ABA Banking Journal
No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
SUBSCRIBE
ABA Banking Journal
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive
No Result
View All Result
No Result
View All Result
Home Compliance and Risk

Mobile apps: Ensuring BSA and FFIEC compliance

January 19, 2023
Reading Time: 5 mins read
Mobile apps: Ensuring BSA and FFIEC compliance

Protections for mobile apps must have the capability to recognize and block the tools that criminals use and abuse to commit fraud.

By Karen Hsu

The global COVID-19 pandemic forced consumers to find contactless ways to take care of shopping, banking and other transactions, and many turned to mobile apps. A new way of doing things that seems to have stuck. Nearly 60 percent of mobile consumers said that they use and download a greater number of mobile apps and are using them to purchase more goods and services since early 2020, according to the Appdome 2021 Global Mobile Security Survey. Payment apps such as Venmo, Zelle, ApplePay and other fintech or mobile-based peer-to-peer consumer apps are seeing exponential growth.

Regulators have taken note. They have issued regulations and guidance to create standards that financial app makers need to meet to ensure that consumers are properly protected.

rightwards arrow
View more
risk and compliance articles

In the US, the Federal Financial Institutions Examination Council and the Federal Crimes Enforcement Network have laid out detailed regulations governing which and how mobile financial applications are to be protected. Banks that publish financial apps must be familiar with these regulations and create plans to make sure that they comply with the Bank Secrecy Act and can satisfy an FFIEC examination.

Compliance with BSA

The May 2019 FinCEN guidance further detailed the regulatory requirements for mobile wallets and other applications with similar functionality. Non-compliance can be extremely expensive and in some cases could result in prison time, so financial app publishers should definitely take these regulations seriously.

The BSA/AML regulations lays out the primary requirements that organizations must meet:

  • Maintain effective know your customer and AML programs.
  • For each transaction over $10,000, file a currency transaction report.
  • When the organization suspects or knows that transactions may involve money laundering or represents attempts to evade BSA requirements, file suspicious activity reports.

Mobile apps: Ensuring BSA compliance and passing FFIEC examinations

“FFIEC IT Examination Handbook” is published by the FFIEC to assist technology service providers, financial institutions and examiners with identifying and controlling the risks that retail payment systems and related banking activities may face.

A new appendix was added by the FFIEC in 2016 that is specifically for mobile applications, detailing the main risks that they carry. In broad terms, they include:

  • The ability for consumers and other end-users to download applications from app stores that not authorized by the manufacturer and may contain malicious code
  • Applications acting as a vector for the delivery of malware
  • The ability of end-users to run financial apps on rooted (Android) or jailbroken (iOS) devices in order to access root user privileges and remove the manufacturer’s device controls. Doing so could result in the user using untrusted sources to download apps which could install malware onto the device
  • Unencrypted storage of personal information on the device or in the app, such as email addresses, passwords and usernames
  • Unsecured secrets, tokens and URLs that can provide hackers with unauthorized access to back-end databases.

To comply with FFIEC and BSA regulation, mobile app publishers need to integrate fraud prevention and cybersecurity protections in their development, security and operations processes to ensure that they can regularly add new security protections into their new and updated Android and iOS apps. When combined with sufficient automation, DevSecOps enables organizations to avoid having to make terrible decisions about whether to delay the app, cut new features or release apps with unaddressed security vulnerabilities. It can do this because operations, security and development are synchronized and coordinated into a continuous workflow.

Security measures that enable compliance

Compliance requires a number of fundamental protections built into an app. For starters, a mobile app’s protections must be able to recognize and block the tools that criminals use and abuse to commit fraud. Most commonly, fraudsters abuse common developer tools that enable dynamic instrumentation, code injection, script injection, accessibility abuse and method hooking—all of which enable them to interfere with or modify the app. By blocking these functions, developers can deprive fraudsters of their tools of the trade, stopping fraud before it starts.

Additionally, the protections inside an app should prevent anyone from copying, altering, repackaging and resigning the app. This will help protect against many exploits, including weaponizing the app by creating a Trojan app that looks like the original and and generally mimics the original user experience. But they carry malicious code that can enable criminals to take over financial accounts and steal sensitive information.

A further tactic that hackers use is to elevate their permissions on the device by rooting (Android) or jailbreaking (iOS) it, which enables them to manipulate the financial apps that run on it. When an app is operating in a rooted / jailbroken environment, the app’s protections should be able to recognize the threat and shut down to protect itself.

Another fundamental protection for a financial app is strong encryption, which usually means encryption via the AES 256 standard. Often, protections in financial apps only encrypt data when it’s in the application sandbox, which is a protected area where applications run within the mobile device. However, this isn’t sufficient to protect data in the financial app. There are many other places where hackers can extract data if it’s left in the clear, most notably in an app’s code. The app needs to encrypt data in the strings, preferences, resources, in-app secrets and much more.

Data in an app’s code is especially sensitive because it includes login credentials, security certificates, back-end server URLs and keys that enable the app to connect to other services. With this data, hackers can successfully mount devastating attacks that target a financial institution’s core systems. They, too, must be protected using strong cryptographic protocols.

Protecting data within code, however, is particularly difficult to implement in a way that doesn’t negatively impact the app, and incorporating the other protections listed above requires a great deal of complicated, manual coding. Software development kits can reduce the amount of manual work that would be required starting from scratch, but they’re far from plug-and-play solutions. They can require a great deal of manual coding, which may be beyond the skills and resources of many development teams. Plus, these tools themselves may contain vulnerabilities, as they often depend on many layers of libraries and other code which could threaten compliance.

There are now, however, AI-powered, no-code platforms that can integrate security into the app, which saves time and increases precision and protection. When integrated into a development organization’s DevSecOps’ process, organizations can incorporate strong security without having to make trade-offs with their release schedule or app functionality.

Whatever choices are made regarding security implementation and anti-fraud protections, these are not areas where banks can afford to skimp. The risk of fraud and non-compliance is simply too large.

Karen Hsu is CMO of Appdome. She previously served as CEO of BlockchainIntel, which she co-founded. She also co-founded the non-profit Blockchain By Women.

Tags: Anti-money launderingBank Secrecy ActFraudMobile banking
ShareTweetPin

Related Posts

Basel Committee: Permissionless blockchains pose ‘novel’ risk challenges for banks

FDIC considering tokenized deposit insurance guidance, stablecoin issuer rules

Newsbytes
November 14, 2025

The FDIC is considering guidance on tokenized deposit insurance for banks that want to explore the option, and the agency plans to issue a proposal later this year to establish an application process for stablecoin issuers, FDIC Acting...

FinCEN, OFAC and FBI issue alert about timeshare fraud linked to organized crime

Treasury Department seeks to sever U.S. financial ties to 10 Mexican casinos

Compliance and Risk
November 13, 2025

The Treasury Department announced a joint effort with Mexico to target several Mexico-based gambling establishments involved in alleged cartel-related money laundering and other criminal activities.

Bank community engagement: Banking on care

Bank community engagement: Banking on care

Community Banking
November 13, 2025

Here are four ways banks can provide crucial support to the 63 million Americans who are caregivers.

Agencies form strike force to target cryptocurrency scams

Agencies form strike force to target cryptocurrency scams

Compliance and Risk
November 12, 2025

Federal law enforcement agencies announced the formation of an interagency “strike force” to target Southeast Asian cryptocurrency-related investment scams and confidence schemes.

ABA, associations object to CFPB ‘junk fee’ label for mortgage-related fees

CFPB proposes changes to fair lending enforcement

Compliance and Risk
November 12, 2025

The CFPB is proposing to remove disparate impact from its enforcement of the Equal Credit Opportunity Act, clarify the prohibition on discouraging prospective applicants, and establish new limits on special-purpose credit programs offered by lenders.

CFPB launches ‘tip line’ to report on bureau employees

CFPB proposes to streamline small-business data collection rule

Ag Banking
November 12, 2025

The CFPB is proposing revisions to its small-business lending data rule to scale back the scope of data collection, saying that adopting a “longer-term” approach that allows for the future addition of more data points would be the...

NEWSBYTES

FDIC considering tokenized deposit insurance guidance, stablecoin issuer rules

November 14, 2025

ABA DataBank: U.S. auto delinquencies approaching pre-Covid highs

November 14, 2025

Banking agencies release CRA data on small-business, small-farm lending in 2024

November 14, 2025

SPONSORED CONTENT

Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

Seeing More Check Fraud and Scams? These Educational Online Toolkits Can Help

November 1, 2025
5 FedNow®  Service Developments You May Have Missed

5 FedNow® Service Developments You May Have Missed

October 31, 2025

Cash, Security, and Resilience in a Digital-First Economy

October 20, 2025
Rethinking Outsourcing: The Value of Tech-Enabled, Strategic Growth Partnerships

Rethinking Outsourcing: The Value of Tech-Enabled, Strategic Growth Partnerships

October 1, 2025

PODCASTS

Podcast: The Erie Canal at 200

November 6, 2025

Podcast: Why branches are top priority for PNC

October 23, 2025

Podcast: From tractors to drones, how farming tech affects ag lending

October 16, 2025

American Bankers Association
1333 New Hampshire Ave NW
Washington, DC 20036
1-800-BANKERS (800-226-5377)
www.aba.com
About ABA
Privacy Policy
Contact ABA

ABA Banking Journal
About ABA Banking Journal
Media Kit
Advertising
Subscribe

© 2025 American Bankers Association. All rights reserved.

No Result
View All Result
  • Topics
    • Ag Banking
    • Commercial Lending
    • Community Banking
    • Compliance and Risk
    • Cybersecurity
    • Economy
    • Human Resources
    • Insurance
    • Legal
    • Mortgage
    • Mutual Funds
    • Payments
    • Policy
    • Retail and Marketing
    • Tax and Accounting
    • Technology
    • Wealth Management
  • Newsbytes
  • Podcasts
  • Magazine
    • Subscribe
    • Advertise
    • Magazine Archive
    • Newsletter Archive
    • Podcast Archive
    • Sponsored Content Archive

© 2025 American Bankers Association. All rights reserved.