Our Ref.: B1/15C
B9/29C
31 October 2023
The Chief Executive
All Authorized Institutions
Dear Sir/Madam,
Enhancement to security of electronic banking services
We are writing to require authorized institutions (AIs) to implement a package of
new enhancement measures, formulated by the Hong Kong Monetary Authority
(HKMA) in consultation with the Hong Kong Association of Banks (HKAB) and
the Hong Kong Police Force, to further strengthen the security of electronic
banking (e-banking) services.
As digitalisation and innovative banking services bring new levels of convenience
to customers, they also create additional avenues for fraudsters to commit digital
crimes. According to statistics compiled by the Police, the number of technology
crime cases reported in the first half of 2023 reached 15,000, representing an
increase of 47% over the same period last year. A similar increase is also
observed in the numbers of fraudulent websites, phishing emails, and other scams
reported by AIs to the HKMA.
Against this backdrop, the HKMA keeps its supervisory requirements on ebanking and other digital services under constant review. Earlier this year, the
HKMA’s conduct and prudential supervisory teams jointly developed a package
of measures to strengthen the security of payment card services. These measures
are contained in the circulars "Binding Payment Cards for Contactless Mobile
Payments" and "Major Enhancements on Protection of Payment Card Customers",
issued on 25 April 2023 and 20 June 2023 respectively.
In parallel with the above efforts, the HKMA has formulated a set of additional
measures, in collaboration with HKAB and the Police, to strengthen the security
of e-banking. These measures aim to increase the protection for bank customers
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against fraudsters seeking to conduct unauthorised transactions through e-banking
accounts. Details of these measures are set out below:
I. Enhanced monitoring for suspicious transactions and additional
customer authentication to counter frauds
- Dynamic fraud monitoring mechanism – In light of the growing
sophistication of deception tactics, AIs should establish dynamic fraud
monitoring rules incorporating the latest threat intelligence and customers’
historical data and transaction patterns. These rules should encompass a
broad spectrum of risk factors, including but not limited to, geographical
locations of logins, the time between successive logins and the value of the
requested transaction. To bolster fraud detection capabilities, scam
intelligence sources (e.g. Scameter) and network analytics tools should be
used to promptly identify suspicious transactions and accounts and generate
timely alerts to customers.
- Ambush authentication – If suspicious e-banking activities are detected (e.g.
access from suspicious IP addresses or device IDs), AIs should deploy
ambush authentication following a risk-based approach to verify the identity
of the person operating the e-banking account. This measure, if properly
designed, can make it substantially more difficult for fraudsters to conduct
unauthorised transactions. AIs should take appropriate follow-up actions,
such as account lock-out and sending notifications to customers, in cases of
multiple authentication failures.
- Additional confirmation for suspicious high-risk transactions – High-risk ebanking transactions are currently subject to two-factor authentication as
stated in the Supervisory Policy Manual (SPM) module TM-E-1 on “Risk
Management of E-banking”. Where high-risk e-banking transactions are
assessed to be suspicious by AIs (e.g. large-value fund transfer shortly after
device binding), AIs should request the customer to provide an additional
confirmation (e.g. in-App confirmation or callback) prior to executing the
transaction.
- Capability to implement multiple authentication methods – As stated in SPM
module TM-E-1, AIs are required to adopt effective authentication methods
to verify the identity of a customer. As fraudsters continually adapt their
tactics, multiple authentication methods are essential for countering different
modus operandi (e.g. use of facial recognition to reduce phishing risk and
soft tokens to address the risk of SIM swapping). AIs should therefore
maintain the capability to implement multiple authentication methods
commensurate with the evolving risk landscape.
II. Empowering customers to safeguard bank accounts
- Review of e-banking activities – To facilitate early detection of unauthorised
e-banking activities, AIs should provide customers with tools that empower
them to review and monitor account activities. These tools should make
available detailed information such as the login date and time, geographical
location and device information relating to a transaction, allowing customers
to promptly identify suspicious access to their e-banking accounts. In
addition, these tools should permit customers to perform searches for highrisk activities such as activation of device binding.
- Notification of unusual e-banking activities – In addition to notifying
customers of high-risk transactions, AIs should conduct risk assessments and
broaden the scope of notifications to include unusual e-banking activities (e.g.
changes in geographical locations, use of new devices and new login
behaviour). Such notifications can help customers detect suspicious
activities over their bank accounts early.
- Lowering default cross-border funds transfer limits – As it is common for
fraudsters to transfer a victim’s money out of Hong Kong, AIs should permit
customers to set a lower default cross-border transfer limit. Requests to
increase the cross-border transfer limit should normally be regarded as highrisk transactions.
- Restricting concurrent login sessions – To guard against unauthorised access,
AIs should put in place session management controls that disallow
concurrent logins to an e-banking account. Key data such as IP address,
device type, and geographical location of the additional login attempts should
be logged for auditing and threat analysis purposes.
III. Containing damage to customers in case of serious breaches
- Suspension of bank accounts – However robust the defence of banks is, the
possibility of a customer’s e-banking account being compromised by
fraudsters cannot be ruled out. To contain the damage to customers in such
cases, AIs should provide a mechanism for customers to promptly suspend
their e-banking accounts. The mechanism can be in the form of a dedicated
hotline or an easily accessible function available on internet banking or
mobile banking applications. Once a bank account is suspended,
appropriately stringent customer authentication should be performed before
the customer’s e-banking account is reactivated.
- Maintaining a 24/7 customer reporting channel – To facilitate customers to
report suspicious banking activities or potential fraud, AIs should offer a
convenient and accessible channel (e.g. through mobile banking applications
or other effective means) for customers to seek and obtain help.
Apart from the above enhancement measures, the HKMA will continue its
consumer education efforts to promote public awareness of e-banking frauds.
AIs are expected to actively participate in and contribute to these efforts.
AIs should implement the aforementioned e-banking enhancements as soon as
practicable, and in any case no later than 31 March 2024. Given that AIs are
currently implementing other enhancement measures to counter digital fraud,
including those relating to payment card protection, the HKMA is prepared to
exercise flexibility where an AI has genuine practical difficulties in observing this
implementation timeline.
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The HKMA will revise SPM module TM-E-1 to incorporate the above new
enhancement measures, as well as those relating to payment card security, into its
e-banking guidelines. Industry consultation on the amendments will be
undertaken in the next few months.
Should you have any questions about this circular, please feel free to contact Mr
Tsz-Wai Chiu on 2878 1389 or Mr Kevin Yau on 2878 1044.
Yours faithfully,
Raymond Chan
Executive Director (Banking Supervision)