks of centrally-managed notebook computers that are each running an installation of Skype. While there are simpler, cheaper and less resource-intensive ways of tying up a target’s phone line, causing all of these systems to call a single number simultaneously would probably achieve the same result. If you don’t see English subtitles when you play the video below, click the “cc” icon in the player to enable them:

THE FIRST RULE OF PROJECT BLITZKRIEG…

vorVzakone’s post has been met with a flurry of curiosity, enthusiasm and skepticism from members of the underground. The skepticism appears to stem from some related postings in which he brags about and calls attention to his credentials/criminal connections, an activity which tends to raise red flags in a community that generally prefers to keep a low profile.

In the following introductory snippet from a homemade movie he posted to youtube.com, vorVzakone introduces himself as “Sergey,” the stocky bald guy in the sunglasses. He also introduces a hacker who needs little introduction in the Russian underground — a well-known individual who used the nickname “NSD” [an abbreviation for the Russian term несанкционированный доступ, or “unauthorized access”] in the mid-2000s, when he claims to have exited the hacking scene.

“Good day to everybody, evening or night, depends on when you are watching me,” the hacker begins, standing in front of a Toyota Land Cruiser. “My name is Serega, you all know me by my nickname “vor v zakone” on the forum. This is my brother, my offline representative – Oleg ‘NSD’. So, what? I decided to meet you, let’s say ‘remotely.’ Without really meeting, right? Now you will see how I live. Let’s go, I will show you something.”

A still shot from a video posted by hacker “vorVzakone”, foreground.

And he proceeds to show viewers around what he claims is his home. But many in the underground community found it difficult to take seriously someone who would be so cavalier about his personal safety, anonymity and security. “This guy’s language and demeanor is that of street corner drug dealer or a night club bouncer, and not of someone who can comprehend what ‘backconnect socks’ or GeoIP is,” remarked one Russian expert who helped translate some of the documentation included in this blog post.

But soon enough, hackers on the forums in which vorVzakone had posted his videos began checking the story, digging up records from Russian motor vehicle agencies indicating that the license plates on the Toyota and other cars in video were registered to a 27-year-old Oleg Vsevolodovich Tolstykh from Moscow. Further, they pointed out, the videos were posted by a youtube user named 01NSD, who also had previously posted Finnish and Russian television interviews with NSD describing various facets of the hacker underground. Indeed, if you pause this 2007 video 22 seconds in, you can see on NSD’s screen that he’s in the midst of a chat conversation with a hacker named vorVzakone.

In response to taunts and ridicule from some in the underground, vorVzakone posted this message on Oct. 6 to a prominent crime forum explaining why he doesn’t worry about going public with his business. Continue reading →


3
Aug 12

Uptick in Cyber Attacks on Small Businesses

New data suggests that cyber attacks aimed at small businesses have doubled over the past six months, a finding that dovetails with my own reporting on companies that are suffering six-figure losses from sophisticated cyber heists.

According to Symantec, attacks against small businesses rose markedly in the first six months of 2012 compared to the latter half of 2011. In its June intelligence report, the security firm found that 36 percent of all targeted attacks (58 per day) during the last six months were directed at businesses with 250 or fewer employees. That figure was 18 percent at the  end of Dec. 2011.

“There appears to be a direct correlation between the rise in attacks against smaller businesses and a drop in attacks against larger ones,” said Paul Wood, a security intelligence manager at Symantec. “It almost seems attackers are diverting their resources directly from the one group to the other.”

I’m seeing the same uptick, and have been hearing from more small business victims than at any time before — often several times per week.

In the second week of July, for example, I spoke with three different small companies that had just been hit by cyberheists (one of the victims asked not to be named, and the other didn’t want their case publicized). On July 10, crooks who’d broken into the computers of a fuel supplier in southern Georgia attempted to transfer $1.67 million out of the company’s accounts. When that failed, they put through a fraudulent payroll batch totaling $317,000, which the victim’s bank allowed.

The bank, First National Bank of Coffee County, managed to claw back an unusually large amount — approximately $260,000. The fuel company hired an outside forensics firm to investigate, and found that the trouble started on July 9, when the firm’s controller clicked a link embedded in an image in an email designed to look as though it was sent by the U.S. Postal Service and alerting the recipient about a wayward parcel. The link in the image loaded content from a site hosting the BlackHole exploit kit, which downloaded the ZeuS Trojan to the controller’s PC.

Interestingly, the fuel company and its bank said one of the money mules that the attackers recruited to help launder the stolen funds turned out to be an employee of Wells Fargo from Alabama. Many money mules are simply not the brightest bulbs, and it is usually difficult to prove that they weren’t scammed as well (because more often than not, the mules end up losing money).  But one would think people who work for banks should be at least be aware of these schemes, and held to a higher standard. What’s more, if this mule wasn’t complicit then he probably suspected something wasn’t right, because he had the funds sent to an account he controlled at a local credit union in Birmingham — rather than an account at Wells Fargo.

By the way, this is the second time I’ve encountered a money mule working at a major bank. Last year, I tracked down a woman at PNC Bank in Maryland who was hired by a mule recruitment gang and later helped move nearly $4,500 from a victim business in North Carolina to cybercriminals in Ukraine. She claimed she did not understand what she had done until I contacted her.

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31
Jul 12

Email-Based Malware Attacks, July 2012

Last month’s post examining the top email-based malware attacks received so much attention and provocative feedback that I thought it was worth revisiting. I assembled it because victims of cyberheists rarely discover or disclose how they got infected with the Trojan that helped thieves siphon their money, and I wanted to test conventional wisdom about the source of these attacks.

Top malware attacks and their antivirus detection rates, past 30 days. Source: UAB

While the data from the past month again shows why that wisdom remains conventional, I believe the subject is worth periodically revisiting because it serves as a reminder that these attacks can be stealthier than they appear at first glance.

The threat data draws from daily reports compiled by the computer forensics and security management students at the University of Alabama at Birmingham. The UAB reports track the top email-based threats from each day, and include information about the spoofed brand or lure, the method of delivering the malware, and links to Virustotal.com, which show the number of antivirus products that detected the malware as hostile (virustotal.com scans any submitted file or link using about 40 different antivirus and security tools, and then provides a report showing each tool’s opinion).

As the chart I compiled above indicates, attackers are switching the lure or spoofed brand quite often, but popular choices include such household names as American Airlines, Ameritrade, Craigslist, Facebook, FedEx, Hewlett-Packard (HP), Kraft, UPS and Xerox. In most of the emails, the senders spoofed the brand name in the “from:” field, and used embedded images stolen from the brands being spoofed.

The one detail most readers will probably focus on most this report is the atrociously low detection rate for these spammed malware samples. On average, antivirus software detected these threats about 22 percent of the time on the first day they were sent and scanned at virustotal.com. If we take the median score, the detection rate falls to just 17 percent. That’s actually down from last month’s average and median detection rates, 24.47 percent and 19 percent, respectively.

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18
Jul 12

Cyberheist Smokescreen: Email, Phone, SMS Floods

It was early October 2011, and I was on the treadmill checking email from my phone when I noticed several hundred new messages had arrived since I last looked at my Gmail inbox just 20 minutes earlier. I didn’t know it at the time, but my account was being used to beta test a private service now offered openly in the criminal underground that can be hired to create highly disruptive floods of junk email, text messages and phone calls.

Many businesses request some kind of confirmation from their bank whenever high-dollar transfers are initiated. These confirmations may be sent via text message or email, or the business may ask their bank to call them to verify requested transfers. The attack that hit my inbox was part of an offering that crooks can hire to flood each medium of communication, thereby preventing a targeted business from ever receiving or finding alerts from their bank.

Shortly after the email barrage began, I fired off a note to Google‘s public relations folks, asking for advice and assistance. Thankfully, my phone line was not a subject of the attack, and I was able to communicate what I was seeing to Google’s team. They worked to fight the attack for the better part of that day, during which time my inbox received tens of thousands of emails, burying hundreds of legitimate emails in page after page of junk messages (in the screen shot above, the note to Google spokesman Jay Nancarrow is at the top of the junk message pile).

What was most surprising about these messages was that many of them contained fairly spammy subject lines that should have been easily caught by Google’s junk mail filters. Each junk message contained nothing but pages full of garbled letters and numbers; the text of each missive resembled an encrypted message.

Google’s engineers managed to block a majority of the junk messages after about six hours, but the company declined to talk about what caused the attack to succeed. It took many more hours to sift through the junk messages to fish out the ones I wanted.

“This isn’t about a hole in Gmail or an exploit — it’s more a matter of spam dynamics and what may be able to get through more easily under certain circumstances,” Nancarrow said. “As a result, we can’t provide specifics that could aid spammers in trying new campaigns.”

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12
Jul 12

EU to Banks: Assume All PCs Are Infected

An agency of the European Union created to improve network and data security is offering some blunt, timely and refreshing advice for financial institutions as they try to secure the online banking channel: “Assume all PCs are infected.”

Source: zeustracker.abuse.ch

The unusually frank perspective comes from the European Network and Information Security Agency, in response to a recent “High Roller” report (PDF) by McAfee and Guardian Analytics on sophisticated, automated malicious software strains that are increasingly targeting high-balance bank accounts. The report detailed how thieves using custom versions of the ZeuS and SpyEye Trojans have built automated, cloud-based systems capable of defeating multiple layers of security, including hardware tokens, one-time transaction codes, even smartcard readers. These malware variants can be set up to automatically initiate transfers to vetted money mule or prepaid accounts, just as soon as the victim logs in to his account.

“Many online banking systems….work based on the assumption that the customer’s PC is not infected,” ENISA wrote in an advisory issued on Thursday. “Given the current state of PC security, this assumption is dangerous. Banks should instead assume that PCs are infected, and still take steps to protect customers from fraudulent transactions.”

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6
Jul 12

Court Ruling Could Be Boon to Cyberheist Victims

A decision handed down by a federal appeals court this week may make it easier for small businesses owners victimized by cyberheists to successfully recover stolen funds by suing their bank.

The U.S. Federal Court of Appeals for the First Circuit has reversed a decision from Aug. 2011, which held that Ocean Bank (now People’s United) was not at fault for a $588,000 cyberheist in 2009 against one of its customers — Sanford, Me. based Patco Construction Co. The appeals court sent specific aspects of the earlier decision back to the lower court for review, but it encouraged both parties to settle the matter out of court.

The appeals court in Boston called the bank’s security systems “commercially unreasonable,” reversing a lower court ruling that Ocean Bank’s reliance on passwords and secret questions was in line with guidance set out by federal banking regulators. A copy of the decision is here (PDF).

Charisse Castagnoli, a bank fraud expert and independent security consultant, said the decision could open the door lawsuits from small businesses that have been similarly victimized with the help of outdated security procedures at their banks.

“What this opinion offers is a strong basis for victims to challenge the security implementations of their banks regardless of whether they agreed that the implementation was ‘commercially reasonable’ at a single point in time in a ‘shrink wrap’ type contract,” Castagnoli said.

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