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What the new NIST Standards Mean for Your Agency

Published: March 7, 2018 by Keir Breitenfeld

June 2018 will mark the one-year anniversary of the National Institute of Standards and Technology (NIST) release of Special Publication 800-63-3, Digital Identity Guidelines. While federal agencies are the most directly impacted, this guidance signals a seismic shift in identity proofing across the entire ecosystem of consumers, private sector businesses and public sector agencies. It’s the clearest claim I’ve seen to date that traditional, and rather basic, personally identifiable information (PII) verification should no longer be trusted for remote user interaction. For those of us in the fraud and identity space, this isn’t a new revelation, but one we as an industry have been dealing with for years. As the data breach floodgates continue to be pushed further open, PII is a commodity for the fraudsters, evident in PII prices on the dark web, which are often lower than your favorite latte.

Identity-related schemes have increased due to fraud attacks shifting away from card compromise (due to the U.S. rollout of chip-and-signature cards), double-digit growth in online and mobile consumer channels, and high-profile fraud events within both the public and private sector. It’s no shock that NIST has taken a sledgehammer to previous guidance around identity proofing and replaced it with an aggressive and rather challenging set of requirements seemingly founded in the assumption that all PII (names, addresses, dates of birth, Social Security numbers, etc.) is either compromised or easily can be compromised in the future. So where does this leave us?

I applaud the pragmatic approach to the new NIST standards and consider it a signal to all of us in the identity marketplace. It’s aggressive and aspirational in raising the bar in identity proofing and management. I welcome the challenge in serving our public sector clients, as we have done for nearly a decade. Our innovative approach to layered levels of identity verification, validation, risk assessment and monitoring adhere to the recommendations of the new NIST standards. I do, however, recommend that any institution applying these standards to their own processes and applications ensure they place equal focus on comparable alternatives for those addressable populations and users who are likely to either opt out of, or fail, initial verification steps stringently aligned with the new requirements. While too early to accurately forecast, it’s relatively safe to assume that the percentage of the population “falling out of the process” may easily be counted in the double digits. It’s only through advanced analytics and technology reliant on a significant breadth and depth of identity data and observations that we can provide trust and confidence across such a diverse population in age, demographics, expectations and access.

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Meeting Know Your Customer (KYC) regulations and staying compliant is paramount to running your business with ensured confidence in who your customers are, the level of risk they pose, and maintained customer trust. What is KYC?KYC is the mandatory process to identify and verify the identity of clients of financial institutions, as required by the Financial Conduct Authority (FCA). KYC services go beyond simply standing up a customer identification program (CIP), though that is a key component. It involves fraud risk assessments in new and existing customer accounts. Financial institutions are required to incorporate risk-based procedures to monitor customer transactions and detect potential financial crimes or fraud risk. KYC policies help determine when suspicious activity reports (SAR) must be filed with the Department of Treasury’s FinCEN organization. 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Define your Customer Identification Program (CIP) The CIP outlines the process for gathering necessary information about your customers. To start building your KYC checklist, you need to define your CIP procedure. This may include the documentation you require from customers, the sources of information you may use for verification and the procedures for customer due diligence. Your CIP procedure should align with your organization’s risk appetite and be comply with regulations such as the Patriot Act or Anti-money laundering laws. 2. Identify the customer's information Identifying the information you need to gather on your customer is key in building an effective KYC checklist. Typically, this can include their first and last name, date of birth, address, phone number, email address, Social Security Number or any government-issued identification number. When gathering sensitive information, ensure that you have privacy and security controls such as encryption, and that customer data is not shared with unauthorized personnel. 3. Determine the verification method There are various methods to verify a customer's identity. Some common identity verification methods include document verification, facial recognition, voice recognition, knowledge-based authentication, biometrics or database checks. When selecting an identity verification method, consider the accuracy, speed, cost and reliability. Choose a provider that is highly secure and offers compliance with current regulations. 4. Review your checklist regularly Your KYC checklist is not a one and done process. Instead, it’s an ongoing process that requires periodic review, updates and testing. You need to periodically review your checklist to ensure your processes are up to date with the latest regulations and your business needs. Reviewing your checklist will help your business to identify gaps or outdated practices in your KYC process. Make changes as needed and keep management informed of any changes. 5. Final stage: quality control As a final step, you should perform a quality control assessment of the processes you’ve incorporated to ensure they’ve been carried out effectively. This includes checking if all necessary customer information has been collected, whether the right identity verification method was implemented, if your checklist matches your CIP and whether the results were recorded correctly. KYC is a vital process for your organization in today's digital age. Building an effective KYC checklist is essential to ensure compliance with regulations and mitigate risk factors associated with fraudulent activities. Building a solid checklist requires a clear understanding of your business needs, a comprehensive definition of your CIP, selection of the right verification method, and periodic reviews to ensure that the process is up to date. Remember, your customers' trust and privacy are at stake, so iensuring that your security processes and your KYC checklist are in place is essential. By following these guidelines, you can create a well-designed KYC checklist that reduces risk and satisfies your regulatory needs. Taking the next step Experian offers identity verification solutions as well as fully integrated, digital identity and fraud platforms. Experian’s CrossCore & Precise ID offering enables financial institutions to connect, access and orchestrate decisions that leverage multiple data sources and services. By combining risk-based authentication, identity proofing and fraud detection into a single, cloud-based platform with flexible orchestration and advanced analytics, Precise ID provides flexibility and solves for some of financial institutions’ biggest business challenges, including identity and fraud as it relates to digital onboarding and account take over; transaction monitoring and KYC/AML compliance and more, without adding undue friction. Learn more *This article includes content created by an AI language model and is intended to provide general information.

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