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The Risks of Open Banking

Fintechs and neobanks benefit greatly from the API ecosystem. But there are also open banking fraud risks involved. Let’s see how that may impact risk operations at your organization.

But first, let's look back at the historical development of Open Banking.

It spans several decades and here's a summarized timeline:

  1. Early Concepts (Pre-2000s): The idea of open banking, or the sharing of banking data and services through APIs, had early conceptual roots. However, the infrastructure and regulatory frameworks necessary for its implementation were not yet in place.

  2. Emergence of APIs (2000s): The proliferation of the internet and advancements in technology led to the development of Application Programming Interfaces (APIs). APIs allowed different software systems to communicate and interact with each other, laying the groundwork for open banking.

  3. Regulatory Initiatives (2010s): Regulatory bodies around the world began recognizing the potential of open banking to foster innovation, competition, and consumer empowerment in the financial sector. In the European Union, the Payment Services Directive 2 (PSD2) was a landmark regulation introduced in 2015, requiring banks to open up their data via APIs to third-party providers.

  4. Implementation and Adoption (Mid-2010s): In the mid-2010s, financial technology (fintech) startups and established financial institutions started leveraging open banking APIs to develop innovative products and services. This led to increased collaboration between traditional banks and fintech firms, as well as the emergence of new players in the financial ecosystem.

  5. Global Expansion (Late 2010s - Present): Open banking initiatives expanded beyond Europe to other regions, including the United States, Canada, Australia, and parts of Asia. Each region developed its own regulatory frameworks and standards for open banking, reflecting the unique characteristics of their financial systems and markets.

  6. Technological Advancements (Present): Recent years have seen rapid technological advancements in open banking, including the use of artificial intelligence, machine learning, blockchain, and cloud computing. These technologies are being integrated into open banking platforms to enhance security, efficiency, and user experience.

  7. Challenges and Opportunities (Present): While open banking presents opportunities for innovation and competition, it also poses challenges related to data privacy, security, interoperability, and regulatory compliance. Addressing these challenges will be crucial for the continued growth and success of open banking initiatives globally.

Overall, the historical development of open banking reflects a gradual evolution driven by technological innovation, regulatory changes, and shifting consumer expectations in the financial services industry.

Fintechs and neobanks derive substantial advantages from the API ecosystem. Nevertheless, they are also exposed to risks associated with open banking fraud. Let's explore how these risks could influence risk management operations within your organization.

open banking tresor

What Are the Applications of Open Banking?

Open banking aims to establish a connection between individuals' financial data and services provided by third-party entities. It serves as a remedy to the longstanding control banks have had over customer data. The EU, along with an expanding array of regulatory bodies, initiated open banking to enable a broader range of third-party financial firms to provide their services to bank customers.

The Payment Services Directive (PSD2) and General Data Protection Regulation (GDPR) are propelling Europe towards adopting an open banking framework. Similarly, the US, Latin America, and Asia are exploring their own variations of this concept. 

What Is Open Banking Fraud?

Fraud within open banking involves malicious actors exploiting financial products, services, and customer data. This type of fraud is escalating rapidly, mainly due to the introduction of new vulnerabilities between financial institutions and users. Fraudsters excel in leveraging emerging technologies, a category into which open banking falls.

The Risks of Open Banking Fraud

Regrettably, the risks associated with open banking can sometimes outweigh its benefits. Additionally, the technology can pose threats to organizations, influenced by various factors.

Increased ecosystem size correlates with higher levels of risk.

An open banking ecosystem may include various players such as data providers, third-party providers, customers, regulators, and government agencies. There are numerous potential points of failure for data security, and fraudsters excel at exploiting the weakest link in the chain.

Account Takeovers Bring Higher Rewards

As widely acknowledged, obtaining access to banking information is the ultimate goal for fraudsters. They possess expertise in thoroughly extracting personal information, currency, reward points, or cryptocurrency from every infiltrated account.

Within the realm of ATO (Account Takeover) fraud, the issue of linked accounts through open banking becomes apparent: the loss of control over one account could result in significant losses for customers. Their identification documents or card numbers might find their way onto the dark web, where they become fuel for synthetic identity fraud transactions.

As the saying goes: One Bad Apple Spoils the Bunch

When all these services are linked through a single technology like the API, you become reliant on the effectiveness of the initial KYC check. What occurs when fraudsters circumvent this check successfully? You're left with an infiltrator capable of opening neobank accounts, applying for loans, securing mortgages, and essentially deceiving every party involved.

The challenge is heightened particularly concerning AML compliance. If a money launderer gains access through the front door for one fraudulent transaction, who bears the responsibility according to government entities?

Compliance serves as a crucial defense against global money laundering and financial crimes. However, recent experiences highlight the significant burden placed on banks and financial institutions due to heightened compliance requirements. In 2020, global financial crime-related penalties surpassed $5.6 billion, with the figure nearing $9 billion by the third quarter, surpassing the previous high of $8 billion in 2019. The majority of these penalties, aside from cases of deliberate corruption, stem from non-compliance with global AML rules and standards.

What is AML in banking requirements?

Money Laundering

Money laundering, categorized as a financial offense, involves the process of disguising criminally obtained funds, known as "dirty money," by transferring it through financial services like banks to make it appear legitimate. As this illicit capital becomes part of the financial system, criminals can access it through legitimate accounts and employ it to fund various illegal activities such as drug trafficking, human trafficking, or terrorism.

In banking, Anti-Money Laundering (AML) refers to the set of policies and regulations established to prevent criminals from integrating unlawful funds into financial systems. Financial institutions undertake various activities to monitor and scrutinize suspicious transactions to comply with these regulations.


Single Point of Attack

Even with robust security measures in place at banks, what occurs when every interconnected service presents the same vulnerable point of entry?? Security and data protection hygiene are increasingly important in the API economy. Open banking fraud would give hackers and fraudsters a potentially higher reward.


Information and Security Asymmetry

Lastly, it's worth noting the potential for open banking APIs to instill a false sense of security. This phenomenon resembles a digital adaptation of the bystander effect, wherein organizations may be less inclined to validate data when it originates from a trusted source. Fraudsters could capitalize on this dynamic to their benefit. Once more, the weakest point in the open banking system's chain might be exploited with minimal personal information to satisfy a KYC check. Neglecting to reinforce verification measures could inadvertently provide criminals with a backdoor entry into your platform.



Consider the risks

Open banking, when implemented with appropriate security measures, can be secure. However, like any system that involves the sharing of sensitive data, there are inherent security risks that need to be addressed. Here are some considerations regarding the security of open banking:

Open Banking binary
  1. Data Encryption: Data exchanged through open banking APIs should be encrypted both in transit and at rest to prevent unauthorized access. Strong encryption algorithms and protocols should be used to protect sensitive information.

  2. Authentication and Authorization: Robust authentication mechanisms, such as OAuth 2.0, should be implemented to ensure that only authorized users and applications can access financial data. Multi-factor authentication adds an extra layer of security by requiring users to provide multiple forms of verification.

  3. Consent Management: Users should have full control over their data and be able to grant or revoke consent for data sharing with third-party applications. Consent should be obtained in a clear and transparent manner, and users should have the ability to monitor and manage their consent preferences easily.

  4. API Security: Open banking APIs should be designed with security in mind, incorporating measures such as input validation, output encoding, and access controls to prevent common attacks like injection, cross-site scripting (XSS), and cross-site request forgery (CSRF).

  5. Monitoring and Logging: Continuous monitoring of API traffic and logging of relevant activities are essential for detecting and responding to security incidents in a timely manner. Anomaly detection mechanisms can help identify suspicious behavior indicative of potential security breaches.

  6. Regulatory Compliance: Compliance with regulations such as PSD2 in Europe and local data protection laws is crucial for ensuring the security and privacy of financial data. Financial institutions and third-party providers must adhere to these regulations and implement necessary security measures to protect customer information.

  7. Vendor Security: When third-party providers are involved in open banking ecosystems, it's essential to assess their security posture and ensure that they adhere to industry best practices for security and data protection.

  8. Education and Awareness: Both users and developers should be educated about the security risks associated with open banking and how to mitigate them. Training programs, security guidelines, and awareness campaigns can help promote good security practices.

While open banking introduces new security challenges, with proper implementation of security controls and adherence to best practices, it can provide significant benefits while still maintaining the security and privacy of financial data.

VR Team is here to help you find the perfect fit for your specific needs. Book a call with us to find or fine-tune the payment solution for your marketplace or platform: or reach us @ email:



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