Back in 2005, the Federal Financial Institutions Examination Council (FFIEC) made security recommendations for banks and financial institutions in response to the increase of cybercrime. Since then, banks have implemented most, if not all, of these guidelines, and cyber criminals have responded by challenging each layer of security, by exploiting different technologies or coming up with new hacking techniques.

The latest security recommendations strongly suggest a layered or “defense-in-depth” approach, which the National Security Agency defines as a practical strategy for achieving Information Assurance in today’s highly networked environments. It is a “best practices” strategy in that it relies on the intelligent application of techniques and technologies that exist today. The strategy strikes a balance between the protection capability and cost, performance, and operational considerations.

The FFIEC recommends that financial institutions replace simple device identification with complex device identification, which most banks had already implemented long ago. Therefore, the next evolution of security is device reputation management, incorporating geolocation, velocity, anomalies, proxy busting, browser language, associations, fraud histories, and time zone differences. iovation, an Oregon-based security firm, offers this service and more.

The FFIEC also recommends that financial institutions replace challenge questions, which are often fact-based questions, and can be easy to figure out with the use social networking data, with “Out of Wallet” (OOW) questions that don’t rely on publicly available information.

Challenge questions include, “What’s your mother’s maiden name?” “What’s your Social Security Number?” “What are your kids’ names?” or “When were you born?” OOW questions are generally opinion-based, such as, “What is your favorite vacation spot?” “What is your favorite flavor of ice cream?” or “What is your favorite book?”

Keir Breitenfeld, Senior Director of Experian Decision Analytics recently joined Device Reputation pioneer and leader, iovation, for a webinar presentation addressing the FFIEC guidelines. You can listen to his presentation on applying proportional treatment to risk-based authentication efforts and dynamically managing credit and non-credit data questions to mitigate fraud via the webinar.

Ultimately, financial institutions must implement a layered approach to security. iovation’s device reputation service is a must-have layer that contributes greatly to a defense-in-depth approach, assessing risk throughout multiple points on an institution’s website.

Robert Siciliano, personal security and identity theft expert contributor to iovation, discusses credit and debit card fraud on CNBC. Disclosures