The two sets of authentication guidance created by the US Government that are widely used in the private sector are the Federal Financial Institutions Examination Council (FFIEC) authentication guidance to financial institutions, and the NIST Electronic Authentication Guideline. This blog post takes a look at a sub-set of the guidance that is focused on what each deems acceptable for authentication controls and tokens.
The FFIEC guidance, while less prescriptive, provides a higher level view when it comes to protecting the end to end transaction using a combination of risk assessment, governance processes and technical controls which encompass areas such as device authentication and privilege management. The NIST guidance is much more explicit when it comes to requirements around identity proofing, authentication controls and tokens.
The thought that kept running through my mind when I was re-reading both documents was that if they were combined, and certain aspects were highlighted and if needed reconciled, it would provide an excellent and holistic approach to risk assessment, authentication, authorization and compensating controls.
But that is a substantial piece of work for another time, so without wanting to boil the ocean, I thought I would explore a potential area of overlap, which is the guidance regarding authentication tokens:
The one theme that is common across both is that single factor authentication is no longer sufficient for any type of high risk or higher LOA transactions, and the notion that using a combination of authentication factors (something a person knows, something a person has, something a person is) is stronger than use of one. The FFIEC Guidance Appendix from 2005 provides some concrete examples of acceptable tokens that overlap with token guidance in the NIST document.
I would be interested in any pointers to work that show a formal cross-walk between the two documents on this topic. Just as important, I am rather interested in which of the FIs (or their service providers) currently implement techniques that utilize multiple authentication factors.
- FFIEC - Authentication in an Internet Banking Environment from 2005 (PDF)
- FFIEC - Supplement to Authentication in an Internet Banking Environment from 2011 (PDF)
- NIST Electronic Authentication Guideline (NIST SP-800-63-1) (PDF)
- NIST SP-800-63-1 Multi-Token Assurance Level Matrix
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This blog post first appeared on Anil John | Blog (https://blog.aniljohn.com). The opinions expressed here are my own and do not represent my employer’s view in any way.