Digital Financial Services Security Audit Guideline

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SECURITY, INFRASTRUCTURE AND TRUST WORKING GROUPDigital Financial Servicessecurity audit guidelineREPORT OF SECURITY WORKSTREAMa Technical report on SS7 vulnerabilities and mitigation measures for digital financial services transactions

b Technical report on SS7 vulnerabilities and mitigation measures for digital financial services transactions

Security, Infrastructure and Trust Working GroupDigital Financial Servicessecurity audit guideline03/2021

DISCLAIMERThe Financial Inclusion Global Initiative (FIGI) is a three-year program implemented inpartnership by the World Bank Group (WBG), the Committee on Payments and MarketInfrastructures (CPMI), and the International Telecommunication Union (ITU) funded bythe Bill & Melinda Gates Foundation (BMGF) to support and accelerate the implementation of country-led reform actions to meet national financial inclusion targets, andultimately the global 'Universal Financial Access 2020' goal. FIGI funds national implementations in three countries – China, Egypt and Mexico; supports working groups totackle three sets of outstanding challenges for reaching universal financial access: (1) theElectronic Payment Acceptance Working Group (led by the WBG), (2) The Digital ID forFinancial Services Working Group (led by the WBG), and (3) The Security, Infrastructureand Trust Working Group (led by the ITU); and hosts three annual symposia to gathernational authorities, the private sector, and the engaged public on relevant topics and toshare emerging insights from the working groups and country programs.This report is a product of the FIGI Security, Infrastructure and Trust Working Group, ledby the International Telecommunication Union.The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of the Financial Inclusion Global Initiative partners including theCommittee on Payments and Market Infrastructures, the Bill & Melinda Gates Foundation,the International Telecommunication Union, or the World Bank (including its Board ofExecutive Directors or the governments they represent). The mention of specific companies or of certain manufacturers' products does not imply that they are endorsed orrecommended by ITU in preference to others of a similar nature that are not mentioned.Errors and omissions excepted; the names of proprietary products are distinguished byinitial capital letters. The FIGI partners do not guarantee the accuracy of the data included in this work. The boundaries, colours, denominations, and other information shownon any map in this work do not imply any judgment on the part of the FIGI partnersconcerning the legal status of any country, territory, city or area or of its authorities orthe endorsement or acceptance of such boundaries. ITU 2021Some rights reserved. This work is licensed to the public through a Creative CommonsAttribution-Non-Commercial-Share Alike 3.0 IGO license (CC BY-NC-SA 3.0 IGO).Under the terms of this licence, you may copy, redistribute and adapt the work fornon-commercial purposes, provided the work is appropriately cited. In any use of thiswork, there should be no suggestion that ITU or other FIGI partners endorse any specificorganization, products or services. The unauthorized use of the ITU and other FIGI partners' names or logos is not permitted. If you adapt the work, then you must license yourwork under the same or equivalent Creative Commons licence. If you create a translationof this work, you should add the following disclaimer along with the suggested citation:"This translation was not created by the International Telecommunication Union (ITU).ITU is not responsible for the content or accuracy of this translation. The original Englishedition shall be the binding and authentic edition". For more information, please visithttps:// creativecommons .org/ licenses/ by -nc -sa/ 3 .0/ igo/

About this reportThis report was written by Kevin Butler, University of Florida. The author would like tothank Vijay Mauree and Arnold Kibuuka, ITU and Rehan Masood, State Bank of Pakistanfor their guidance and assistance in the report's review and edits. The author would alsolike to thank the FIGI Security Infrastructure and Trust working group members for theircontributions and comments.If you would like to provide any additional information, please contact Vijay Mauree attsbfigisit@ itu .int.Digital Financial Services security audit guideline3

b Technical report on SS7 vulnerabilities and mitigation measures for digital financial services transactions

ContentsAbout this report 3Acronyms 61Introduction 72DFS security audit guideline 73DFS security assurance framework controls and audit guideline 94Security audit checklist 204.1Access Control 204.2 Authentication 204.3 Availability 214.4 Fraud Detection 214.5 Network Security 214.6 Privacy & Confidentiality 225Bibliography 24Digital Financial Services security audit guideline5

AcronymsAPIApplication Programming InterfaceDFSDigital Financial ServicesDMZDemilitarized ZoneIMEIInternational Mobile Equipment IdentityIMSIInternational Mobile Subscriber IdentityMDMessage DigestMFAMulti-Factor AuthenticationMNOMobile Network OperatorMSISDNMobile Station International Subscriber Directory NumberNTPNetwork Time ProtocolOTPOne Time PasswordPKIPublic Key InfrastructurePOSPoint of SaleRBACRole Based Access ControlSDSecurity DimensionSHASecure Hash AlgorithmsSESecure Element - A formally certified, tamper-resistant, stand-alone integratedcircuit often referred to as a "chip" as defined by the European Payments Councilor other recognized standards authority.SIMSubscriber Identity ModuleSMSShort Messaging ServiceSTKSIM ToolkitXMLExtensible Markup LanguageUSSDUnstructured Supplementary Service Data6Digital Financial Services security audit guideline

Digital Financial Servicessecurity audit guideline1INTRODUCTIONThe Digital Financial Services (DFS) Security AuditGuidelines complements the DFS Security Assurance Framework [1], to help stakeholders determineand identify security control deficiencies within theDFS infrastructure. The guidelines are based on theDFS Security Assurance Framework which providesa systematic security risk management process foridentifying threats and vulnerabilities. The DFS Security Assurance Framework also proposes securitycontrol measures that should be implemented by the2DFS provider, mobile network operator, and otherthird parties within the ecosystem.In a DFS application, a deficiency in any one of thecontrols increases the likelihood of a breach of privacy, access to DFS data, confidentiality, user authentication and authorisation, DFS service availability, fraud (internal and external) network security.The audit checklist can be used by DFS regulators,providers, and operators in assessing whether thecontrols in the DFS Security Assurance Frameworkare present and functioning as intended.DFS SECURITY AUDIT GUIDELINEThe DFS security audit guidelines are categorisedinto six different groups that a regulator, internal/external application security auditor, mobile networkoperator, or DFS provider can use to assess the implemented DFS security assurance control measures.Each group provides a series of questions that theauditor can use as a checklist for the security audit ofthe DFS infrastructure.DFS Security audit Guidelines are categorised intothe following groups:i)Access controlAudit guidelines in this group assess whether sufficient selective restrictions on appropriate access to DFS associated systems,services, resources, and controls are in placeto guarantee protection against unauthorized use of network resources.Digital Financial Services security audit guideline7

ii) Authenticationcustomer personal data and steal customerfunds from a DFS system.Audit guidelines in this group assess a DFSapplication's capability to verify the authenticity of the users.iii) AvailabilityAudit guidelines in this group assess the DFSinfrastructure and application for reliabilityand ability to grant timely access to authorised DFS users. The application and infrastructure are validated for resistance to denial-of-service attacks.v) Network securityAudit guidelines in this group assess thecontrols in place to protect the underlyingnetwork infrastructure from unauthorizedaccess, misuse, malfunction, modification,destruction, or improper disclosure. Thesecan also be used to test whether informationonly flows between authorized endpointswithout being diverted or intercepted.vi) Privacy and confidentialityiv) Fraud detectionAudit guidelines in this group to assess thecontrols in place within the DFS systems todetect intentional and unlawful interception by internal or external entities to obtainAudit guidelines in this group assess thecontrols in place to protect DFS participants/user's data from unauthorised disclosure, including data protection that might bederived from observing network activity.The DFS security audit guideline is structured in the format below:Impacted DFSEntityGroupRisk and VulnerabilityControlSecurity auditquestionApplicable policy orprocedureThe table above shows the DFS security risks and vulnerabilities, the DFS entities affected by those risks,controls to mitigate the risks, the security audit question an auditor would ask and the respective policy andprocedure. The "Impacted DFS entity" lists the entity affected by the risk and vulnerability within the DFS ecosystem.The "Risk and vulnerability" column outlines the threats that an entity within the DFS ecosystem will facebased on the eight security dimensions (SD).The "control" column lists the DFS controls for each of the DFS entities within the ecosystem.The "Security audit question" column outlines the auditor's question for compliance checking of the specific control.The "Applicable policy or procedure" column suggests the applicable policy or procedure documents thatguide the day-to-day actions and strategies of a particular entity based on ISO/IEC 27001- InformationSecurity Management [2].The structure table above is elaborated in section 3 and includes the detailed audit checklist for all the securitycontrols in DFS security assurance framework. The table outlines the various security checks that need to beundertaken at the DFS provider and mobile network operator level to verify compliance. This table can be usedas a guideline by telco and financial services regulators, security auditors, and DFS providers for internal andexternal security audits.Section 4 describes the process the security auditors may adopt by outlining a series of questions from Table 1grouped by category for easy reference.8Digital Financial Services security audit guideline

3DFS SECURITY ASSURANCE FRAMEWORK CONTROLS AND AUDIT GUIDELINEThe guideline includes a checklist with questions that the auditor can use to evaluate the security controls.ImpactedDFS EntityDFSProviderGroupAccessControlRisk and vulnerabilityControl- Inadequate controlson user sessions (SD:access control)C1: Set timeouts and auto logouts usersessions on DFS applications (logicalsessions). Within the application, ensuresupport for password complexity (enforcedby the server), set maximum unsuccessfullogin attempts, password history and reuseperiods, account lock-out periods to areasonably minimal value to minimize thepotential for offline attackSecurity audit questionAre the following logical controls set for DFSuser sessions:i) auto logouts and session time outApplicable policyor procedureAccess controlPolicy - System andapplication accesscontrolii) Maximum failed password login attemptsiii) Password and PIN complexity.iv) Password/PIN reuse periodsDFSProviderAccessControl- Inadequate controlson dormant accounts(SD: authentication)C2: Require user identity validation forIs there a sufficient way of validating userdormant DFS accounts users before re-acti- identity before activating previously dormantvating accounts.accounts for example biometric validation?DFSProviderAccessControl- Failure to performgeographical locationvalidation (SD: Communication security)C3: Limit access to DFS services based onuser locations (for example disable accessto DFS USSD codes while roaming, STKand SMS for merchants and agents) wherepossible restrict access by region for DFSagents, where possible check that agentand number performing a deposit or withdrawals are within the same serving area.Does the DFS system have capability to detect Access controlout-of-pattern transactions based on cusPolicy - System andtomer profile?application accesscontrolFor example: Does the DFS provider checkauthenticity of transactions using location-based validation of transactions, forexample through geo-velocity tracking orother means?DFSProviderAccesscontrol- Inadequate user verification of preferreduser communicationchannels for DFSservices (SD: Communication security)C4: Restrict DFS services by communication channels (during registrationcustomers should optionally choose service access channel, USSD only, STK only,app only, or a combination) attempted DFSaccess through channels other than optedshould be blocked and red-flagged.Has the DFS provider limited concurrent userlogins and provided the option for customersto opt into other login channels?For example, are customers who use USSDable to optionally choose to use a DFS appchannel before the DFS provider activatesaccess through this channel?Access controlPolicy - User accessmanagementAccess controlPolicy - System andapplication accesscontrolDFSProviderAuthentication- Replay sessionbased on tokensintercepted (SD: communication security)C5: The DFS system should not trust anyDoes the DFS provider enforce server-basedclient-side authentication or authorization authentication for all access requests?tokens; validation of access tokens must beperformed at the server-side.Access controlPolicy - System andapplication accesscontrolDFSProviderPrivacy andConfidentiality- Weak encryptionalgorithms for password storage (SD:data confidentiality)C6: Store DFS user passwords using strongsalted cryptographic hashing algorithms.Is there a mechanism in place to ensure thatdata-at-rest is encrypted and stored securely?Data Security andData Leakage Prevention StandardMNOAccessControl- Session timeoutsnot specified for DFSservicesC7: Add session timeouts for USSD, STKapplication, and web access to DFSservices.Has the DFS provider set USSD and STK DFSsessions to automatically disconnect after aset period of user inactivity?Access controlPolicy - System andapplication accesscontrolMNOAccesscontrol- User credentials forDFS application aresent in inherentlyinsecure ways likeSMS or throughagents (SD: dataconfidentiality)C8: Where possible, DFS users should settheir own passwords at registration andthey should be encrypted throughout thetransmission to the DFS system. Wherefirst-time credentials are sent to the users,ensure DFS application credentials aresent to users directly without third parties/agents. Users should then be requiredto set new passwords after the first-timelogin.Is the password transmitted securely? Is theuser required to change password after firsttime login?Access controlPolicy - User accessmanagementAccesscontrol- Failure to performlogin monitoring,leaving systemssusceptible to bruteforce attacks (SD:access control)C12: Enforce a maximum number of loginattempts to DFS accounts for back-endusers, merchants, agents and DFS customers on DFS systems (database, OS,application)Is there a maximum number of failed loginattempts set before account is locked?Access controlPolicy - System andapplication accesscontrolAuthentication- Insecure transfer ofcustomer credentials(SD: access control)C14: DFS providers should transmit theuser authentication credentials securelyover a different channel (out of band).Are DFS user authentication credentials transmitted via a different channel/out-of-band?(e.g. if account setup is done via USSD channel are one-time passwords transmitted viae-mail or voice calls?)Access controlPolicy - System andapplication accesscontrolMNODigital Financial Services security audit guideline9

(continued)ImpactedDFS EntityGroupRisk and vulnerabilityControlSecurity audit questionApplicable policyor procedureMNONetworkSecurity- Exposure of internalnetwork to externaladversaries (SD:access control)C15: Use Network Address Translation tolimit external exposure of DFS IP addressand routing information.Are there technical controls in place to limitexposure of internal DFS systems addresses(like database IP addresses?CommunicationsSecurity Policy- Network securitymanagementDFSProviderNetworkSecurity- Insufficient protection of internalsystems againstexternal adversaries(SD: access control)C16: Avoid direct access by externalsystems to the DFS backend systems bysetting up a DMZ that logically separatesthe DFS system from all other internal andexternal systems.Are there logical boundaries that limit accessto the DFS systems from all other systems?(For example, are other unauthorized internal users logically and/physically limited onthe network from accessing DFS processingsystems)CommunicationsSecurity Policy- Network securitymanagementDFSProviderPrivacy andConfidentiality- Reliance by DFSapplication on security libraries offeredby operating systems(SD: communicationsecurity)C17: Ensure that security libraries offeredby the operating system are correctlydesigned and implemented and that thecipher suites they support are sufficientlystrong.Are the cryptographic libraries used by theoperating system or by the application correctly designed and implemented and arethey up to date? Do the cryptographic libraries support strong cryptographic ciphersuitesand do they prevent or discourage use ofweak ciphersuites? Are hashing algorithmsused that have not been deprecated and areadequate digest lengths supported? (Anything less than SHA512 is considered weaktoday. MD5 and SHA1 have been broken.)Cryptography policy- CryptographiccontrolsFor symmetric encryption ciphers, are strongciphers used and are adequate key lengthssupported? (For example, AES is consideredsecure to use while 3-DES is no longer a preferred cipher because of the SWEET-32 attack,and it is encouraged to move away from itto AES as soon as possible.) - For public-keyencryption, are key lengths chosen to be anappropriate size for the public key algorithmbeing used?Are the criteria used for selecting cryptographic algorithms and key sizes based onpublic and well-examined standards? (Forexample, NIST 800-57 special publication hasguidelines on minimum key sizes for eachalgorithm and how long this key size is goodfor)MNOPrivacy andConfidentiality- Weak encryptionpractices or sendingsensitive informationin clear text over insecure traffic channelslike SMS and USSD(SD: communicationsecurity)C18: Ensure all sensitive consumer datasuch as PINs and passwords are encrypted,when traversing the network and while thedata is at rest.Has all sensitive consumer data beenCryptography policyencrypted by the application or the operating - Cryptographicsystem? Are unencrypted versions of thecontrolsdata accessible in the device, for example,in temporary buffers or in memory? Is allinformation sent over a network connectionencrypted with a strong encryption cipher?(See C17 for more discussion of what comprises a strong encryption cipher.)DFS Provider andThird-partyprovidersFraudDetection- Inadequate dataprotection controls(SD: privacy)C19: Remove customer sensitive data fromtrace logs. Examples of data that shouldbe removed include cash retrieval vouchercodes, bank account numbers, credentials.Instead, use place holders, where possible,to represent this data in logs.Do trace logs and event data records capture/store sensitive user data? (e.g. are customerPINs stored in EDRs)Operations security - Logging andmonitoringDFS Provider andThird-partyprovidersPrivacy andConfidentiality- Exposure of customer sensitiveinformation duringtransactions orthrough APIs (SD:privacy)C20: DFS providers should restrict sharingof DFS user information to the minimumamount required for transactions withthird parties and service providers.Is there limitation on customer sensitive information shared during transaction processingwith third parties? (e.g. Only informationneeded for processing the transaction isshared with the third party)Operations securitypolicy - Operationalprocedures andresponsibilities10Digital Financial Services security audit guideline

(continued)ImpactedDFS EntityDFS Provider andThird-partyprovidersGroupRisk and vulnerabilityFraudDetection- Weak encryptionon the API interfaces(SD: privacy)ControlC21: Monitor the use of APIs and encryptall data shared with third parties. Additionally, put into place data managementprocedures and controls such as signednon-disclosure agreements with paymentservice providers to avoid information/data leakage.Security audit questionAre there sufficient mechanisms to monitortransactions processed through paymentAPIs?Applicable policyor procedureOperations securitypolicy - Logging andmonitoringDoes the DFS provider have nondisclosureagreements pertaining to customer sensitivedata with third parties?Are there strong cryptographic algorithmsused when transferring data with thirdparties?MNOMNOAvailabilityAvailability- Network failuredue to insufficientnetwork capacityor to maintenanceor design (SD:availability)C22: The mobile network operator shouldtake steps to ensure high network availability to allow access to DFS servicesthrough USSD, SMS, and the Internet.Are there systems in place to ensure serviceavailability? Example (service redundancy)- Network failuredue to insufficientnetwork capacityor to maintenanceor design (SD:availability)C23: The MNO should perform technicalcapacity tests simulating different transactions based on customer numbers,expected growth, expected number oftransactions, and expected peak periods toensure continued system performance.Are there systems to measure quality of service and quality of experience?Are there reports and utilities to measuresystem response time and down time?Do the QoS and QoE conform to the standards for DFS?Informationsecurity incidentmanagement- RedundanciesSystem acquisition,development,and maintenance- Security in development and supportprocessesDFSProviderNetworkSecurity- Lack of monitoringof network traffic andindividual networkpackets (SD: availability, communicationsecurity)C24: The DFS provider should protectagainst network attacks by the use of firewalls and traffic filters and protect againstDFS infrastructure threats by challengingsuspicious traffic through network admission techniques and mechanisms such asCAPTCHAs.Are there adequate protections against network attacks like firewalls and traffic filterswith proper configurations?Operations security- Protection frommalwareDFSProviderNetworkSecurity- Enabling unnecessary services (SD:data confidentiality)C25: Inbound internet traffic should belimited and continuously monitored.Is there adequate monitoring of traffic forinternet facing DFS applications?Operations security- Protection frommalwareDFSProviderNetworkSecurity- Enabling unnecessary services (SD:data confidentiality)C26: Set restrictive firewall rules by default,use port whitelisting, use packet filters,and continuously monitor access towhitelisted/permitted ports and IP's.Are the firewall rules adequately configured?e.g., port whitelisting, packet filteringOperations security- Protection frommalwareDFSProviderFrauddetection- Insufficient internal controls oncritical operations(SD: access control)C27: Where possible, limit critical changesusing the four-eye principle (maker-checker/two-person rule) for criticalactions including (but not limited to)an administrator creating, modifying, ordeleting another administrator account,changing, attaching and detaching of DFSaccount from mobile number/user ID, andtransaction reversal.Are there sufficient controls to review andapprove for critical changes on accounts? e.g.,is there maker-checker and approval processbefore changes are made?Access controlPolicy - System andapplication accesscontrolDFSProviderFrauddetection- Lack of validation ofdata inputs (SD: dataintegrity)C28: DFS providers should ensure sufficient Is there more than one person required toseparation of duties for maker-approver;complete a critical DFS tasks?for example, an administrator may nothave access rights to both create andactivate a DFS account.DFSProviderAccessControl- Insufficient privilege C29: Limit, control, and monitor physicalmanagement (SD:access to sensitive physical DFS infrastrucaccess control)ture. Physically isolate and put in placelogical and physical deterrents/barriers toDFS infrastructure from other infrastructure. Employ least privilege techniquessuch that preventative access is allowedfor authorized persons, supplanted bydetection and enforcement (e.g., alarms ifforced). Monitor system activity by loggingall access (e.g., who accessed, what theyaccessed, where they accessed from, andwhen they accessed it).Are there sufficient physical and logical barriers to limit access to DFS infrastructure?Access controlPolicy - System andapplication accesscontrolPhysical and environmental security- Secure areasDigital Financial Services security audit guideline11

(continued)ImpactedDFS EntityGroupRisk and vulnerabilityControlSecurity audit questionApplicable policyor procedureDFSProviderNetworkSecurity- Addition of test data C30: The DFS provider should employIs the DFS provider performing input validainto production data robust input validation routines ontion checks?(SD: data integrity)external-facing services by checkingout-of-range values and unpermitted characters in fields, and by constraining andsanitizing input. Input validation shouldhappen at the earliest possible point andshould be done both on the client, andserver-side, however, the server should notrely solely on client-side validation. Additionally, block, log and review all requeststhat violate the Web Services DescriptionLanguage (WSDL) and schemas.DFSProviderFrauddetection- Addition of test data C31: Use database fingerprinting to detectinto production data tampering and modification of data after it(SD: data integrity)has been storedAre there mechanisms in place to detect data Operations secumodification and tampering on the database? rity - Logging andmonitoring- Addition of test data C32: Ensure all test data is removed frominto production data code before it is migrated to the produc(SD: data integrity)tion environment.Is test data and test user accounts deletedfrom the production environment?DFSProviderSystem acquisition,development,and maintenance- Security in development and supportprocessesSystem acquisition,development, andmaintenance - TestdataDFSProviderFrauddetection- Absence of logging,ability to alter logs,and insufficient information in logs (SD:non-repudiation)C33: DFS systems should use loggingAre DFS logs stored securely in a tamper proof Operations secumechanisms, including capturing the prov- module? e.g., SIEMrity - Logging andenance of user actions or logging of criticalmonitoringactions into tamper-proof storage, secureDFS system logs from tampering, editing,deleting, stopping.DFSProviderNetworkSecurity- Inaccurate andunsynchronisedclocks (SD: dataintegrity)C34: Ensure clock accuracy synchronizaAre the clocks within the DFS ecosystemtion on all systems connected to the DFSsynchronized?system. NTP and SNTP are some of the protocols used to sync accurate time; however,these must be deployed securely.Operations security - Operationalprocedures andresponsibilitiesMNONetworksecurity- Weak over-the-airencryption (SD: communication security)C38: Discontinue the use of A5/0, A5/1,and A5/2 GSM encryption ciphers. Closelymonitor results from the security andcryptographic community regarding thefeasibility and ease of compromising A5/3and A5/4 and begin considering strongerciphers. Have a deployment strategy readyfor these newer ciphers.Has the use of known weak ciphers beendiscontinued? Has the deployment beenprepared for new ciphers?Communicationssecurity: Information transferMNOFrauddetection- Weak Calling LineC39: MNOs should do CLI analysis for calls/Identification filtering SMS to detect calls and SMS that may be(SD: communication spoofed to appear like DFS provider calls.security)Are there mechanisms to detect SMS and callspoofing? E.g., CLI analysis?Communicationssecurity: Information te accountconfiguration andauthoris

Audit guidelines in this group assess the controls in place to protect DFS partici-pants/user's data from unauthorised disclo-sure, including data protection that might be derived from observing network activity. 8 Digital Financial Services security audit guideline The DFS security audit guideline is structured in the format below: Impacted .

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