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Who's to blame?
Revisiting the argument of who's to blame for these attacks, the blame can be supported on either side. The fact is that those involved need to think beyond the legal debate and continue to play each of their respective roles to counter this threat. I strongly believe that financial institutions need to "up-the--ante" and go well-beyond introducing those links on their web pages that educate users about keyloggers, viruses, Trojans and phishing attempts.
Some banks now provide RSA tokens that generate one-time passwords to mitigate the risk associated with stolen credentials to their customers -- but most still do not. Another example of some forward progress is the Stanford Federal Credit Union who has implemented an authentication solution from Passmark Security that goes beyond conventional passwords.
These approaches are significant initiatives and may not be economically feasible or timely solutions for many financial institutions -- after all, if their own systems are secure, what have they got to lose? Besides their customers and their customer's money, that is.
Even slight changes, such as a conspicuous message on the main page of the bank's website educating users about these threats and the appropriate countermeasures can be very useful. Or, displaying the latest phishing statistics from the Anti-Phishing Working Group would be very easy to do. Or, providing links to websites like Microsoft's Windows Update that checks both the browser and operating system patch levels can have a positive impact. These have virtually no cost to the financial institution, but can be a great value in educating their customers about the risks.
Regulators like the FDIC have already been advising financial institutions against using single-factor authentication and finally upgrading to two-factor authentication -- a positive step towards better security. Given the "epidemic nature" (as described by the US-CERT) of the problem, a more firm regulatory stance requiring the deployment of stronger authentication systems may prove to be successful.
In the meantime, let's all take control of our destinies, or at least our bank accounts, and doing the things that most SecurityFocus readers already know: patching our systems (especially those accessed via web browsers); installing personal firewalls; updating anti-virus definitions; browsing the Internet logged in as a non-administrative user on the operating system.; and educating users about the risks that probably still exist on their home machines. Every little bit can help.