The EBA blinks first …

EDIT: since posting this blog the UK’s FCA has confirmed our expectation that it won’t be enforcing SCA on the 14th September as long as the participants are aiming to comply with a soon to be announced migration plan. In the meantime it’s “working with the industry to develop a plan to migrate the industry to implement SCA for card payments in e-commerce as soon as possible”.  See: https://www.fca.org.uk/news/statements/fca-response-european-banking-authority%E2%80%99s-opinion-strong-customer-authentication

The doom-laden headlines appearing in the press have, it seems, worked and the EBA has decided to replace the 14th September deadline for the introduction of SCA with … another deadline. Only they won’t tell us what it is, presumably we have to figure it out for ourselves.  

So, let’s see what the EBA has done now …

Firstly, they haven’t actually changed the date as they can’t, it’s written into EU law. But given dire warnings of a collapse in online payments they’ve come up with a fudge:

The EBA therefore accepts that, on an exceptional basis and in order to avoid unintended negative consequences for some payment service users after 14 September 2019, CAs may decide to work with PSPs and relevant stakeholders, including consumers and merchants, to provide limited additional time to allow issuers to migrate to authentication approaches that are compliant with SCA, such as those described in this Opinion, and acquirers to migrate their merchants to solutions that support SCA.

https://eba.europa.eu/documents/

Let’s summarise that. National regulators – competent authorities (CAs) – may work with PSPs (Issuing and Acquiring banks) and unregulated actors (merchants, consumers) to agree to delay the introduction of SCA. Which presumably means unprepared merchants and confused consumers are breathing a sigh of relief. Unfortunately, as this is now in the hands of local regulators there’s no guarantee at all that this will be applied evenly, opening up the possibility that some countries will enforce and others (notably the UK and France) will not.

On top of that, there’s no guarantee that Issuers won’t apply SCA anyway, even if their local regulator permits them to not do so. So merchants who are unprepared may still find themselves suffering random declines. And, furthermore, if Acquirers haven’t implemented the necessary changes then even if the merchants are compliant they may still have transactions irrevocably declined.

Note also the “limited additional time” clause. Frankly, introducing SCA prior to the critical holiday shopping period was foolish anyway (but was an unintended consequence of the 18 month implementation period following the adoption of the RTS), so we can assume that the date will be pushed out at least into early or mid 2020. The EBA adds (but not in the actual Opinion):

In order to fulfil the objectives of PSD2 and the EBA of achieving consistency across the EU, the EBA will later this year communicate deadlines by which the aforementioned actors will have to have completed their migration plans.

And that’s the catch:

This supervisory flexibility is available under the condition that PSPs have set up a migration plan, have agreed the plan with their CA, and execute the plan in an expedited manner. CAs should monitor the execution of these plans to ensure swift compliance with the PSD2 and the EBA’s technical standards and to achieve consistency of authentication approaches across the EU.

Basically, Issuers and Acquirers need to publish what they’re going to do including how they’re going to communicate the requirements to consumers and merchants respectively. Quite how this is all going to be co-ordinated is unclear – no sensible merchant is going to disadvantage themselves by unilaterally turning on SCA when its competitors aren’t. Issuers may take the same approach, as they probably don’t want their cardholders switching to other banks: but there’s no requirement on them to do so.

The rest of the opinion focuses on the validity of various authentication factors. That’s interesting too, but we’ll look at the implications of it another day.

The one thing this does allow is for 3DS-2.2 to be made ready. That’s an advantage to smart merchants who can at least develop a proper, low friction SCA strategy. In the meantime, we’re looking forward to getting involved in lots of migration planning.

Digital Identity Alphabet Soup

We’ve been attending various identity conferences over the last few months, including KNOW 2019, the Internet Identity Workshop, and IdentityNORTH in North America, and EIC and Identity Week in Europe. One of the major themes that continues to stand out in all these events is the number of simultaneous initiatives going on around the world to create standards addressing various aspects of digital identity. It’s one of the reasons we created our 3-Domain Identity Model (see here for a refresher on 3DID), to help our clients navigate their way through all of this and to think about where they may play a role.

Interoperable digital identity will only be possible if there is agreement on how the systems will work from a business, legal and technical standpoint. The variety of proposed international and national standards, guidelines and technology protocols leave our clients wondering “Which of these should I use and when?”.

When we look at the solutions being built the picture is equally confusing. Some are built on open standards, while others are based on proprietary developments, and some are a combination of the two. Some are built for specific industries like healthcare, financial services, or government services. To date, the focus of many digital identity solutions has been within the identification domain (i.e. customer onboarding, ID proofing, KYC, etc.), however the general movement of the industry is now shifting towards a broader ecosystem enabling the sharing of trusted or verifiable data centered around the subject (person, organization or thing).

All these factors have led to a fragmentation of the digital identity market. But all is not lost. Several collaborative cross-sector organizations are actively working to get everyone on the same page.

To try to make some sense of all these initiatives, we pulled together the diagram below to give a representative example (not exhaustive) of the ongoing efforts across each of the domains of identity. Some of these have been developed for targeted purposes (e.g. FIDO biometric authentication) while others have a broader approach that crosses all three domains (e.g. the Pan-Canadian Trust Framework).


Comparing identity standards, solutions and services can be difficult. While in general these are all trying to solve similar problems, they can approach it in quite different ways. Any of these initiatives in isolation will not get us all on the same page.

It has been encouraging to see over the last few months, across the digital identity community, the spirit of collaboration continuing to strengthen. The effort has been building for a few years now, but this year has seemed different with many of the key organizations across the spectrum joining forces and recognizing the necessity to meet the needs of all users to solve the lack of trust online today.

In that spirit, do get in touch if you want to discuss any of these things further. We do not have all the answers, but we hope that an open and collaborative dialogue will help us all to move forward.

Identity Week

The opening keynote at identity week in London was given by Oliver Dowden, the Minister for implementation at the Cabinet office and therefore the person in charge of the digital transformation of government. At Consult Hyperion we think digital identity is central to digital transformation of government (and the digital transformation of everything else, for that matter) so I was looking forward to hearing the UK government’s vision for digital identity. I accompanied the Minister on his visit to the IDEMIA stand where he was shown a range of attractive burgundy passports.

In his keynote, the Minister said that the UK is seen as being at the cutting edge of digital identity and that GOV.UK Verify is at the heart of that success.

(For foreign visitors, perhaps unfamiliar with this cutting edge position, a spirit of transparency requires me to note that back on 9th October 2016, Mr. Dowden gave written statement HCWS978 to Parliament, announcing that the government was going to stop funding Verify after 18 months with the private sector responsible for funding after that.)

Given that the government spends around £1.5 billion per annum on “identity, fraud, error, debt, how much identity costs to validate, and how much proprietary hardware and software bought”, it’s obviously important for them to set an effective strategy. Now, members of the public, who don’t really know or care about digital ID might be saying to themselves, “why can’t we just use ‘sign in with Apple’ to do our taxes?”, and this is a good point. Even if they are not saying it right now, they’ll be saying it soon as they get used to Apple’s mandate that all apps that allow third-party sign-in must support it.

Right now you can’t use a GOV.UK Verify Identity Provider to log into your bank or any other private sector service provider. But in his speech the Minister said that he looks forward to a time when people can use a single login to “access their state pension and the savings account” and I have to say I agree with him. Obviously you’d want a different single login for gambling and pornography, but that’s already taken care of as, according to Sky News, “thanks to its ill-conceived porn block, the government has quietly blundered into the creation of a digital passport – then outsourced its development to private firms, without setting clear limits on how it is to be used”. One of these firms runs the world’s largest pornography site, Pornhub, so I imagine they know a thing or two about population-scale identity management.

Back to the Minister’s point though. Yes, it would be nice to have some sort of ID app on my phone and it would be great if my bank and the HMRC and Woking Council and LinkedIn would all let me log in with this ID. The interesting question is how you get to this login. Put a PIN in that and we’ll come back to it later.

The Minister made three substantive points in the speech. He talked about:

  • The creation of a new Digital Identity Unit, which is a collaboration between DCMS and Cabinet Office. The Unit will help foster co-operation between the public and private sector, ensure the adoption of interoperable standards, specification and schemes, and deliver on the outcome of the consultation.
  • A consultation to be issued in the coming weeks on how to deliver the effective organisation of the digital identity market. Through this consultation the government will work with industry, particularly with sectors who have frequent user identity interactions, to ensure interoperable ‘rules of the road’ for identity.
  • The start of engagement on the commercial framework for consuming digital identities from the private sector for the period from April 2020 to ensure the continued delivery of public services. The Government Digital Service will continue to ensure alignment of commercial models that are adopted by the developing identity market to build a flourishing ecosystem that delivers value for everyone.

The Minister was taken away on urgent business and therefore unable to stay for my speech, in which I suggested that the idea of a general-purpose digital identity might be quite a big bite to take at the problem. So it would make sense to look at who else might provide the “digital identities from the private sector” used for the delivery of public services. Assuming the current GOV.UK Verify identities fail to gain traction in the private sector, then I think there are two obvious private sector coalitions that might step in to do this for the government: the big banks and the big techs.

For a variety of reasons, I hope that the big banks are able to come together to respond to the comments of Mark Carney, the Governor of the Bank of England, on the necessity for a digital identity in the finance sector to work with the banks to develop some sort of financial services passport. I made some practical suggestions about this earlier in the year and have continued to discuss the concept with potential stakeholders. I think it stacks up, but we’ll have to see how things develop.

On the other hand, if the banks can’t get it together and the big techs come knocking, they are already showing off their solutions. I’ll readily admit that when the Minister first said “private sector identities”, the first thought to flash across my brain was “Apple”. But I wouldn’t be at all surprised to go over to the HMRC web site fairly soon to find a “log in with Amazon” and “log in with Apple” next a button with some incomprehensible waffle about eIDAS that I, and most other normal consumers I’m sure, will simply ignore.

How do you use Apple ID to log into the Inland Revenue? Easy: you log in as you do now after sending off for the password and waiting for it to come in the post and that sort of thing and then once you are connected tell them the Apple ID that you want to use in the future. If you want to be “jackdaniels@me.com” or whatever, it doesn’t matter. It’s just an identifier for the Revenue to recognise you in the future. Then next time you go to the Inland Revenue, you log in as jackdaniels@me.com, something pops up on your iPhone and you put your thumb on it or look at it, and bingo you logged in to fill out your PAYE.

Yet another GDPR article – the story so far

How time flies, GDPR has just had its first birthday!

This past year you will have been inundated with articles and blogs about GDPR and the impact on consumers and businesses alike. According to the UK’s Information Commissioner, Elizabeth Denham, GDPR and its UK implementation, the Data Protection Act (DPA) 2018, has marked a “seismic shift in privacy and information rights”. Individuals are now more aware of their information rights and haven’t been shy about demanding it. In the UK, the ICO received around 14,000 personal data breach reports and over 41,000 data protection concerns from the public from 25 May 2018 to 1 May 2019, compared to around 3,300 PDB reports and 21,000 data protection concerns in the preceding year. Beyond Europe, the regulation has had a remarkable influence in other jurisdictions, where they have either enacted or are in the process of enacting a ‘GDPR equivalent’ law – something similar is underway in Brazil, Australia, California, Japan and South Korea.

With all the good intentions of GDPR some of its provisions contradict, other, equally well-intentioned EU laws. Bank Secrecy Laws on one hand, require that customers’ personal data should be protected and used for the intended purpose(s), except where otherwise consented to by the customer. AMLD4/5 on the other hand, requires that identifying personal data in ‘suspicious transactions’ should be passed on to appropriate national authorities (of course without the customer’s consent/ knowledge). Then PSD2 requires banks to open up customers’ data to authorised Third Party Providers (TPPs), subject to obtaining the customer’s consent. One issue that arises out of this is the seeming incongruity between Article 94 PSD2’s explicit consent, and GDPR’s (explicit) consent.

Under GDPR, consent is one of the lawful bases for processing personal data, subject to the strict requirements for obtaining, recording, and managing it, otherwise it’s deemed invalid. In some cases, a lack of good understanding of these rules has resulted in poor practices around consent processing. That is why organisations like the Kantara Initiative are leading the effort in developing specifications for ‘User Managed Access’ and ‘Consent Receipt’.

In addition, EU regulators have been weighing in to clarify some of the conundrums. For example, the Dutch DPA issued a guidance on the interplay of PSD2/GDPR, which shows that there’s no straightforward answer to what seems like a relatively simple question, as one might think. The EDPB has also published an opinion on the interplay between GDPR, and the slowly but surely evolving ePrivacy regulation. Suffice to say, correctly navigating the compliance requirements of all these laws are indeed challenging, but possible.

What will the second year of GDPR bring?

While regulators are keen to enforce the law, their priority is transparent co-operation, not penalties. The ICO has provided support tools, and guidance, including a dedicated help line and chat services to support SMEs. They are also in the process of “establishing a one-stop shop for SMEs, drawing together the expertise from across our regulatory teams to help us better support those organisations without the capacity or obligation to maintain dedicated in-house compliance resources.” However, for those who still choose to ‘wilfully or negligently break the law’, GDPR’s recommended administrative fines may help to focus the mind on what is at stake, in addition to the ‘cleaning up’ costs afterward. Supervisory Authorities require time and resources to investigate and clear the backlog as a result of the EU wide increase in information rights queries and complaints of the past one year. The UK’s ICO, and its Netherlands and Norwegian counterparts are collaborating to harmonise their approaches and establish a “matrix” for calculating fines. France’s CNIL has led the way with the $57 million Google fine earlier in the year, however, the ICO has confirmed that there will soon be fines for “a couple of very large cases that are in the pipeline, so also,the Irish DPC expects to levy substantial” fines this summer.

A new but important principle in GDPR is the ‘accountability principle’ – which states that the data controller is responsible for complying with the regulation and must be able to demonstrate compliance. So, it is not enough to say, ‘we have it,’ you must be able to produce ‘appropriate evidence’ on demand to back it up. The ICO states in its ‘GDPR – one year on’ blog that “the focus for the second year of the GDPR must be beyond baseline compliance – organisations need to shift their focus to accountability with a real evidenced understanding of the risks to individuals in the way they process data and how those risks should be mitigated.” By now one would expect that most organisations would have put in the effort required beyond tick boxes to achieve an appropriate level of compliance with the regulation so they can reap the reward of continued business growth borne out of trust/loyalty from their customers.

One of the methods of demonstrating GDPR accountability is through a Data Protection Impact Assessment­ (DPIA) – a process by which organisations can systematically analyse, identify, and minimise the data protection risks of their project or plan ‘before going live.’ GDPR does not mandate a specific DPIA process, but expects whichever methodology chosen by the data controller to meet the requirements specified in its Article 35(7).

At Consult Hyperion, we have a long track record of thinking about the risks associated with transactional data, so much so that we published and continue to use our own Structured Risk Analysis (SRA) methodology. Our approach, in response to the needs of our customers, has always been to describe the technological risks in a language that allow the business owner, who ultimately owns the risk, to make a judgement. Building on this we have developed a business focused approach to GDPR compliant DPIA to help our customers, for the products we design, review, or develop for them.

If you’re interested in finding out more, please contact: sales@chyp.com

Know 2019 Vegas

Well, Know 2019 in Las Vegas was great. Having attended the One World Identity (OWI) “KnowID” Washington events, it was exciting to see them grow and relocate to Las Vegas!

The event began with an “Education Day” on the Sunday preceding the main event. Consult Hyperion ran a couple of the sessions and we were taken aback at the turnout – standing room only in the session discussing the digital identity of people, companies and things that we presented with Mastercard and PaymentWorks (the hotel staff had to bring in three stacks of chairs during the talk!) and while we’d like to think that this is solely a reflection of Consult Hyperion’s leading position in the industry, we took it as a reflection of the increasing importance of digital identity across corporate strategies in a range of sectors.

As most of our clients are in the financial services sector, we naturally paid most attention to the presentations and discussions around digital identity in banking and finance. Mastercard chose the event to drive a stake into the ground around digital identity, with the launch of their paper on the topic, “Restoring Trust in a Digital World”. This presented a framework of how digital identity will work, putting the individual at the heart of every digital interaction. Mastercard’s commitment to the sector reinforced many peoples’ view that digital identity has gone up the priority list to become a matter of immediate concern for financial institutions, regulators and customers. The scale of identity theft and fraud on the one hand and the costs of patchwork digitised identity solutions on the other hand may not the pressure for real change is growing.

Outside the financial sector, I particularly enjoyed the keynote on the third day from Colleen Manaher from the US Customs and Border Control. She was talking about the use of biometrics and spent some of the time talking about the specific use of biometrics in airports as an interesting example of how to use biometric technologies for security but at the same time deliver convenience into the mass market.

The point of her talk, was partnerships around identity. In this case, she was talking about quite complex public-private partnerships in travel. The investments made in biometrics to allow paperless travel have obvious benefits in terms of security but, as we have found in our other work about the cross-sector exploitation of digital identity, intelligent use of these new capabilities can also transform the customer experience. The same biometric system that scans your passport picture on entry to the airport and then checks you in for your flight can also be used to direct you through the airport and implement smart departure boards that as you approach them switch from displaying a list of all flights to displaying your flight only.

The use of digital identity, as a means to provide what looks like convenience to the man in the street but under the hood provides much higher levels of security than are currently obtained through the use of physical documents and manual checking opens up new possibilities and set me thinking about how to replicate this dynamic, in other sectors. An obvious example of this back in financial services is for the kind of digital ID called for by Mark Carney, the governor of the Bank of England, which would result in significant cost savings around the K YC and AML for the banks but should at the same time mean that customers can connect securely and quickly to their financial services providers.

We were sad to leave Las Vegas after such a great event but I can assure you that we’ll be back there again next year for Know2020.

Loosely-coupled MaaS payments

I was a panellist discussing the barriers to mobility as a service (MaaS) at the Transport Ticketing Global (TTG19) conference in London in January. In fact, many of the presentations over the two-day conference were about MaaS and reasons why it is proving very hard to deliver. Perhaps one of the most mature MaaS offerings is the one from MaaS Global branded as ‘Whim’ which launched in the UK in the West Midlands but, by their own admission, has struggled to gain a foothold.

Until recently, MaaS providers have avoided London. We have seen some excellent journey planning apps exploiting Transport for London’s (TfL)  open APIs, but nobody was going that extra mile and actually proving a complete MaaS solution in a single app that allow both planning journeys together with payment and ticketing (i.e. proving authority to travel when entering the transit network). TfL has been very clear that they will not provide any cut of the fares to MaaS providers, so they will have to find other ways to make a profit.

So, the announcement from CityMapper that they are about to launch a MaaS solution in London surely doesn’t make any sense? Given the above barriers to MaaS and the high complexity of London’s public transport network, why on earth would you start there?

The answer is payments and identity, two of our favourite topics. These are services needed in order to offer account-based ticketing (ABT) and ABT is a corner-stone of MaaS. Passengers need to identify themselves to their customer account so that their journey charges can be calculated. Payment for the journeys needs to be handled in a way that is suitable to the particular customer.

One of the barriers I suggested on the TTG19 panel is that payment and identity are too ‘closely coupled’ in modern account-based ticketing offerings. I am old enough to remember the emergence of service oriented architectures in the ‘noughties’. The idea was that by ensuring services are ‘loosely coupled’, they can freely evolve without affecting consumers or implementations. I argued that if everyone rushes to implement the open-loop payment models with the payment networks like TfL has done, then we will be left with fare collection services that are highly dependent on the payment schemes and constrained from evolution. The identifier the passenger uses at the gate is their bank card (or its emulation on mobile or wearable devices). This identifies them to their ABT travel account but it also identifies their means of payment. Some would say this is convenient, I am suggesting it is too closely coupled and will stifle innovation.

Open banking APIs are a subject close to our hearts at the moment. The APIs are very new and they seem not to be thinking about transit payments at this stage. However, one could imagine that there could be future open banking APIs that would allow passengers to consent to transit payments from their bank to their MaaS provider without the need for the payment networks in between. I expect this will be subject of future blogs or white papers from Chyp.

The reason CityMapper is launching in London is that all the public transport modes accept open-loop payments and the CityMapper solution to payments and identity is to provide their MaaS customers with a Mastercard-branded prepaid card, ‘Pass’. CityMapper will offer a subscription model at a discount on TfL prices and any travel on TfL modes outside of this will simply use the prepaid bank card like any other.

This works for all London public transport modes, but there are very few other cities that have committed so totally to the open-loop models. It will be interesting to see whether CityMapper can make a profit and if they do, whether they can replicate it outside of London. Right now, it looks like they are using investment funding and planning on taking a loss to start with since they are offering to undercut the TfL fares and as stated above TfL has said they will not offer discounts to Maas providers. Or perhaps city mapper is planning on selling advertising space or plans to sell anonymised travel data to make up the shortfall? Only time will tell.

Meanwhile, may all your transit tokens be loosely coupled and your payment instruments plentiful.

Why can’t I use Apple Pay for everything online?

Pottering around on Twitter, I noticed an interesting question:

Why can’t I use Apple Pay for everything online? Shouldn’t there be some way for me to hold my phone up to the screen when I get to an order page online and scan a QR code and hold my thumbprint or something? — Joe Weisenthal (@TheStalwart) January 2, 2019

Joe has a point. Apple Pay is far more secure, and far more convenient, than messing around typing card numbers in to web pages as we did back in 1998. And globally, merchants lose some $20-$30 billion per annum in card-not-present fraud, so why aren’t we using our (secure) mobile payment systems to pay for things we buy on the (insecure) web already?

Well, first of all you can use Apple Pay to pay for things on the web but only if you are using Safari and only if the merchant has implemented Apple Pay. The merchants, however, don’t want to implement a solution that only works for a small proportion of their customers (ie, people who use iPhone, Safari on the web and have Apple Pay configured correctly). Merchants would prefer a more universal solution such as W3C or SRC.

Change, however, may be just around the corner.

Barclays Equity Research put out an interesting note on payments in November. Called “Sleepwalking into 3DS2.0 and PSD2”, it kicks off by saying that “the mandated 3-D Secure 2.0 and the requirement for two-factor Secure Customer Authentication (SCA) are around the corner, but the industry does not seem ready for this major change in transaction processing protocols”.

Well, quite. I’m glad to see they agree with our decision to make SCA the highest priority of our “Live 5” areas for our clients to focus on in the coming year.

In this note, Barclays say that an unintended consequence of PSD2 will be a better e-commerce experience on mobile, where biometrics are a convenience technology, rather than the desktop, and this should benefit digital wallets (again as we note in our Live 5). In the store too, mobile may have the advantage. Contactless payments will require a PIN entry every five transactions or €150 (depending which the issuer mandates), unless an online transaction in the interim authenticates the card and restarts the counter.

However, an Apple Pay or Google Pay mobile transaction would be authenticated every time and because of CDCVM, can ignore the contactless limit (currently £30 in the UK). While a card is arguably marginally easier than mobile wallets today for contactless, this may be enough to shift the advantage to mobile. 

Thus, the future of secure retail transactions will converge on the smartphone, irrespective of whether those transactions are physical or virtual.

Consult Hyperion’s Live 5 for 2019

It’s that time of year again. I’ve had a chat with my colleagues at Consult Hyperion, gone back over my notes from the year’s events, taken a look at our most interesting projects around the world and brought together our “live five” for 2019.  Now, as in previous years, I don’t expect you to pay any attention to our prognostications without first reviewing our previous attempts, otherwise you won’t have any basis for taking us seriously! So, let’s begin by looking back over the past year and then we’ll take a shot at the future.

Goodbye 2018

As we start to wind down 2018, let’s see how we did…

  1. 1. Open Banking. Well, it was hardly a tough call and we were bang on with this one. We’ve been working on open banking projects in the UK, on the continent and beyond. What seems to be an obviously European issue, is of course a global one and we’ve been helping the global payment brands understand the opportunities. Helping existing market participants and new market entrants to develop and implement responses to open banking has turned out to be intellectually challenging and complex, and we continue to build our expertise in the field. Planning for the unintended consequences of open banking and the potentially un-level playing field that’s been created by the asymmetry of data, was not the obvious angle of opportunity for traditional tier one banks.

  2. 2. Conversational Transactions. Yes, we were spot on with this one and not only in financial services. Many organisations are shifting to messaging channels for customer support and for transactions, in both the banking and retail sectors. The opportunity for this continues with the advancements of new messaging enablers, such as the GSMA backed RCS. But as new channels for support and service are introduced to the customer experience, so are new points of vulnerability.

  3. 3. The Internet of Cars. This is evolving although the security concerns that we spoke about before, continue to add friction to the development of new products and services in this area. Vulnerabilities to card payments or building entry systems are security threats, vulnerabilities to connected or autonomous vehicles are potentially public safety threats.

  4. 4. Artificial Intelligence. Again, this was an easy prediction because many of our clients were already active. Where we did add to thinking this past year, it was about the interactive landscape of the future (i.e. bots interacting with bots) and how the identity infrastructure needs to evolve to support this.

  5. 5. Tokens/ICOs. Well, we were right to highlight the importance of “tokens” (the basis of Initial Coin Offerings, or ICOs) and our prediction that once the craziness is out of the way, then regulated token markets will become significant looks to be borne out by mainstream commentary. At Money2020 Asia in Singapore, I had the privilege of interviewing Jonathan Larsen, Corporate Venture Capital Manager at Ping An and CEO of their Global Voyager Fund (which has a $billion or so under management). When I put to him that the tokenisation of assets will be a revolution, he said that “tokenisation is a really massive trend… a much bigger story than cryptocurrencies, initial coin offerings (ICOs), and even blockchain”.

As we said, 2018 has seen disruption because the shift to open banking, starting in the UK,has meant the reshaping of financial services while at the same time the advance of AI into the transaction flow (transactions of all types, from buying a train ticket to selling corporate bonds) begins to reshape the way we do business.

Hello 2019

This year we are organising our “live five” in a slightly different way, listing them by priority to our clients rather than as a simple list. So here are the four key technologies that we think will be hot throughout the coming year together with the new technology that we are looking at out of the corner of our eyes, so to speak. The mainstream technologies are authentication,cross-sector digital identity, digital wallets for ticketing and secure IoT in the insurance sector. The one coming up on the outside is post-quantum cryptography.


So here we go…


  1. 1. With our financial services customers we are moving from developing strategies about open banking to developing implementation plans and supporting the development of new systems and services. The most important technology at the customer interface from the secure transactions perspective is going to be the technology of Strong Customer Authentication (SCA). Understanding the rules around which transactions need SCA or not is complicated enough, and that’s before you even start working out which technologies have the right balance of security and convenience for the relevant customer journeys. Luckily, we know how to help on both counts!

As it happens, better authentication technology is going to make life easier for clients in a number of ways, not only because of PSD2. We are already planning 3D Secure v2 (3DSv2) and Secure Remote Commerce (SRC) implementations for customers. Preventing “authentication friction” (using e.g. FIDO) is central to the new customer journeys.

  1. 2. Forward thinking jurisdictions such as Canada and Australia have already started to deliver cross-sector digital identity (where in both cases we’ve been advising stakeholders). New technologies such as machine learning, shared ledgers and self-sovereign identity, if implemented correctly, will start to address the real issues and improvements in know your customer (KYC), anti-money laundering (AML), counter-terrorist financing (CTF) and the management of a politically-exposed person (PEP).  The skewed cost-benefit around regtech and the friction that flawed digitised identity systems cause, mean that there is considerable pressure to shift the balance and in the coming year I think more organisations around the world will look at models adopted and take action.

  1. 3. In our work on ticketing around the world, we see a renewed focus on the deployment of real digital wallets. Transit and other forms of ticketing (such as for sporting events) are the effective anchor tenants of the digital wallet, not payments. In the UK and in some other countries there has been little traction for the smartphone digital wallet because of the effectiveness of the deployment and use of contactless cards. If you look in your real wallets, most of what your find isn’t really about payments. In our markets, payments alone do not drive consumers to digital wallets, but take-up might be about to accelerate. It’s one thing to have xPay put cards into a digital wallet but putting your train tickets, your sports rights and your concert passes into a digital wallet makes all the difference to take-up and means serious traction. Our expertise in using the digital wallets for applications beyond payments will give our clients confidence in setting their strategies.

  2. 4. In the insurance world we see the business cases building around the Internet of Things (IoT). The recent landmark decision of John Hancock, one of the oldest and largest North American life insurers, to stop selling traditional life insurance and instead sell only “interactive” policies that track fitness and health data through wearable devices and smartphones is a significant step both in terms of business model and security infrastructure. We think more organisations in the insurance sector will develop similar new services.  Securing IoT systems becomes a priority. Fortunately, our very structured risk analysis for IoT and considerable experience in the practical assessment of countermeasures, deliver a cost-effective approach.

  3. 5. In our core field of security, we think it’s time to start taking post-quantum cryptography (PQC) seriously not as a research topic but as a strategic imperative around the development and deployment of new transaction systems. As many of you will know, Consult Hyperion’s reputation has been founded on the mass-market deployments of new transactions systems and services and this means we understand the long-term planning of secure platforms. We’re proud to say that we have helped to develop the security infrastructure for services ranging from the Hong Kong smart identity card, to the Euroclear settlement system and from contactless payments to open loop ticketing in major cities. Systems going into service now may well find themselves overlapping with the first practical quantum computer systems that render certain kinds of cryptography worthless, so it’s time to add PQC to strategies for the mass market.

And there you have it! Consult Hyperion’s Live 5 for 2019. Brexit does not mean the end of SCA in the UK (since PSD2 has already been transcribed into UK law) and SCA means that secure digital identities can support transactions conducted from digital wallets, and those digital wallets will contain things other than payment instruments. They might also start to store transit tickets or your right to travel, health and fitness data for your insurance company. Oh, and all of that data will end up in the public sphere unless the organisations charged with protecting it start thinking about post-quantum cryptography or,as Adi Shamir (one of the inventors of public key cryptography) said five years ago, post-cryptographysecurity.

Cyber Monday is here – and SRC is on its way

With estimates of the sales over the Black Friday weekend in excess of £7bn in the UK and $90bn in the USA, retailers are currently focused on getting shoppers into their stores and through their checkouts as seamlessly as possible. As was apparent at last week’s US Payments Forum, the last part of that process, payment, is probably the one area that the retailer believes it has the least control over. Online the problem is even greater; consumers have a variety of ways to authenticate themselves to their bank and to their retailer, many of which leave something to be desired.

75% of sales on Black Friday are online and Cyber Monday is set to be the biggest yet. Many of these online sales depend on consumers having to manually enter card details, or log-in using dimly remembered passwords. Those who are not blessed with the memory of an elephant may have to undergo password reset processes that can involve checking rarely used email addresses or having to remember the incorrect spelling of their answers to a wide variety of questions about their past history. Having apparently completed the process, the percentage of remote transactions that are then declined by the Issuer is around 10 times greater than those completed in the store. Not all these declines will be valid, with legitimate customers being turned away in the name of fraud prevention. Even so  millions of pounds of the approved transactions in the UK alone will still turn out to be fraudulent, further undermining the trust of the merchant and consumer alike.

Isn’t it strange that we live in a world where there is significant growth in online sales, but the mechanisms used to pay for those purchases are more cumbersome, less secure and less reliable than those used to buy on the high street? The good news is that the Payment Brands think that this is strange too and have a plan to fix it!

Earlier this month they published a draft version of their Secure Remote Commerce specification, which outlines an approach to promote security and interoperability within the card payment experience in a remote payment environment. The specification is currently out for public consultation. The Payment Brands are looking for feedback from those organizations which will deliver, interact with or use such solutions. (I know a few people who have read them and can help you to shape your reply if you are interested.) We may not see commercial solutions deployed in time for next year’s Black Friday event – these things take time. However they do offer the potential for interoperable payment solutions, with common authentication processes and levels of data security similar to those currently experienced on the high street.

In the short term, I really need to update the TV. So, in preparation for a flurry of holiday season internet shopping, I have cleared funds on my payment cards, cleaned the fingerprint readers on my tablets, found my long paper list of passwords and a similar list of answers to security questions. However, I can’t remember; was my first dog called Fido or Fenton?

Securing Payments in a Post-EMV Chip World

Now that the US has (finally) migrated from magnetic stripe to chip payments, and signature will soon be going too, the time has come to think about where the fraud will go next. This was the topic of a great discussion at Money 20/20 involving amongst others EMVCo, Capital One and USAA.

Obviously the first place fraud will jump to will be card-not-present transactions such as e-commerce. This is well understood by those of us who went through the EMV chip migration over a decade ago. Brian Byrne outlined the various initiatives in EMVCo to secure these transactions – Tokenisation, 3DS 2.0 (with live solutions being imminent) and SRC (which is open for public comment).

Increasingly though it’s an identity problem. Identity theft and synthetic identities are being used to attack payments in a number of ways.

Because EMV chip cards are much harder to counterfeit than magnetic stripe cards, fraudsters instead will try to get their hands on genuine cards. This could be through opening a fraudulent account or by taking over an account and ordering a replacement card.

Identity fraud will be a big issue in faster payments too, with a need for good authentication on both ends of the transaction.

Synthetic identities are a particular challenge. Detecting them is tough, spotting the subtle clues that indicate that an identity record which looks legitimate has actually be cultivated over time by a fraudster. And this is big business, with criminals using the latest machine learning and ready access to data (thanks to all of those breaches) to launch well organised attacks at scale.

In the following session, Professor Pedro Domingos (author of “The Master Algorithm”) gave the great quote “if you try to fight machine learning with code you are doomed”. But it is not simply a case of implementing machine learning. As the Prof explained, the characteristics of fraud are constantly changing so any machine learning system will need to be constantly tuned and re-trained to keep up.

Definitely a case of whack-a-mole.


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