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Re: ANSI X9.122 Secure Customer Authentication for Internet Payments

From: Anders Rundgren <anders.rundgren.net@gmail.com>
Date: Tue, 5 Jul 2016 18:18:26 +0200
To: Erik Anderson <eanders@pobox.com>, public-payments-wg@w3.org, public-webpayments-ig@w3.org
Message-ID: <828a7436-35a0-99aa-8847-b9d8ba5fe6dc@gmail.com>
Dear Erik,

May I offer some brief comments on this work?

The world is quickly evolving towards an open source ditto.  Apparently that fact haven't fully reached organizations like ISO and X9:
https://x9.org/standards/standards-store/
http://www.iso.org/iso/home/store.htm

 > - To ensure segregation of authentication data and PAN data, the
 > authentication data and the PAN must be transmitted in separate sessions
 > from the consumer’s browser and the merchant to the authenticating vendor.

In addition to imposing a specific architecture for payment applications, there's no need for such measures.

I would be extremely surprised if the recommendation above will be reflected in the Web Payment API.

Anders


On 2016-07-05 14:40, Erik Anderson wrote:
> X9.122 is about to pass votes in X9. My last email about this topic was
> "Mon, Dec 7, 2015".
>
> This standard will be a requirement for authentication  to financial
> payment systems in the US. I am sure this will propagate internationally
> as well.
>
> I have put it on WatchDox system. If you need access to the special X9
> instance of Watchdox please email me.
>
> Below is a few snippets of requirements throughout financial services.
>
> Erik Anderson
> Bloomberg
>
>
>
> - To ensure segregation of authentication data and PAN data, the
> authentication data and the PAN must be transmitted in separate sessions
> from the consumer’s browser and the merchant to the authenticating
> vendor.
>
> - To ensure privacy of the payment instrument, the transmission of the
> PAN must be in a separate browser session than the merchant checkout
> process. The Merchant must not be exposed to the users payment
> instrument details.
>
> - The authentication data shall be secured and processed separately from
> other sensitive consumer data until it is encrypted in an HSM or other
> SCD.
>
> - The merchant shopping and payment must be in separate browser
> sessions. Acceptable methods below using internet redirection.
>
> - Encryption key storage requirements – The keys should be securely
> stored, and more specifically encrypted using tamper-resistant hardware
> encryption, using them only when required.
>
> - Consumer authentication data shall be subject to a limited number of
> invalid verification attempts before rendering it unavailable for a
> temporary period of time.
>
> - Encryption key only for consumer authentication data (i.e. not
> overloaded use for other data)
> - Encryption key rotation / replacement requirements
> - Encryption key storage requirements – The keys should be securely
> stored, and more specifically encrypted using tamper-resistant hardware
> encryption, using them only when required.
> - Protection from intercepting authentication data entry (e.g. keyboard
> logging).
> - Requirement to separate identification data ("what you have") from
> consumer authentication data ("what you know"), across the enterprise
> and across disparate networks participating in a given transaction. This
> includes transmission, storage or display.
> - Ensure no clear-text, unencrypted consumer authentication data should
> be transmitted across any network.
> - Compromise of authentication data for one user SHALL not compromise
> the authentication data for another user.
> - Parties that issue authentication credentials vs. parties that capture
> or pass the credentials should be separated.  For those that capture or
> pass the credentials, authentication data shall never be stored
> post-authentication
> - Consumer authentication data shall be subject to a limited number of
> invalid verification attempts before rendering it unavailable for a
> temporary period of time.
> - Static consumer authentication data should be changed periodically,
> where possible – the strength and frequency with which the
> authentication data is changed should be commensurate with business risk
> and application vulnerability.
> - Dynamic consumer authentication data shall be subject to a
> "time-to-live" (TTL) period and lifecycle management that includes
> provisioning, binding and verification/validation. The TTL period
> protects the authentication data from attacks such as replay. Any
> attempts to verify such authentication data beyond the TTL shall fail.
> - Matching environment requirements – Jeff to provide further input..
> Matching could potentially take place at client or server side.
> - Storage of cryptographic keys must occur in an HSM (Hardware Security
> Module)
> - Secure consumer authentication SHALL provide audit information.
> - Successful completion or failure of an authentication event and/or
> payment transaction must be traceable.
> - Peripheral Hardware Devices/Secure Cryptographic Devices (SCD) are
> required to capture payment and/or authentication data at the point of
> entry for internet payments. The devices small protect the data prior to
> the data entering a less secure environment.  An acceptable form of
> protecting the data is an ANSI/ISO approved encryption algorithm.
> Pprotection refers to maintaining the secrecy of the authentication data
> from unauthorized disclosure.
> - Personal owned SCD provides acceptable "environmental security levels"
> where as a public device must provide UKPT (Unique Key Per Transact) to
> increase the "device security levels".
> - Cleartext secret cryptographic keys utilized by a data protection
> method shall be protected within an SCD.
> - Cryptographic operations utilizing a cryptographic key that must be
> kept secret must execute within an SCD.
> - Peripheral Hardware Devices may be authenticated prior to authorizing
> a payment.
> - Authentication data SHALL be encrypted and SHALL be transmitted
> through a separate channel/session from the identification data so that
> it is not possible to associate the card data with the authentication
> data.
> - Protected data, such as knowledge factors, SHALL not be stored by the
> software used on the consumer’s device. (e.g)
> - Secure consumer authentication SHALL provide audit information:
>    - Successful completion of an authentication event and payment
> transaction SHALL be verifiable
>    - Failure of an authentication event or payment transaction SHALL be
> traceable
>    - Device geolocation information (e.g., mobile tower, IP address, GPS
> coordinates) should be captured for audit-ability when such information
> is accessible.  Note that for some token devices (e.g., credit card,
> access token), geolocation information may not be available
> - Consumer authentication based on PIN capture shall be through a PIN
> Entry Device (PED) peripheral or Secure UI.
>
>
>
> - Secure UI/Graphical Passcode Entry Method
> - The consumer is presented with a graphical display at the time of
> purchase to be used for entry of authentication data. The consumer
> should have antivirus software for malware, etc. Numeric passcode,
> string of digits … not related to credit/debit card.  Any kind of
> financial service transaction that is NOT a debit/credit card
> transaction.
>    - The authentication data captured by the graphical display shall use
> an encryption key that is randomly generated each time it is presented
> to the consumer to capture the data.
>    - The encryption key for the graphical display shall be used only for
> the encryption of the authentication data.
>    - As required by RISK policy of the payment provider: The encryption
> key should be replaced / rotated within the constraints of a maximum
> duration (e.g. 24 hours) or maximum number of transactions (e.g. 1000)
> which ever constraint first becomes applicable. While knowledge of any
> previous transaction does not present itself as an attack vector to the
> current transaction, a maximum duration or number of transactions
> threshold is considered best practice. Additional implementation
> considerations that are more restrictive than those above are allowed
> based on internal risk assessments.
>    - The authentication data entry shall be without use of keyboard to
> mitigate keyboard logging based attacks.
>    - Authentication Data Symbols shall be randomly located to mitigate
> the risk that the symbol position can be predicted.
>    - The identification data (e.g. Account number, PAN) and the
> authentication data symbols shall never appear on the screen at the same
> time. If a screen capture is made, the malware only has access to a part
> of the data needed for an authentication.
>    - The actual authentication data shall not route or pass through a
> merchant provider’s web server or database.
>    - The authentication data entry and card data entry shall be done
> using separate channels – for example, you can’t enter authentication
> data and PAN on same web site/page. Card credential capture provider may
> not be the same as the cardholder credential capture provider.
>    - To ensure segregation of authentication data and PAN data, the
> authentication data and the PAN shall be transmitted in separate
> sessions from the consumer’s browser and the merchant to the
> authenticating vendor.
>    - Once the authenticating vendor receives the authentication data, it
> shall be kept separate from card data and other sensitive data outside
> of a SCD.
>    - The authentication data shall never be stored post-authentication –
> for example, as set forth in the PCI-DSS 3.0 standard
>    - Transmission of authentication data from the browser shall be
> encrypted using an ANSI/ISO approved encryption algorithm with a minimum
> requirement as set forth by NIST 800-57/SP800-131.
>    - Each authentication display session shall follow appropriate key
> management procedures in accordance with ANSI/ISO.
>    - Data transmission from the consumer’s browser to the authenticating
> vendor shall be encrypted using TLS/SSL in accordance to data
> transmission security standards.
>    - To enable mutual authentication, an Anti-Phishing solution shall be
> embedded into the graphical display process and available for consumer
> use.  The Anti-Phishing solution should let the consumer know that the
> graphical display they are interacting with is a genuine display and not
> a fraudulent display.
>
> - IVR passcode entries
>    - In event a PIN capture device, secure UI is not available an
> out-of-bands a voice call prompting for a passcode at the time of
> purchase is acceptable
>
> - Dynamic Password
>    - One-Time Passwords (OTP) - an authentication method that may be
>    used
> for internet payments.  The OTP may be issued and verified either by the
> card issuer or payment provider. OTPs may be unique in some systems, or
> random in others without a guarantee of uniqueness.
>
>
> - The online/web merchant SHOULD never ask the consumer to enter their
> actual payment card information.
>    - Internet Redirect Method
>      - The consumer is redirected at the time of checkout to the
> financial institution’s secure online banking web site where a one-time
> use, pseudo payment card number is generated by the financial
> institution for use in subsequent internet payments. The pseudo payment
> card number should also have a minimum lifespan.
>      - Prior to an online debit transaction, the consumer is required to
> register and agree to online banking through his/her financial
> institution.
>      - The Merchant’s checkout page SHOULD redirect the consumer
> seamlessly into the online banking platform of the consumer’s financial
> institution.
>      - The consumer SHOULD be able to validate the financial institution
> website
>      - The financial institution SHOULD authenticate the consumer and
> then generate a one-time use pseudo payment card number for each online
> purchase.
>
>
Received on Tuesday, 5 July 2016 16:19:03 UTC

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