+3.2 Fraud Management
---+3.2.1 CSP Fraud Management
---+3.2.2 RP Fraud Management
---+3.2.3 Treatment of Fraud Check Failures

3.2 Fraud Management

A critical aspect of the identity proofing process is to mitigate fraudulent attempts to gain access to benefits, services, data, or assets that are protected by identity management systems. Resolution, validation, and verification processes are designed to mitigate many types of attacks. However, with the constantly changing threat environment, layering additional checks and controls can provide increased confidence in proofed identities and additional protections against advanced and emerging types of attacks. The ability to identify, detect, and resolve instances of potential fraud is a critical functionality for CSPs and RPs.

1. Übersicht

Bezeichnung Standard
3.2.1 CSP Fraud Management
CSPs SHALL establish and maintain a fraud management program that provides fraud identification, detection, investigation, reporting, and resolution capabilities. The specific capabilities and details of this program SHALL be documented within their CSP practice statement.
CSPs SHALL conduct a privacy risk assessment of all fraud checks and fraud mitigation technologies prior to implementation.
The CSP SHALL establish a self-reporting mechanism and investigation capability for subjects who believe they have been the victim of fraud or an attempt to compromise their involvement in the identity proofing processes.
CSPs SHALL analyze all remote proofing communication channels to look for high-risk indicators (e.g., blocklisted proxies and IP addresses).
The CSP SHALL take measures to prevent unsuccessful applicants from inferring the accuracy of any self-asserted information with that confirmed by authoritative or credible sources.1
CSPs SHALL monitor the performance of their fraud checks and fraud mitigation technologies to ensure continued effectiveness in mitigating fraud risks.
CSPs SHALL establish a technical or process-based mechanism to communicate suspected and confirmed fraudulent events to RPs.
CSPs SHALL implement a death records check for all identity proofing processes by confirming with a credible, authoritative, or issuing source that the applicant is not deceased. Such checks can aid in preventing synthetic identity fraud, the use of stolen identity information, and exploitation by a close associate or relative.
CSPs SHOULD implement the following fraud checks for their identity proofing processes based on their available identity proofing types, selected technologies, evidence, and user base:
SIM swap detection: Confirm that the phone number used in the identity proofing process has not been recently ported to a new user or device. Such checks can provide an indication that a phone or device was compromised by a targeted attack.
Device or account tenure check: Evaluate the length of time a phone service subscription or other account (e.g., email account) has existed without substantial modifications or changes. Such checks can provide additional confidence in the reliability of a device or piece of evidence used in the identity proofing process.
Mailing address check: Determine whether the mailing address is a known virtual Post Office (PO) Box or has other high-risk characteristics.
Device fingerprinting: Incorporate device fingerprinting checks to protect against scaled and automated attacks and enrollment duplication. Device fingerprinting is the process of collecting and analyzing the hardware and software characteristics of a device in order to create a unique identifier (i.e., fingerprint) for the device.
Transaction analytics: Evaluate anticipated transaction characteristics (e.g., IP addresses, geolocations, transaction velocities) to identify anomalous behaviors or activities that can indicate a higher risk or a potentially fraudulent event. Fraud velocity checks monitor the frequency and pattern of transactions over a specific period of time to identify unusual activity associated with transaction data. Such checks can protect against scaled and automated attacks, as well as indicate whether specific attack patterns are being executed on identity systems.
Fraud indicator check: Evaluate records (e.g., reported, confirmed, or historical fraud events) to determine whether there is an elevated risk related to a specific applicant, applicant’s data, or device. Such checks can indicate identity theft or compromise. Where such information is collected, aggregated, or exchanged across commercial platforms and made available for use by RPs and other CSPs, users SHALL be made aware of any privacy implications based on a privacy risk assessment. This also applies to all websites that report user activity to federal RPs.
CSPs SHOULD periodically employ independent testing (e.g., red teaming exercises) to validate the effectiveness of their fraud mitigation measures.
CSPs SHOULD consider the recency of fraud-related data when factoring such data into fraud prevention capabilities and decisions.
For attended proofing processes, CSPs SHALL train proofing agents to detect indicators of fraud and SHALL provide proofing agents and trusted referees with tools to flag suspected fraudulent events for further treatment and investigation.
Collusion is possible whenever CSP representatives are directly involved in proofing processes or decisions. CSPs SHALL implement insider threat controls to detect and prevent collusion involving CSP representatives that are directly involved with or can intervene in proofing processes or decisions.
CSPs SHOULD communicate fraud events in real time to RPs through methods such as shared signaling, as described in Sec. 4.8 of [SP800-63C].
CSPs MAY employ KBV as part of its fraud management program.
CSPs MAY implement fraud mitigation measures as compensating controls. When this is done, these SHALL be documented as deviations from the normative guidance of these guidelines and SHALL be conveyed to all RPs through a Digital Identity Acceptance Statement (DIAS) prior to integration. See Sec. 3.4.4 of [SP800-63] for more information about the DIAS.

CSPs that employ artificial intelligence (AI) or machine learning (ML) as part of their identity service SHALL adhere to the requirements provided in Sec. 3.8 of [SP800-63], as applicable.

3.2.2 RP Fraud Management
RPs SHALL establish a point of contact with whom CSPs can interact and communicate fraud data.
RPs SHALL conduct a privacy risk assessment (see Sec. 3.3.1) of any CSP fraud checks and mitigation technologies to identify potential privacy risks or unintended harms. Federal agency RPs SHALL implement this consistent with the requirements contained in Sec. 3.7.
RPs SHOULD include any requirements for fraud checks and fraud mitigation technologies in trust agreements with their CSPs.
RPs SHALL conduct periodic reviews of their CSP’s fraud management program, fraud checks, and fraud technologies to adjust thresholds, review investigations into fraud events, and evaluate the effectiveness and efficacy of fraud controls.
RPs SHALL review all fraud mitigation measures that have been deployed as compensating or supplemental controls by CSPs to align with their internal risk tolerance and acceptance. The RP SHALL record the CSP’s compensating controls in their own DIAS prior to integration.
Pursuant to applicable laws and regulations, RPs SHOULD establish a mechanism to communicate the outcomes of fraud reports and investigations, including both positive and negative results, to CSPs and other partners in order to allow them to improve their own fraud identification, mitigation, and reporting capabilities.
RPs SHOULD establish a fraud management program for digital identity management consistent with their mission, regulatory environment, systems, applications, data, and resources.
Informed by risks identified in a privacy risk assessment, the RP MAY also request additional attributes beyond what a CSP provides as its core attributes to combat fraud or to support other business processes.
3.2.3 Treatment of Fraud Check Failures

The effectiveness of fraud checks and mitigation technologies will vary based on numerous contributing factors, including the data sources used, the technologies used, and — perhaps most importantly — the applicant population. Therefore, it is critical to have well-structured and documented processes addressing failures that arise from the fraud management measures. The following requirements apply to handling these failures:

CSPs SHALL establish and document actions and practices related to each of their fraud checks and provide these actions and practices to RPs.
CSPs SHALL establish procedures for redress to allow applicants to resolve issues associated with fraud checks and mitigation technologies. See Sec. 3.6 of [SP800-63] for more information about redress.
The CSP SHOULD offer trusted referee services to applicants who fail fraud checks in unattended remote processes. If trusted referees are offered to applicants who fail fraud checks in unattended remote processes, the trusted referees SHALL be provided with a summary of the results of the fraud failures to inform their risk-based decision-making processes.

1.1 Referenzen

1.2 Identifizierte Anforderungen

1.3 Zugehörige Regulierungen

2. Identifizierte Anforderungen

Anforderungen
Quelle Anforderung

3. Zugehörige Regulierungen

Regulierungen
Quelle Regulierung
  • NIST -

    EN: Publications of the National Institute of Standards and Technology (NIST), U.S. Department of Commerce, https://www.nist.gov/, from their electronic versions (OSCAL; SP 800-63-4 from its HTML version, https://pages.nist.gov/800-63-4/). Works of NIST employees are not subject to copyright protection in the United States (17 U.S.C. § 105); the OSCAL content is dedicated to the public domain worldwide (CC0 1.0); outside the United States NIST grants the right to reprint its technical series publications in all formats (NIST copyright statement). Republished courtesy of the National Institute of Standards and Technology; each document names its citation. Divided into sections and converted into the GRCA format, the wording unchanged. Only the versions published by NIST are authoritative.

    DE: Veröffentlichungen des National Institute of Standards and Technology (NIST), U.S. Department of Commerce, https://www.nist.gov/, aus ihren elektronischen Fassungen (OSCAL; SP 800-63-4 aus ihrer HTML-Fassung, https://pages.nist.gov/800-63-4/). Werke von NIST-Beschäftigten sind in den USA urheberrechtlich nicht geschützt (17 U.S.C. § 105); die OSCAL-Inhalte sind weltweit gemeinfrei gestellt (CC0 1.0); außerhalb der USA räumt das NIST das Recht ein, seine Technical-Series-Publikationen in allen Formaten neu zu veröffentlichen (Copyright-Hinweis des NIST). „Republished courtesy of the National Institute of Standards and Technology“; jedes Dokument nennt seine Zitierangabe. In Abschnitte aufgeteilt und in das GRCA-Format umgewandelt, der Wortlaut unverändert. Maßgeblich sind allein die vom NIST veröffentlichten Fassungen.