Tag Archives: Fintech

TPRM Audit Fatigue: When Trust, Time, and Teams Collide

 

audit fatigue

Lately, I’ve been observing a growing trend where Financial Institutions (Banks and NBFCs) are increasingly mandating 3-day onsite audits as part of their Third-Party Risk Management (TPRM) programs. It often feels like an implicit signal that they don’t fully trust the fintechs or startups they work with, even those that proudly hold ISO 27001 or SOC-2 certifications. These certifications were meant to demonstrate a baseline of security maturity and due diligence, yet they’re being treated more like a footnote than a foundation.

Now, if you’re a fintech or startup working with even a moderate number of financial partners, say 8 to 10, your security and GRC teams could be spending upwards of 30 working days a year managing these TPRM audits. That’s nearly a month of valuable bandwidth lost to redundant assessments and fragmented processes.

To make matters even more tangled, there’s no standard playbook across auditors. Some send sprawling spreadsheets. Others insist on a live walkthrough with no prep and rapid-fire questions. Yet another expects you to navigate a third-party portal with its own quirks and terminology. Every new audit feels like starting from scratch.

Walkthrough-style audits, in particular, tend to be the most disruptive. They often require specific team members to join calls, explain configurations, demo access flows, or justify implementation choices. And since the questions tend to repeat across audits, these sessions end up being déjà vu for many teams, especially engineering. Their time is typically reserved for product building and problem-solving. Getting them to repeatedly field audit questions naturally creates friction between Engineering and Security, and sometimes even with the partner institutions.

On the flip side, the pressure within startups isn’t helping either. Many founders are pushing their teams: security, engineering, DevOps, legal, consultants—to rush through ISO or SOC-2 readiness on extremely tight deadlines. I’ve heard the same frustration echoed by several folks: long nights, tight audits, no breathing room. It’s become a checkbox race, not a maturity journey.

There’s also a growing school of thought within the industry that ISO/SOC-2 reports, especially the ones churned out by compliance automation platforms are becoming more of a sales enablement tool than a reliable indicator of security posture. That perception is driving financial institutions to dig even deeper during TPRM audits, essentially second-guessing the very frameworks designed to reduce the need for redundant assessments.

It’s tempting to wish for regulatory clarity here—perhaps a unified guidance from the regulator on how TPRM audits should be approached across the ecosystem. But that might be asking too much, given the operational nature of these audits and the regulator’s usual hands-off stance on implementation details.

To me, this is a multi-layered challenge. ISO and SOC-2 were designed to communicate security assurance to stakeholders for both internal teams and external partners. But if the output is no longer trusted, the entire premise starts to wobble.

As a small experiment, I once created a detailed Security Handbook for a client I consult for as a vCISO. It outlined their security practices end-to-end and drastically improved our turnaround time for security questionnaire responses. But unfortunately, the auditors weren’t too pleased—they preferred their own templates, their own questions, their own format. It didn’t matter that the answers were clear and well-structured. Standardization was nowhere in sight.

And let’s not ignore the irony where auditors are still asking for screenshots in an age where APIs could provide real-time evidence. It just feels out of sync with the pace and capabilities of modern tech. Honestly, this entire space is long overdue for disruption.

So the question is “how do we solve this?” What’s a practical, scalable way to balance assurance demands with the productivity of already stretched teams? How do we rebuild trust in certifications without burning out people in the process?

Would genuinely love to hear your thoughts.

How A Search For “Free Netflix Trial” Led Me To Uncover A Fintech Fraud

 

fintech compliance, RBI Notice #paytm #compliance #fintech

 

This article reminds me of an incident from my past life. I used to work for a Fintech company that was also into PrePaid Instrument wallets, powering one of the biggest utility service providers in India.

One day while doing an Attack Surface Management exercise, something strange happened. I noticed that our company name was quite popular on Youtube and associated hashtags were “free Netflix trial”, #freenetflix. This was around the time Netflix had entered India.

Attack Surface Management (ASM) is basically trying to find out all the references and entry points into an organisation’s servers / apps/ IPs on the web. This is done by doing deep searches using google dorks, dark web/deep web in both manual and automated ways. Nowadays, there are third-party companies that specialise in these.

Trivia: Interestingly, Cyber Insurance companies also use these ASM techniques to understand more about their clients digital footprint, exposure etc., and use it for calculating Cyber Insurance Premiums.

Curious, I dug deeper and found out a youtube video where an influencer had put up a tutorial on how one could easily create a virtual prepaid card in our platform, loading it for INR 2/- and then use that for Netflix trial for about a month and then recycle the whole process. I figured out that:

They were using the same Driving License (DL) numbers and sometimes recycling DL numbers by appending a digit. Since, in Minimum KYCs only numbers and some basic details like name and etc were collected, usually without any kind of photocopy of the documents. I believe this process has improved now (?).

I took those details and with the help of the internal teams, started researching more about those DL numbers. Turns out there were close to a few hundred accounts associated with that single number. Ideally, the systems should have flagged and blocked subsequent wallet creation using the same ID numbers. Somehow it was failing.

rbi non compliance

We looped in Compliance, FRM and legal. Such accounts with dubious credentials were invalidated and we started rolling out additional controls.

It was trivial to use the same numbers, unless there was a robust mechanism that checked the Document ID numbers and the associated identifiers like Mobile number, names etc.

Though I was in cybersecurity, this was my first brush with fighting digital fraud.

In another incident, fraudsters had cloned our fintech app and we had to loop in our legal teams to send a Trademark infringement to the AppStore to get this fake loan app removed.

In security we analyse the Tactics, Techniques and Procedures (TTPs) that are used commonly by the hackers. This helps us security teams in detecting and mitigating attacks by understanding the way threat actors operate.

Adapting a similar approach of examining the tactics, techniques, and procedures used by fraudsters will provide valuable insights into their behaviour and motives. With this understanding, the Fintechs and FIIs can help develop effective countermeasures. A good start would be documenting all the counter-fraud use-cases !

A key takeaway or a piece of advice to all the fintechs is to build a comprehensive list of use-cases proactively, and have them tested thoroughly. You can take help from your InfoSec teams in building these use-cases!

What do you say ?

#DigitalFraudPrevention #fintech #fintechfraud #search #attacksurface #TTPs #Tactics #Techniques #Procedures #usecase #ThreatActorAnalysis #frauddetection

Fighting Fraud Loan Apps with PKI

Fintech loan app scams

Rise of Fraudulent Loan Apps During Covid

In the aftermath of the Covid-19 pandemic from 2020 and its subsequent decline, there has been a notable surge in fraud cases, particularly revolving around counterfeit fintech apps offering loans. Individuals unsuspectingly downloading these deceptive loan apps are not only falling victim to steep interest rates but also compromising personal data such as photos and contacts. There have been following media reports where some have even committed suicide:

News report on Fake Loan Apps

This has escalated into a relentless cat-and-mouse game, with the odds heavily favouring fraudsters. I have closely followed some great work done by folks like Babu Lal in getting these fake loan apps removed from the playstores:

Babu Lal fighting against fake loan apps

Regulatory bodies are deflecting responsibility onto Play Stores, but I think that addressing this issue requires a collaborative effort between the Reserve Bank of India (RBI), Non-Banking Financial Corporations (NBFCs), and Play Stores operated by industry giants like Google and Apple.

Play Stores employ a gating check for allowing fintech apps, which involves verifying the NBFC certificate issued by the RBI. This certificate is essentially a copy of the physical document provided by the RBI to NBFCs/Banks/Financial Instituitions.

What has come to my attention, through both extensive reading of various reports and first-hand encounters with similar incidents, is that:

Fraudsters are Fabricating copies of the RBI-issued NBFC certificates.

These fabricated copies are then submitted to Play Stores along with the mobile app applications. It’s essential to note that sharing this NBFC certificate is mandatory for apps to be categorised as financial apps.

In the case we encountered, it took a significant amount of time to get the fake app removed from the playstore. This was an OEM playstore and not the regular Google or Apple owned.  The resolution ultimately necessitated pursuing the trademark infringement route.

The Solution:

One of the ways I thought this could be curbed or to an extent limited is by making use of Public Key Infrastructure (PKI) setup with Digitally Signed Certificates + Encryption and using the good old PGP/GPG tools. PGP stands for Pretty Good Privacy and originally developed by Phil Zimmermann in 1991 as a proprietary software. While GNU Privacy Guard (GPG) was developed as an open-source alternative to PGP. GPG is essentially PGP with an open-source licence.Yeah, it’s free and has no impact monetarily on the smaller banks and financial institutions for easy adoption. Only a small learning curve in the beginning on usage of GPG, but it’s better than losing money.

The goal is to establish a robust system that ensures the integrity of certificates and prevents the submission of falsified documents to Play Stores, thereby mitigating financial losses and data leaks.

Using PKI for leveraging a Web of Trust already in place

In the context of multiple stakeholders, this proposed solution aligns with the shared responsibility among Apple, Google, RBI, and NBFCs in addressing the rise of fraudulent fintech apps. Here’s a breakdown of the proposal:

1. Establish Dedicated Email Addresses and Publish Public Keys:

– All involved parties would create dedicated email addresses and publish their public keys into a Key Server. This ensures a secure and standardised communication channel.

2. RBI Digitally Signs Certificates for NBFCs:

– The RBI would be responsible for digitally signing certificates in the names of respective NBFCs, establishing a secure and verifiable authentication process.

3. Optional Encryption of Certificates for NBFCs:

– As an additional layer of security, the RBI could choose to encrypt these certificates with the respective NBFCs’ public keys while transmitting them, preventing potential Man-in-the-Middle (MITM) attacks. The reason to make this optional is, there are situations these certificates are attached when interacting with regulators.

4. NBFCs/Fintechs Decrypt and Use Certificates:

– NBFCs and Fintechs would then decrypt these certificates using their private keys and utilise them for their intended purposes.

5. NBFCs/Fintechs Sign and Encrypt Certificates for Playstores:

– NBFCs and Fintechs, having used the certificates, would digitally sign them and encrypt them with Google’s public keys as part of the Mobile App application form.

6. Playstore Teams Validate and Approve Apps:

– Playstore teams can efficiently validate these digitally signed and encrypted certificates, facilitating a streamlined approval process. Automation could be implemented given the inherent security of digital signatures.

7. Preventing Submission of Fake Documents:

– The proposed system effectively prevents the submission of fraudulent documents, such as copies of physical certificates, by ensuring the authenticity and integrity of digital certificates.

I couldn’t think of any loopholes except for the fact that commercial viability of PGP seems to have taken a severe beating. But there is good old GPG software to the rescue. While there has been similar implementation using Blockchain, the biggest hurdle I anticipate is the adoption with the NBFCs and other Financial Institutions that may not be tech-savvy.

The onus of keeping the RBI provided Certificates will be on the NBFCs and they can be revoked by RBI if in case they are leaked.

This is just a high level idea and can be further customised to handle the technical challenges and as reiterated earlier, this is a:

Shared Responsibility between the Regulator: RBI & Others, Playstore: Google, Apple & other Playstores, and NBFC/Fintechs/FIIs/Banks.

Opening this to scrutiny by peers. Please let me know what you think..

Reserve Bank of India (RBI) Google Apple

#fraudapps #fraudloanapps #loanappscams #loansharks #onlineloan #instantloan #loanpps #fintechfrauds