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Sahel Analyst: ISSN 1117-4668 Page 73
DETERMINANTS OF INTERNET BANKING FRAUD IN NIGERIA
Mr Imagbe, V. U.1
Mr Abilogun, T. O.2
Abstract
This study reviews the determinants of electronic banking fraud in
Nigeria. Primary data were used for the data, the population and sample size
of this study was gotten from all the quoted banks in Nigerian Stock Exchange
(NSE) as at 31st December, 2016. This study utilised ordinary least square
regression model. It was found out that the major and key determinants of
electronic banking fraud are security challenges, legal and regulatory
challenges and lack of continuous public education which had over the years
made the banking institutions and their customers vulnerable to different
forms of fraudulent attacks on internet. This indicates that a further increase
in these variables will increase banking institutions’ vulnerability to internet
banking fraud. The study recommended that the banking institutions should
strictly apply every legal and regulatory guideline, also to develop a know-
your-customer policy by vigilantly monitoring every e-banking transaction
strictly and continuous customers’ education on different security risk.
Keywords: E-banking, Security Challenges, Legal and Regulatory challenges,
Lack of Continuous Public education, Fraud.
Introduction
The quest for users and consumers to find it easy and convenient in
managing their accounts with the banks has given rise to internet banking
globally. The banking industry themselves enjoyed this so called internet
banking system because it has reduced some of their overhead costs such as
operational costs, staff training cost, the need for more skilful staffs,
investment in ATMs and some other branches. Electronic banking or online
banking as defined by Geethai and Malarvizhi (2010) is the delivery of both
modern and traditional banking products and services directly to users and
customers automatically through electronic and interactive communication
medium. This encompasses those systems that enables the banking customers,
governments, individuals, partnerships and businesses to transacts business, to
1 Bursary Department, University of Benin, Benin City, Nigeria 08060568819
[email protected] 2 Bursary Department, Rufus Giwa Polytechnic, Owo, Ondo State, Nigeria
08138152323 [email protected]
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access accounts, to get information on their services and products through the
use of public or private network while not necessarily getting down to the
nearest branch. Saudi Arabian Monetary Agency (2010) noted that Customers
access e-banking services using an intelligent electronic device, such as a
personal computer (PC), personal digital assistant (PDA), automated teller
machine (ATM), kiosk, or Touch Tone telephone. This internet banking has
the capability to transform the traditional business to a model of electronic
commerce (e-commerce) in providing banking alternatives and facilitating for
the convenience to their Internet banking customers (Steinfield, 2002).
Electronic banking are majorly associated with some basic services
which are: viewing of account balances and transaction histories; paying
several bills; transferring funds between accounts; requesting credit card
advances; loading of recharges cards; and ordering checks for more faster
services that can be provided by domestic and foreign bank. E-banking is
beneficiary to both the banks and its customers. Hamid (2007) viewed from
the bank’s perspectives that e-banking has enabled banks to lower operational
costs through the reduction of physical facilities and staffing resources
required, reduced waiting times in branches resulting in potential increase in
sales performance and a larger global reach. Jain, Hong and Pankanti (2000)
viewed from the customer’s perspective that e-banking allows customers to
perform a wide range of banking transactions electronically via the bank's
website at their own convenience. Customers no longer relied on the opening
hours of banks, the need to travel and the waiting times before they can access
information regarding banking services because they are now easily available
due to internet banking (Hutchinson & Warren, 2007).
The banking industry in an attempt to keep on with the new trend in
the evolutionary world brought about the challenged that arose due to new
technology and software systems to be put in place in order to make the
institution run smoothly and be more globally competitive (Stewart, 2000).
Panida and Sunsern (2011) noted that the more increase in the benefits derived
by the banking industry in adopting e-banking services as led to increase
security threat in terms of integrity, confidentiality and privacy, which is
capable of limiting the advancement of its progress. These security issues
seems to be something that cannot be really defined because fraudsters tends
to design new methods everyday order to overcome every security obstacles
but in place by the institution, but the most common among them are:
confidentiality of information exchanged, authentication of the relevant
instructions, integrity of the banking platform etc. A secure transaction must
have integrity i.e. not being altered while transmitting. Confidentially on the
other hand means that the content of the messages remain private as it move
from the customer though the internet to the bank. Without this, anyone can
view the transaction information and gain undue private information. Another
security factor is the authentication; authentication goes a long way with
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confidentiality because someone can be right sure that the person sending the
information is the person they say they are.
Other determinable factor of electronic banking fraud is the legal and
regulatory challenges. The absence of proper legal and regulatory law on
internet banking constitutes one of their major challenges in Nigeria. The
banking laws in existence do not address the security issues as it relates to e-
banking system in Nigeria. The increased and very high exposures of the e-
banking system to fraudsters, system hackers and other criminally minded
persons who could retrieve, access and utilised confidential information from
the systems majorly where there are weak measures to check mate the
unauthorised access. Other key determinable factor or area that has not being
explored or observed by various researchers is the area of continuous public
education. This paper tends to fill this gap by addressing this three key
determinants of electronic banking fraud which are the security challenge,
legal and regulatory challenges with continuous staff and customer’s
education.
Objectives of the Study
Given the scenario described above, the broad objective of this paper
is to investigate on the determinants of internet banking fraud in Nigeria.
Specific objectives are:
(i) to know the extent at which security challenges affects internet
banking fraud;
(ii) to examine the influence of legal and regulatory challenges on internet
banking fraud; and
(iii) to know how lack of continuous public education on various internet
fraudulent activities affect internet banking fraud.
Research Hypotheses
The hypotheses to be tested in this study are stated in null form as
follows:
(i) Security challenges does not have significant influence on internet
banking fraud
(ii) There is no relationship between legal and regulatory challenges and
internet banking fraud; and
(iii) Lack of continuous public education has no significant influence on
internet banking fraud.
Literature Review
Concept of Electronic Banking Fraud
Electronic banking has been around for quite some time in the form of
automatic teller machines (ATMs) and telephone transactions. In recent times,
it has facilitated banking transactions for both customers and banks, by using
Internet, and has enabled banks to scale borders, change their strategic tactics
and open new possibilities. Banking industries in countries all over the world
in this 21st century have transformed or changed to better operate in the new
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complex and competitive environment (the electronic environment or
electronic platform), in which the economic climate also has changed.
Information technology (IT) is the pivot of these major substantial changes.
With the new era of technological revolution, banking and financial industries
are now capable for offering financial services, through electronic media to
various customers, regardless of their place, time and distance (Tunmibi &
Falayi, 2013). In the 1990’s, the use of Internet evolved when more people
owned computers and became connected to the Internet through their dial-up
connection from anywhere in their homes. This technological evolution and
the spread of home Internet use allowed bank customers to enjoy 24/7 e-
banking services. But customers during the 1990’s didn’t fully trust e-banking
enough to make serious and substantial monetary transactions. This triggered
a massive effort and investment by banks to develop more security features
for their online banking services. Throughout the 2000’s, online banking
started to grow and become more acceptable by customers. It covered most of
banking services range (Shannak, 2013). There are many various types of
services that can be provided by e-banking.
The popular services include automated teller machines (ATMs),
credit cards, debit cards, smart cards, electronic fund transfer (EFT) systems,
mobile banking, etc. On the transaction level, e-banking include account
access, balance transfer, bill payment, bill presentment, mortgage lending,
customer service and administration, cross selling, etc. From the bank’s point
of view, the use of Internet has significantly reduced the physical costs of
banking operations, including the costs of information processing and
transmission. E-banking can be seen as the extension of existing physical
banks. It’s the use of computers to retrieve and process banking data, and to
initiate transactions directly and remotely with a bank via telecommunication
networks. It addresses several emerging trends such as customer demand for
anytime/anywhere service, product to market imperatives and increasingly
complex back-office integration challenges (Omariba, Masese & Wanyemi,
2012). Scholars classified e-banking under the domain of ecommerce, where
e-financing is the other major financial eservice provided. E-banking is more
devoted to Internet banking, telephone banking, and other banking channels
(Chavan, 2013). While e-banking is the commonly used term in literature, it is
used by people interchangeably with virtual banking, on-line banking, cyber-
banking, web banking, phone-banking and remote electronic banking
(Shannak, 2013).
Fraud on the other hand defined as” any behavior by which one person
intends to gain a dishonest advantage over another” (Chakrabarty, 2013).
Fraud is an act which intends to cause wrongful gain to one person and a loss
to the other, either by a way of concealment of facts or otherwise. Kovach and
Ruggiero (2011) concluded that a large number of different e-banking
accounts were accessed by a single fraudster, which included small value
transactions with a total value larger than a single account fraud are common
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based on the increased number of password failures that open doors for
fraudulent behaviours. Wei, Li, Cao, Ou, and Chen (2012) in their
investigation made in one of the largest banks in Australia as regard e-banking
fraud concludes that most of the banks has the following challenges: i) Highly
imbalanced large dataset: With large number of transactions usually millions
in e-banking system and very small number of daily frauds, the task of
detecting frauds becomes a tough challenge. ii) Real time detection: In some
online banking transactions, fraud detection needs to be in real time to prevent
instant money loss. iii) Dynamic fraud behaviour: fraudsters continually
advance their techniques to defeat online banking defenses. Defence against
an ever-growing set of attacks is beyond the capability of any single fraud
detection model. iv) Weak forensic evidence: Some external information
(forensic evidence) associated with each e-banking transaction is very useful
and needed to be known, to help understand the nature of deception of fraud
behaviour. v) Diverse behaviour patterns of customers. Customers of online
banking perform different kind of transactions in many ways and for several
purposes, this is a challenge as it leads to diversity of genuine customer
transactions that would be simulated by fraudsters who change their styles
frequently to compete with advances in fraud preventive and detective
measures, thus makes it difficult to characterise fraud behaviour from genuine
behaviour. These determinants are discussed under three sub-heads below:
Security Challenges and E-banking fraud
One of the major determinants of e-banking fraud is security
challenges, which are commonly referred to as Cybercrimes. This has been
the major concern of business executives in Nigeria and all over the world,
though banks have implemented some high technology security system for
online banking but yet have fallen victims of security breach.
The introduction of e-banking has come with its challenges, ranging
from e-banking adoption, to financial limitations of new system (Usman &
Shah, 2013). Research concluded to several factors that influence the adoption
process of e-banking like its usefulness and ease of use, system security, trust
and social influence, the user friendly features of system, accessibility, the
cost and time factors embedded in fund transfer (Abu-Shanab & Pearson,
2013). Security is a factor that is constantly highlighted as a critical success
factor (CSF) for the success of e-banking. The inadequacy of security will
potentially lead to financial losses, punitive measures by regulators and
negative media publicity. Security was rated in some research as the most
important issue of online banking services (Auta, 2010). Jassal and Sehgal
(2013) aimed to find various types of flaws in the security of online banking
that result in loss of money for account holders and financial institutions.
They explained the reasons behind security breaches, and the participation of
both customers and banks to enable hackers or crackers to access their
networks. Bank clients log on to bank websites daily, through a Web-browser
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installed on client’s personal computers, which open opportunities for
cybercrimes to take place.
The authors pointed to some flaws in security that could result in loss
of money, along with leakage of information to unauthorised persons. Flaws
could be on banking websites themselves, such as cross site scripting which
happens when an attacker injects malicious scripts into a web page, and
structured query language (SQL) injection vulnerability in which the hacker
enters SQL statements into a field on a web form, in an attempt to get to the
website to pass the command to the database (Jassal & Sehgal, 2013). Other
Flaws could be in banking security policies, that they publish online in order
to help users understand security measures that the bank follows, or could be
in users’ usability and customer awareness. It is important for clients to
educate themselves about risks involved in online banking. Nigudge and
Pathan (2014) stated the advantages and various popular services that could be
provided by e-banking, but they presented the challenges that e-banking faces.
One of these challenges is concerned with the security issues which can be
represented by the increased potential of fraud, weak security measures, and
the lack of strong trust environment. Generally, some security challenges
which can lead to fraud in e-banking are leakage of important information to
unauthorised persons, cross site scripting (injection of malicious script),
injection of structured query language by hackers and some careless banking
security policies.
Legal and Regulatory Challenges and E-Banking fraud
Lack of a proper legal and regulatory law for internet banking
constitutes one of the major challenges of e-banking in Nigeria. The banking
laws in existence do not address the security issues of e-banking as a new
banking system in Nigeria. The high exposure of the system to fraudsters,
hackers and other criminally minded persons who could access, retrieve and
utilise confidential information from the system where security measures are
weak to checkmate unauthorised intrusion is a major challenge to the
authorities (Singh & Malhorta, 2004).
Central Bank of Nigeria (2003) on the report technical committee on
electronic banking gave an all-encompassing legislation on internet/electronic
banking, which should be enacted to address issues inclusive of privacy,
encryption, digital signature, domain registration penal provisions and
issuance of guidelines on e-banking consumer protection. They amend
relevant provisions of the evidence act to admit computer generated document
as primary evidence, they also enacted an act of electronic funds transfer
(EFT) and that bill of exchange act be amended to accommodate cheque
truncation.
The Central Bank of Nigeria Guidelines on electronic banking in
Nigeria has given provisions to address issues relating to technology solutions
on E-banking to ensure that every bank meets the needs of consumers, the
economy and international best practice in the areas of communication,
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hardware, software and security, Internet banking, electronic payments
delivery channels and consumer rights protection. However, these guidelines
have not fully solved the problems; the recent loss of money recorded by the
Central Bank of Nigeria (CBN) has given a case study which shows that the
acclaimed tools and techniques currently used by Nigerian banking authorities
and banking institution are not sufficient (CBN guidelines on electronic
banking, 2013).
Lack of strict compliance with legislations or inadequate law or
regulation protecting the Consumer information from various online banking
risks represents another major challenge of the development of e-banking in
Nigeria. The risks include financial loss, malfunctioning of terminals or cards
as well as the possibility of unauthorised disclosure of information without the
consent of the consumer. The challenges here range from customer details
being stolen via fraudulent website to unauthorised withdrawal from account
via other means. Online breach of Internet banking has not been adequately
solved and the banks as well as the customers are susceptible to banking risk
(Sokolov, 2007).
Continuous Public Education and E-Banking Fraud
In this modern era, most customers rely heavily on the web for their
banking business, leading to an increase in the number of online transactions
(Berney, 2008). Fraudsters react to these changes as the internet provides
them with more opportunities to attack customers (Gates & Jacob, 2009).
Orad (2010) even claims that the internet allows criminals to organise as a
network, supporting each other in their attacks. Banks are expected to provide
sensitisation or educations to both their employee and customers on
continuous basis because fraudsters are very skilful and dynamic; they
improve on their unethical attitude every single minute and continuously
designing new means of defrauding the financial institutions. As this fact is
established, banks should be well positioned to provide basic electronic
banking fraud prevention education to both staff and customers. This can be
done by providing tips on their websites, through SMS, in fliers, radio and
television information, also displaying this tips in the poster pasted in the
banking hall wall, just to better communicate the concern people on how to
avoid becoming fraud victims. Even during regular meeting with their staff
and sometimes with customers they can also better discussed fraud mitigation
strategies. Lack of continuous public education would have greater effect on
e-banking fraud.
Theory of Fraud Triangle
This theory entails the triangle of different fraud aspects which
includes perceived pressure/motives, perceived opportunities and
rationalisation. The term perceived is important in the context because at
times pressure, opportunities and rationalisation may not be necessarily real
(Chiezey & Onu, 2013; and Ogechuckwu, 2013). Chiezey and Onu (2013)
observe that the first temptations to commit fraud are financial and non-
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financial pressure. Though financial pressure is the major pressure and as
argued by Ngalyuka (2013) that 95% of fraud committed are due to financial
pressure. This pressure can be inform of debts, underpayments, personal
family financial challenges of the employees and those that related to work in
terms of pressures to perform more than others (Ngalyuka, 2013).
The opportunity to commit fraud on the internet banking is determined
by the undue access of the fraudsters to some resources and basic information
which gives them an advantage to commit an unethical behaviour and conceal
it (Chiezey & Onu, 2013). Mahinda (2012) argue that these opportunities are
due to lack of control measures, weak control measures, lack of expectation
for punishments which can serve as deterrence, inadequate infrastructure and
inadequate public sensitisation.
The last factor in the fraud triangle is the perceived rationalisation.
Njenga and Oseimo (2013) observe that rationalisation which in other word
called justification of fraud aspect as acceptable by the fraudster.
Rationalisation is the justification of an unethical behaviour within an
organisation other than a criminal activity. Mahinda (2012) opined that
individual that can’t rationalise its unethical behavior might probably not
commit fraud. From the argument above, it is glaring that Security
Challenges, Legal and Regulatory challenges, Public education are great
potential for preventing opportunity and rationalisation of fraud which in turn
break the fraud triangle and determines e-banking fraud if not properly
explore.
Methodology
This study employed the use of primary data and questionnaire as a
tool for collecting data, the population of this study was made up of 15
commercial Banks listed on Nigerian stock exchange (NSE) as at December
2016, their Directors/Finance Managers, Branch Managers and Operations
Managers, Compliance officers, Head of different units and Customers service
officer were the respondents and some other staffs based on their experience
and knowledge of banking activities and some customers met at each branch.
A branch of each of the quoted banks was chosen at random to represent the
entire branch in Nigeria, ten respondents each were selected from each of the
quoted banks which makes it 150 respondents in total. This study uses simple
random sampling technique, which gives all the population equal chance of
been selected. The instrument was an 8 – term survey questionnaire with a – 4
Likert scale responses which are Strongly Agreed (SA), Agreed (A),
Disagreed (D) and Strongly Disagreed (SD).
Model specification
The dependent variable for the study is the Internet Banking Fraud
(IBF). The independent variables are Security Challenges (SC), Legal and
Regulatory Challenges (LRC) and Lack of Continuous Public Education
(LCPE). For empirical analysis purpose, the study used Regression Model
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with Ordinary Least Square (OLS) Technique to test the relationship between
the dependent and independent variables, in such a way that the results
obtained from the regression analysis are used to make decision in order to
reject or accept formulated hypothesis of the study.
The following models were specified in accordance with the objectives
and formulated hypothesis in other to guide and capture the effect of
independents variable on dependent variable on this study:
IBF = f (SC, LRC, LCPE) ………………………………………………… (i)
This is can be re-specified in a regression form thus:
BFPt = β0 + β1SCt + β2LRCt+ β3LCPEt + ut ……………………………… (ii)
Where:
IBF = Internet Banking Fraud
β0= Intercept/Constant, β1, β2, β3 are slope/coefficient,
SC = Security Challenges
LRC = Legal and Regulatory Challenges
LCPE = Lack of Continuous Public Education
u= Error term.
The Apriori signs are: β1, β2, β3,>0
Data Analysis and Interpretation of Results
Table 1: Descriptive Statistics
N Range Mean Std. Deviation Skewness
Kurtosis
IBF 150 3 2.46 1.024 0.115 -1.039
SC 150 3 2.56 1.012 0.082 -1.I20
LRC 150 3 2.49 1.034 0.124 -1.048
LCPE 150 3 2.54 1.046 0.130 -1.180
Valid N (list wise) 150
Source: Field Study, 2016
Descriptive Statistic (Table 1)
The descriptive statistics of the variables used in the analysis as
presented in Table 1 explains the range, mean, standard deviation and the
normality of variables, Banks fraud prevention is the main variable of interest,
which is the dependent variable. From the table internet banking fraud had a
mean value of 2.46 and the standard deviation is 1.024 which is a little close
to the mean, this shows a low degree of variability of data. Internet banking
fraud was positively skewed with a skewed value of 0.115 which shows it is
normally distributed. All the explanatory variables are positively skewed
which are Security Challenges (SC), Legal and Regulatory Challenges (LRC)
and Lack of Continuous Public Education (LCPE).
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Table 2: The Computation of (OLS) Result
Variables Coefficient Standard error. T-statistics Probability
Intercept 3.684 0.247 8.968 0.000
SC 2.275 0.120 3.865 0.016
LRC 1.352 0.257 3.876 0.003
LCPE 2.683 0.456 8.465 0.005
R2=0.782, R
2 bar=0.734, F-stat., (3,150)=34.572, Pro(F-stat.,)=0.000
D.W = 2.142
Source: Field Study 2016
OLS Analysis (Table 2)
IBF = 3.684 + 2.275 + 1.352 + 2.683 +U
S.E = (0.247) (0.120) (0.257) (0.456)
T-Stat = {8.968} {3.865} {3.876} {8.465}
The intercept value shows 3.684 which means Internet Banking Fraud
(IBF) has 3.684 units when other variables are held constant. Security
Challenges shows that 1unit increase in Security Challenges will bring 2.275
unit increases in Internet Banking Fraud and this is significant at 0.016 level
of significance which means it is less than 0.05 level of significance; therefore
this variable can significantly affect the Internet Banking Fraud. Legal and
Regulatory Challenges (LRC) shows that 1unit increase in it will bring 1.352
unit increases in the Internet Banking Fraud, it is also significant at 0.003
level of significance which means it is less than 0.05 level of significance,
therefore this variable can significantly affect Internet Banking Fraud.
Lack of Continuous Public Education (LCPE) shows that 1unit
increase in it will bring 2.683 unit increases in the Internet Banking Fraud, it
is also significant at 0.005 level of significance which means it is less than
0.05 level of significance, therefore this variable can significantly affect
Internet Banking Fraud.
The R-squared stand at 0.782 which shows the explanatory power of
the model which can be seen as 78.2%, means 78.2% of changes in Internet
Banking Fraud can be explained living 21.8% unaccounted for. The F –
statistic shows the robustness of the model by comparing F-calculated to F-
critical in order to explain the impact of whole explanatory variables on
explained variable, and this was shown by looking at it from the angle of 0.01
and 0.05 level of significance which are 3.78 and 2.60 and are less than
34.572 calculated respectively, in terms of overall significance all independent
variables showed a significant relationship with the dependent variable with
the prob. (F-statistic) of 0.000. The Durbin Watson value of 2.142 is an
indication of the absence of autocorrelation in the model.
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Discussion of Findings
Based on the OLS Table 2 above, the result shows about 78.2% of the
systematic variation in IBF is explained by three independent variables (SC,
LRC and LCPE). This coefficient is strong and shows a good fit of the
regression line as well as indicating the forecasting power of the model is
strong. The F value of 34.572 is statistically significant at 5%. This means that
SC, LRC and LCPE have significant positive relationship with IBF and this is
in compliance with the Apriori expectation. The results from the analyses
above are indications that the independent variables have a significant impact
on the Internet Banking Fraud.
In considering the variables individually, Security Challenges (SC)
showed both positive and significant relationship with banks Internet Banking
Fraud. This implies that security challenges have a greater effect on internet
banking fraud. This is in consistent with the findings of Tunmibi and Falayi
(2013) and Panida and Sunsern (2011). Legal and Regulatory Challenges
(LRC) showed both positive and significant relationship with Internet
Banking Fraud. This means inadequate laws and regulations on internet
banking will have a greater effect on Internet Banking Fraud. Chavan (2013)
also found a positive and statistically significant relationship in consistence
with this finding.
Lack of Continuous Public Education (LCPE) was also found to have
positive and significant relationship with Internet Banking Fraud. This implies
that, inconsistency in the education and sensitisation of the public towards
internet banking fraud will cause more damage by increasing internet banking
fraud. This is in consistent with the findings of Geetai and Malaryzhi (2010).
Conclusion
The exponential growth of Internet has offered tremendous market
potential for today’s businesses including e-banking industry. E-banking
revolution changed the business of banking fundamentally by providing many
benefits for customers and new business opportunities for banks. However, it
imposes traditional banking risks and many challenges especially in terms of
security and legal issues. Security aspects should be taken in consideration at
all levels of financial organisations, to protect themselves against various
types of fraud and attacks. There is no doubt that security issues in electronic
banking are key considerations in any meaningful discourse on the purport
and impact of electronic banking. The vulnerability of the e-banking platforms
to new and more sophisticated threats makes the situation even more
dangerous. Efforts are however being made continuously to ensure that the
various e-banking platforms are better secured from these threats.
From all the above, it can be concluded that there is not any single
strategy that covers all the different dangers threatening the e-Banking
platforms. On the contrary, focusing on a multi-layer protection approach is
the best alternative for system security and for protection of consumers’
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interests, including a mix of different factors that allow implementing
complementary protection for the end-user’s station; communicating the
occurrence of potential transactions frauds to the end-user; shielding the
authentication process from malicious activities that can affect the end user’s
station; providing user-to-site authentication strategies which allow the end-
user to verify that the connection is indeed established with the correct site.
Recommendations Electronic banking has a great potential of creating opportunities for
criminal activities and thereby facilitating fraudulent activities such as money
laundering. In that context, there should be a strict application every legal and
regulatory guideline developed at both national and international level,
development of “know-your-customer policies and vigilantly monitoring
every e-banking transaction strictly, taking a strategic and proactive approach
to information security and continuous customer education on different
security risk which will play an important role for consumer protection and
the same time limiting reputational risk.
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