PD Merchant Acquiring Services
PD Merchant Acquiring Services
Applicable to:
TABLE OF CONTENTS
PART A OVERVIEW
1. Introduction
1.1 Merchant acquiring services enable merchants to accept payment instruments for
the sale of goods or services to their customers. Acquirers provide the link
between the users of payment instruments to the merchants to enable the
purchase of goods or services. When users pay for the goods or services using
payment instruments, acquirers ensure that funds for such payment are settled in a
timely manner to the merchants.
1.2 In tandem with the rapid changes in the electronic payment (e-payment)
landscape, merchant acquiring services have experienced significant growth and
considerable change in their business arrangements and set-up. Merchants have
extended their acceptance of payment instruments from only payment cards to
other types of instruments such as electronic money (e-money). Merchant
acquiring services are no longer confined to the use of traditional Point-of-Sale
(POS) terminals but now extend to the use of new payment methods such as
Quick Response (QR) code and online banking. The acquiring arrangements have
also expanded to accept more electronic commerce (e-commerce) merchants and
involvement of third parties such as payment facilitators to facilitate expansion.
Merchant acquiring services have also adapted to constant evolution of
technological advancements to cater for needs of users and enhance efficiency. All
of the above changes have increased the complexity and the number of players
along the payment chain before payment reaches the merchants.
1.3 Due to the increasingly important role played by acquirers in the payment
landscape, it is important to specify the minimum expectations and regulatory
requirements for merchant acquiring services to promote confidence in the use of
e-payment by both merchants and users of payment instruments. The regulatory
requirements serve to ensure proper risk management in merchant acquiring
services, which includes the management of settlement risk, financial risk, fraud
risk and technology and cyber risk.
2. Applicability
2.2 The requirements under paragraph 9 of this policy document are only applicable to
non-bank acquirers.
3. Legal Provisions
3.1 The requirements in this policy document are specified pursuant to sections 18(2),
33(1), 49, 123(1) and 143 of the FSA.
3.2 The guidance in this policy document is issued pursuant to section 266 of the FSA.
4. Effective Date
(a) paragraphs 17.1 to 21.3 come into effect on 15 September 2022; and
(b) paragraphs 9.1 to 9.3 come into effect on 15 September 2023.
5. Interpretation
5.1 The terms and expressions used in this policy document shall have the same
meanings assigned to them in the FSA unless otherwise defined in this policy
document.
“acquirer” refers to any person who is registered 1 pursuant to sections 17(1) and
18 of the FSA to provide merchant acquiring services and fulfils the criteria under
paragraph 2.1;
“critical system” refers to any application system that supports the provision of
critical services, where failure of the system has the potential to significantly impair
the acquirer’s provision of services to customers or counterparties, business
operations, financial position, reputation or compliance with applicable laws and
regulatory requirements;
1
For avoidance of doubt, an e-money issuer that also conducts its own merchant acquiring services (i.e.
acquires merchants directly) for its own e-money scheme is also considered as an acquirer.
2
A licensed bank, licensed Islamic bank or prescribed institution appointed or identified to conduct direct
settlement to merchants.
“licensed Islamic bank” means an Islamic bank licensed under the IFSA;
“non-bank acquirer” refers to any person who is not a licensed bank, licensed
Islamic bank or prescribed institution that is registered pursuant to sections 17(1)
and 18 of the FSA to provide merchant acquiring services and fulfils the criteria
under paragraph 2.1;
3
For avoidance of doubt, an arrangement which is time-bound does not preclude that activity from being
considered as being performed on a continuing basis.
“production data centre” refers to any facility which hosts active critical
production application systems irrespective of location;
“third party service provider” as used in Part D of this policy document refers to
an internal group affiliate or external entity providing technology-related functions
or services that involve the transmission, processing, storage or handling of
confidential information pertaining to the acquirer or its customers. This includes
cloud computing software, platform and infrastructure service providers.
6.1 This policy document must be read together with other relevant legal instruments
and policy documents that have been issued by the Bank, in particular –
(a) the policy document on the Risk-Based Authentication for Online Payment
Card Transaction;
(b) the policy document on the Payment Card Reform Framework;
(c) the policy document on the Management of Customer Information and
Permitted Disclosures; and
(d) the policy document on Interoperable Credit Transfer Framework.
4
Issued on 27 December 2017.
PART B GOVERNANCE
S 8.1 Acquirers shall establish adequate governance arrangements which are effective
and transparent to ensure the continued integrity of its merchant acquiring services
which include, among others, the following –
(a) a board of directors (board) and senior management that consists of people
with calibre, credibility and integrity;
(b) clearly defined and documented organisational arrangements, such as
ownership and management structure; and
(c) segregation of duties and internal control arrangements to reduce the
chances of mismanagement and fraud.
S 8.3 The board shall have the overall responsibility in ensuring the sustainable growth,
financial soundness and reliability of the acquirer’s merchant acquiring services
which include –
(a) determining, reviewing and approving strategies, business plans and
significant policies, including its risk appetite and monitoring management’s
performance in implementing them;
(b) setting corporate values and clear lines of responsibility and accountability
that are communicated throughout the organisation;
(c) ensuring adequate assessment is conducted on key responsible persons
(KRP);
(d) ensuring selection of competent senior management;
(e) ensuring that the operations of the business are conducted prudently, and
within the framework of relevant laws and policies;
S 8.4 The board shall ensure that an effective oversight and risk management mechanism
is in place, which includes the following –
(a) an effective oversight and governance structure to manage the day-to-day
operations of the acquirer;
(b) risk management and control framework on the following areas –
(i) technology risk management and cyber resilience;
(ii) mitigation of fund settlement risk to merchants;
(iii) mitigation of fraud or illegal activities;
(iv) merchant recruitment and monitoring;
(v) outsourcing arrangement with service providers; and
(c) appropriate and timely reporting or escalation of issues that may impact the
safety, security or operational reliability of the merchant acquiring operations.
S 8.5 The board shall ensure that the risk management and control framework is
periodically reviewed for continued effectiveness. This includes ensuring an audit by
an independent party is conducted with reasonable frequency to detect weaknesses
and enable corrective measures to be taken in a timely manner.
S 8.6 The board and its committees (if any) shall be of a size that promotes effective
deliberation and encourages the active participation of all directors. The board shall
meet sufficiently whereby the number and frequency of board meetings shall
commensurate with the size and complexity of the acquirer’s operations, to review
the acquirer’s performance, including the status of its compliance with regulatory
requirements and to deal with any issues pertaining to the operations of merchant
acquiring services.
S 8.7 The board shall ensure that clear and accurate minutes of board meetings are
maintained to record the decisions of the board, including the key deliberations,
rationale for each decision made, and any significant concerns or dissenting views.
S 8.8 With regard to the management of technology and cybersecurity risks, the board
shall –
(a) establish and approve the technology risk appetite which is aligned with the
acquirer’s risk appetite statement. In doing so, the board shall approve the
corresponding risk tolerances for technology-related events and ensure key
performance indicators are in place to monitor the acquirer’s technology risk
against its approved risk tolerance. The board shall ensure the senior
management of the acquirer provides regular updates on the status of these
indicators, key technology risks and critical technology operations to facilitate
strategic decision-making; and
(b) ensure and oversee the adequacy of the acquirer’s IT and cybersecurity
strategic plans covering a period of no less than three (3) years. These plans
shall address the acquirer’s requirements on infrastructure, control measures
to mitigate IT and cyber risk as well as financial and non-financial resources,
which are commensurate with the complexity of the acquirer’s operations and
changes in the risk profile as well as the business environment. These plans
shall be periodically reviewed, at least once every three (3) years.
G 8.9 Given the rapidly evolving cyber threat landscape, the board should allocate
sufficient time to discuss cyber risks and related issues, including the strategic and
reputational risks associated with a cyber-incident. This should be supported by
input from external experts as appropriate. The board should also ensure its
continuous engagement in cybersecurity preparedness, education and training.
S 8.10 The board shall be responsible for ensuring the effectiveness of the audit function
including technology audit. The board shall review and ensure the appropriate audit
scope, procedures and frequency of audits. The board shall also ensure effective
oversight over the prompt closure of corrective actions to address any issues or
control gaps.
Senior Management
S 8.11 The senior management of acquirers shall be responsible for ensuring the following
–
(a) effective policies and procedures are established and implemented for,
among others, the following areas –
(i) risk management and appropriate controls to manage and monitor
risks, including those under paragraph 8.4(b);
(ii) due diligence and oversight to manage outsourced arrangements
supporting the merchant acquiring operations;
(iii) sufficient and timely reporting or escalation of issues to the board;
(b) overseeing the formulation and effective implementation of any business or
strategic plan, including the strategic technology plan and associated
technology policies and procedures; and
(c) a robust assessment is conducted to approve any deviation from policies and
procedures, including technology-related policies. Material deviations shall be
reported to the board.
S 8.12 The senior management shall consist of individuals with the appropriate skill set
and experience to adequately support the merchant acquiring services. This
includes individuals from technology functions to provide guidance on the
acquirers’ technology plans and operations.
S 8.13 The senior management shall ensure adequate allocation of resources as well as
appropriately skilled and competent staff to support all critical functions of the
merchant acquiring services, including to ensure maintenance of robust technology
systems and management of technology risk.
G 8.14 For large acquirers, the senior management should embed appropriate oversight
arrangements within the technology function to support the enterprise-wide
S 9.1 Small non-bank acquirers are required to maintain, at all times, minimum capital
funds of RM300,000.
S 9.2 Large non-bank acquirers are required to maintain, at all times, minimum capital
funds of RM1,000,000.
S 9.3 Non-bank acquirers shall maintain the required minimum capital funds in
accordance with the computation specified in Appendix 1.
S 10.1 Acquirers shall be responsible to process the payment of funds to its merchants in
a proper and timely manner to manage settlement risk. For the purpose of this
paragraph, settlement risk is described as the risk of acquirers’ inability to honour
the obligation to transfer funds arising from a transaction as a result of clearing, at
an agreed-upon time to the merchants.
S 10.2 Acquirers shall ensure timely and complete funds settlement to merchants as per
the terms agreed in the contractual agreement with merchants.
S 10.3 Acquirers shall ensure that the settlement period commensurate with the
merchants’ business models and needs.
G 10.4 Acquirers should ensure that the settlement period is no longer than two (2) and
five (5) working days from the date of funds received from the payment instrument
S 10.5 Acquirers shall deposit the funds received for settlement to merchants in a
dedicated deposit account (i.e. designated account) with licensed banks, licensed
Islamic banks or prescribed institutions, separately from their own funds. The funds
in the dedicated deposit account shall only be used for settlement purposes to the
merchants and/or chargebacks to issuers of payment instruments less the
Merchant Discount Rate (MDR) charged or any other applicable charges to the
merchant.
S 10.6 In the event settlement by acquirers to SME merchants takes more than two (2)
working days from the date of funds received from the payment instrument
network, the acquirer shall ensure the funds are safeguarded as follows –
(a) place the settlement funds in a trust account with a licensed bank, licensed
Islamic bank or prescribed institution in accordance with the Trustee Act
1949; or
(b) adopt direct settlement method to merchants; or
(c) secure a bank guarantee from a licensed bank, licensed Islamic bank or
prescribed institution on such settlement funds or outstanding amount for
settlement.
S 10.7 Acquirers shall be liable to provide the funds settlement to merchants in the event
the issuer, including foreign issuers of payment instruments, or any other parties
involved in the handling of such funds, fail to fulfil its settlement obligations.
Merchant recruitment
S 11.1 Acquirers shall establish prudent underwriting criteria and procedures to ensure
proper due-diligence for on-boarding of a merchant. The assessment criteria shall
include the following –
(a) relevant background information on the merchant (e.g. financial history such
as bankruptcy/insolvency check, nature of business, etc.);
(b) legitimacy of the merchant’s business, with no involvement in or association
with any fraudulent or illegal activities including business activities intended
to deceive consumers such as “scratch and win” and “get-rich-quick”
schemes; and
(c) the merchant has not been blacklisted by any authorities or other acquirers
for any suspected fraudulent or illegal activities.
S 11.2 Acquirers shall verify the merchants’ identity using reliable documents, information
or any other measures that acquirers deem appropriate, taking into consideration
the nature and size of the business of the respective merchants, before
establishing any acquiring relationship with the merchants.
S 11.4 Merchants shall not be on-boarded via a merchant recruitment agent 5 unless
approved by the acquirer. Acquirers shall retain the responsibility to ensure proper
5
The merchant recruitment agent’s roles are limited to the referral of merchants, collection of merchants’
information and documents for application purposes and submission to acquirers for approval. The
activities do not involve processing of funds or facilitating the transactions.
Merchant monitoring
S 11.5 Acquirers shall conduct effective monitoring on their merchants’ activities to ensure
that the merchants are not involved in any fraudulent or illegal activities.
S 11.6 Acquirers shall maintain a “watch list” of merchants that are suspected to be
collusive or involved in fraudulent or illegal activities, and the activities of these
merchants shall be closely monitored and investigated.
S 11.7 Acquirers shall monitor chargebacks and its trend, including the merchants’
capacity to repay these chargebacks and act accordingly (e.g. close monitoring,
termination of merchant, if necessary) to mitigate any risks associated with
engaging such merchants.
S 11.8 Acquirers shall terminate immediately any acquiring relationship with a merchant
that has been charged or convicted of a criminal offence relating to fraudulent or
illegal activity.
G 11.9 Acquirers shall conduct periodic assessment, which may include mystery shopping
or audit on their merchants, to ensure that the merchants adhere to payment
instruments’ acceptance and authorisation procedures.
6
Controls include process and procedures as well as IT security controls that are commonly accepted as
effective by industry practice.
includes any third party service providers engaged by the merchants for accessing,
storing, transmitting and processing customer data.
S 11.11 The acquirers’ agreements with merchants shall include provisions to ensure the
merchants and merchants’ third party service providers maintain compliance with
applicable security requirements and established security standards.
S 11.12 Acquirers shall educate 7 and raise awareness among their merchants on the
importance of protection of customer data and the legal consequences 8 of failing to
adequately protect such data.
S 12.1 Acquirers shall put in place an effective mechanism, which includes the process
and procedures to mitigate fraud risk, which includes fraud prevention, detection
and monitoring.
7
By providing appropriate level of awareness through various measures such as training, constant
reminders or engagement sessions.
8
Such as non-compliance with the Personal Data Protection Act 2010.
(e) reporting to the Bank shall be made in a timely manner if the impact is
significant and in accordance with the fraud reporting requirement as issued
by the Bank.
S 13.1 Acquirers shall ensure that they have adequate resources and capacity in terms of
hardware, software and other operating capabilities 9 to deliver consistently reliable
and secure services.
S 13.2 Acquirers shall ensure that measures are in place to support operational reliability,
which include –
(a) strong internal controls to minimise operational risk such as system security
risk;
(b) comprehensive and well-documented operational and technical procedures;
and
(c) systems with a robust disaster recovery plan, including a highly reliable
backup system.
S 13.4 Acquirers shall develop an effective business continuity plan (BCP) and disaster
recovery plan (DRP) for at least all critical business functions and other functions,
where applicable.
G 13.5 For purposes of paragraph 13.3, acquirers are expected to carry out a business
impact analysis (BIA) on an annual basis, which forms the foundation of
9
This may refer to any other skills or processes involved in the operations (e.g. adequate manpower and
skill set to operate the systems).
developing the BCP and as and when there are material changes to the acquirers’
business activities.
G 13.6 Acquirers should determine the maximum tolerable downtime (MTD) and recovery
time objectives (RTO) for each critical business function. The goal is to develop a
BCP that details out the procedures and the minimum level of resources required
to recover the critical business functions within the recovery timeframe and
maintain services at an acceptable level.
S 13.8 Acquirers shall test the BCP and DRP regularly to ensure the functionality and
effectiveness of the recovery strategies and procedures, preparedness of staff and
other recovery resources.
14. Outsourcing
S 14.1 Acquirers shall remain responsible and accountable for the services outsourced to
any service provider 10 (e.g. payment facilitators, merchant recruitment agents,
payment gateway service providers, IT service providers) under an outsourcing
arrangement 11.
S 14.2 Prior to entering into any outsourcing arrangement, acquirers shall, at minimum,
ensure the following –
(a) availability of sufficient expertise within the acquirer to oversee and manage
the outsourcing relationship;
10
Including affiliates of the acquirer, regardless of jurisdiction.
11
For avoidance of doubt, an arrangement will be deemed as an outsourcing arrangement as long as the
activities fulfil the “outsourcing arrangement” definition specified under paragraph 5.2 of this policy
document.
(b) the scope and nature of services and operations to be outsourced would not
compromise the controls and risk management of the merchant acquiring
services. Acquirers shall ensure the following –
(i) the outsourcing of such processes does not take away the critical
decision making function of the acquirers;
(ii) the outsourcing of such processes does not threaten strategic
arrangements, flexibility needed by acquirers on important areas and
control of the acquirers;
(iii) the outsourcing of such processes would not impair the reputation,
integrity and credibility of the acquirers; and
(iv) processes are in place for the acquirers to retain the ability to comply
with the regulatory and supervisory requirements on the outsourced
functions.
S 14.3 Acquirers shall perform appropriate due diligence of the service provider before the
outsourcing arrangements are formalised, which includes the following areas –
(a) capacity, capability, financial strength and business reputation 12;
(b) risk management and internal control capabilities, including physical and IT
security controls as well as business continuity management 13;
(c) measures and procedures to ensure data protection and confidentiality;
(d) reliance of service providers on sub-contractors; and
(e) ability of the service provider to comply with relevant laws, regulations and
requirements in this policy document.
G 14.4 Acquirers should also assess the extent of concentration risk to which the acquirer
is exposed with respect to a single service provider and the mitigation measures to
address this concentration, except when the service provider is an affiliate and is
supervised by a financial regulatory authority.
12
This includes an assessment that the service provider is a going concern and has strong governance
structures to manage the outsourced activity throughout the duration of the arrangement.
13
Including the ability of the service provider to respond to service disruptions or problems resulting from
natural disasters, or physical or cyber-attacks, within an appropriate timeframe.
S 14.5 Approval from the board to outsource identified functions shall be obtained and
documented, substantiated by outcomes of the due diligence process conducted
on the service provider.
SS 14.6 Acquirers shall ensure that the outsourcing arrangement is governed by a written
agreement, which shall be comprehensive, legally enforceable and shall include
the minimum requirements specified in Appendix 2.
S 14.8 Acquirers shall ensure that appropriate controls are in place and are effective in
safeguarding the security, confidentiality and integrity of any information shared
with the service provider. In meeting this requirement, acquirers shall ensure the
following –
(a) information disclosed to the service provider is limited to the extent
necessary to provide the contracted service, and only on a need-to-know
basis;
(b) all locations (e.g. city and country) where information is processed or stored,
including back-up locations, are made known to the acquirer;
(c) where the service provider is located, or performs the outsourced activity,
outside Malaysia, the service provider is subject to data protection
standards that are comparable to Malaysia;
S 14.10 Acquirers shall ensure their service provider complies with the relevant regulatory
requirements specified in this policy document 15 and as may be specified by the
Bank from time to time.
S 14.11 The requirement in paragraph 14.10 is also applicable when a service provider
engages a sub-contractor to undertake the activities that were outsourced by the
acquirer, whereby the acquirer shall implement proper controls to ensure that the
sub-contractor complies with the relevant requirements based on standards issued
by the Bank to acquirers from time to time.
14
Any relevant local or international standards commonly applied by the relevant industry.
15
This includes specific requirements for system development and acquisition, data centre operations,
network resilience, technology security and cybersecurity, wherever applicable.
S 14.13 Notwithstanding that the operational activities are outsourced, reporting by the
service provider to the acquirer and monitoring mechanisms on the service
provider shall be put in place by the acquirer to ensure that the integrity and quality
of work conducted by the service provider is maintained. Regular reviews shall also
be conducted by the acquirer to monitor the performance of the service provider.
S 14.14 Periodic independent reviews either via internal and/or external audits, shall be
conducted on the outsourced operations, with the same scope of review if the said
operations are conducted in-house.
S 14.15 Acquirers shall ensure that any weaknesses highlighted during the audit pursuant
to paragraph 14.14 are well-documented and promptly rectified by the service
provider especially where such weaknesses may affect the integrity of the internal
controls of the acquirers.
G 14.16 For outsourcing arrangements where the service provider is located or the services
are performed outside Malaysia, the acquirer should have appropriate controls and
safeguards in place to manage any additional risk, with regard to various
conditions, including legal and regulatory requirements as well as social and
political conditions.
S 14.17 Acquirers shall ensure that the outsourcing arrangements undertaken outside
Malaysia are conducted in a manner which does not affect –
(a) the acquirer’s ability to effectively monitor the service provider and execute
its BCP;
(b) the acquirer’s prompt recovery of data in the event of the service provider’s
failure, having regard to the laws of the particular jurisdiction; and
(c) the Bank’s ability to exercise its regulatory or supervisory powers, in
particular the Bank’s timely and unrestricted access to systems, information
or documents relating to the outsourced activity.
S 14.18 For outsourcing involving cloud services, acquirers may rely on third party
certification and reports made available by the cloud service provider for purposes
of conducting audits and inspections on the cloud service provider and sub-
contractors. However, such reliance by the acquirer shall be supported by an
adequate understanding and review of the scope of the audit and methods
employed by the third party, and access to the third party and service provider to
clarify matters relating to the audit.
S 15.1 Acquirers are responsible for ensuring that the parties that they enter into a
contract with, who may also expose merchants to payment and/or settlement risk,
are able to manage such risks appropriately. Such parties include payment
facilitators.
S 15.2 In addition to the requirements in paragraph 14, acquirers are required to ensure
such parties in paragraph 15.1 have adequate operational and risk management
policies and procedures in place, which include the following –
(a) the parties conduct sound assessment and due-diligence on their
merchants to ensure that the merchants are conducting a legitimate
business and not involved in fraudulent or illegal activities;
(b) the parties have safeguard measures to ensure timely and complete funds
settlement to the merchants (e.g. placing funds in a designated account
with licensed banks, licensed Islamic banks or prescribed institutions only
for settlement purposes and are transparent in their settlement terms and
period to their merchants);
(c) the parties as well as their merchants are able to ensure confidentiality,
security and integrity of customer data at all times;
(d) the parties are able to ensure the safety, reliability and availability of their
system and network infrastructure; and
(e) the parties have appropriate dispute resolution mechanisms for the
merchants.
S 15.3 Acquirers shall be held responsible for fulfilling the settlement obligation to the
merchants of a payment facilitator, in the event that the payment facilitator fails to
fulfil its settlement obligations to the merchants.
S 15.4 Notwithstanding paragraph 14.11, acquirers shall ensure that a payment facilitator
does not appoint another payment facilitator for purposes of acquiring a merchant.
S 15.5 Acquirers shall periodically monitor the transactions or activities of the parties
mentioned in paragraph 15.1 (e.g. through transaction monitoring, site visits at the
business premises or audit assessment) to ensure that appropriate controls and
risk mitigation measures are put in place by such parties in managing the payment
and/or settlement risk and any issues or weaknesses detected are promptly
rectified.
S 16.1 Acquirers shall establish appropriate rules and procedures on liability management
and chargeback, which shall be clearly specified in the merchant agreements.
Acquirers shall ensure that merchants are not held liable for any fraud losses or
chargeback if the transactions acceptance procedures as stipulated in the
merchant agreement have been adhered to by the merchants.
S 16.2 In the event funds are withheld from the merchants, the acquirers are responsible
for ensuring that the withholding of such funds due to their merchants (e.g. for
suspected fraudulent transactions or to facilitate chargeback requests from the
issuer) is done in a fair manner and not detrimental to the merchants. This shall
include but is not limited to the following –
(a) provide clarity in the circumstances for withholding of funds due to the
merchants (e.g. fraudulent transactions);
(b) provide clarity and identify the definite period for withholding of funds due
to the merchants (e.g. within chargeback period of one hundred and
twenty (120) days);
S 16.3 Acquirers shall establish clear and robust dispute resolution procedures to ensure
effective and timely resolution of dispute cases between acquirers and their
merchants.
S 16.4 Acquirers shall acknowledge receipt of the dispute within two (2) working days from
the date such dispute is lodged and provide a written decision to merchants within
thirty (30) working days. Acquirers shall inform the merchants if a longer time is
required to address the dispute and provide appropriate rationale.
S 17.1 Acquirers shall establish the Technology Risk Management Framework (TRMF),
which is a framework to safeguard the acquirers’ information infrastructure,
systems and data as an integral part of the acquirers’ risk management framework.
G 17.5 The CISO should be responsible for ensuring the acquirers’ information assets and
technologies are adequately protected, which include —
(a) formulating appropriate policies for the effective implementation of TRMF
and CRF;
(b) enforcing compliance with these policies, frameworks and other technology-
related regulatory requirements; and
16
Relevant third party assessment may include the Data Centre Risk Assessment (DCRA), Network
Resilience and Risk Assessment (NRA) and independent assurance for introduction of new or enhanced
digital services.
17
Acquirers’ CISO may take guidance from the expertise of a group-level CISO, in or outside of Malaysia,
and may also hold other roles and responsibilities. Such designated CISO should be accountable for and
serve as the point of contact with the Bank on the acquirers’ technology-related matters, including
managing entity-specific risks, supporting prompt incident response and reporting to the acquirers’ board.
G 18.2 The risk assessment should identify and address the key risks arising from the
implementation of technology projects. These include the risks that could threaten
successful project implementation and the risks that a project failure will lead to a
broader impact on the acquirers’ operational capabilities. At a minimum, due regard
should be given to the following areas –
(a) the adequacy and competency of resources including those of the vendor to
effectively implement the project. This should also take into consideration the
number, size and duration of significant technology projects undertaken
concurrently by the acquirers;
(b) the complexity of systems to be implemented such as the use of unproven or
unfamiliar technology and the corresponding risks of integrating the new
technology into existing systems, managing multiple vendor-proprietary
technologies, large-scale data migration or cleansing efforts and extensive
system customisation;
(c) the adequacy and configuration of security controls throughout the project life
cycle to mitigate cybersecurity breaches or exposure of confidential data;
(d) the comprehensiveness of the user requirement specifications to mitigate risks
18
For example, large-scale integration projects or those involving IT systems should be subject to more
stringent project governance requirements such as more frequent reporting to the board and senior
management, more experienced project managers and sponsors, more frequent milestone reviews and
independent quality assurance at major project approval stages.
G 18.3 The board and senior management should receive and review timely reports on the
management of these risks on an ongoing basis throughout the implementation of
significant projects.
S 18.5 Acquirers shall establish clear risk management policies and practices for the key
phases of the system development life cycle (SDLC) encompassing system
design, development, testing, deployment, change management, maintenance and
decommissioning. Such policies and practices shall also embed security and
relevant enterprise architecture considerations into the SDLC to ensure
confidentiality, integrity and availability of data 19. The policies and practices shall
be reviewed at least once every three (3) years to ensure that they remain relevant
to the acquirers’ environment.
19
The security considerations shall include ensuring appropriate segregation of duties throughout the SDLC.
G 18.6 Acquirers are encouraged to deploy automated tools for software development,
testing, software deployment, change management, code scanning and software
version control to support more secure systems development.
G 18.7 Acquirers should consider the need for diversity 20 in technology to enhance
resilience by ensuring critical systems infrastructure are not excessively exposed
to similar technology risks.
S 18.8 Acquirers shall establish a sound methodology for rigorous system testing prior to
deployment. The testing shall ensure that the system meets user requirements and
performs robustly. Where sensitive test data is used, acquirers shall ensure proper
authorisation procedures and adequate measures to prevent their unauthorised
disclosure are in place.
G 18.9 The scope of system testing referred to in paragraph 18.8 should include unit
testing, integration testing, user acceptance testing, application security testing,
stress and regression testing, and exception and negative testing, where
applicable.
S 18.10 Acquirers shall ensure any changes to the source code of critical systems are
subject to adequate source code reviews to ensure the code is secure and was
developed in line with recognised coding practices prior to introducing any system
changes.
S 18.11 In relation to IT systems that are developed and maintained by vendors, acquirers
shall ensure the source code continues to be readily accessible and secured from
unauthorised access.
S 18.12 Acquirers shall physically segregate the production environment from the
development and testing environment for critical systems. Where acquirers are
20
Diversity in technology may include the use of different technology architecture designs and applications,
technology platforms and network infrastructure.
relying on a cloud environment, the acquirers shall ensure that these environments
are not running on the same virtual host.
S 18.14 Where acquirers’ IT systems are managed by third party service providers, the
acquirers shall ensure, including through contractual obligations, that the third
party service providers provide sufficient notice to the acquirers before any
changes are undertaken that may impact the IT systems.
G 18.15 When decommissioning systems, acquirers should ensure minimal adverse impact
on merchants and business operations. This includes establishing and testing
contingency plans in the event of unsuccessful system decommissioning.
Cryptography
G 18.16 Acquirers should promote the adoption of strong cryptographic controls for
protection of important data and information which include –
(a) the adoption of industry standards for encryption algorithms, message
authentication, hash functions, digital signatures and random number
generation;
(b) the adoption of robust and secure processes in managing cryptographic key
lifecycles which include generation, distribution, renewal, usage, storage,
recovery, revocation and destruction;
(c) the periodic review, at least every three (3) years, of existing cryptographic
standards and algorithms in IT systems, external linked or customer-facing
applications to prevent exploitation of weakened algorithms or protocols; and
(d) the development and testing of compromise-recovery plans in the event of a
cryptographic key compromise. This should set out the escalation process,
G 18.17 Acquirers should conduct due diligence and evaluate the cryptographic controls
associated with the technology used in order to protect the confidentiality, integrity,
authentication, authorisation and non-repudiation of information. Where acquirers
do not generate their own encryption keys, the acquirers should undertake
appropriate measures to ensure robust controls and processes are in place to
manage encryption keys. Where this involves a reliance on third party
assessment 21, the acquirers should consider whether such reliance is consistent
with the acquirers’ risk appetite and tolerance. Acquirers should also give due
regard to the system resources required to support the cryptographic controls and
the risk of reduced network traffic visibility of data that has been encrypted.
G 18.18 Acquirers should ensure cryptographic controls are based on the effective
implementation of suitable cryptographic protocols. The protocols should include
secret and public cryptographic key protocols, both of which should reflect a high
degree of protection to the applicable secret or private cryptographic keys. The
selection of such protocols should be based on recognised international standards
and tested accordingly. Commensurate with the level of risk, secret cryptographic
key and private-cryptographic key storage and encryption/decryption computation
should be undertaken in a protected environment, supported by a hardware
security module (HSM) or trusted execution environment (TEE).
21
For example, where the acquirers are not able to perform its own validation on embedded cryptographic
controls due to the proprietary nature of the software or confidentiality constraints.
S 18.20 Acquirers shall ensure proper management of data centres and specify the
resilience and availability objectives 22 of their data centres which are aligned with
their business needs.
G 18.21 The network infrastructure should be designed to be resilient, secure and scalable.
Potential data centre failures or disruptions should not significantly degrade the
delivery of its financial services or impede its internal operations.
G 18.22 Acquirers should ensure production data centres are concurrently maintainable.
This includes ensuring that production data centres have redundant capacity
components and distribution paths serving the computer equipment.
G 18.23 In addition to paragraph 18.22, large acquirers are also encouraged to ensure
recovery data centres are concurrently maintainable.
G 18.24 Acquirers should host IT systems in a dedicated space intended for production
data centre usage. The dedicated space is to be physically secured from
unauthorised access and is not located in a disaster-prone area. Acquirers should
ensure there is no single point of failure (SPOF) in the design and connectivity for
critical components of the production data centres, including hardware
components, electrical utility, thermal management and data centre infrastructure.
S
S 18.25 Acquirers shall establish proportionate controls, ensure adequate maintenance,
and holistic and continuous monitoring of the critical components of the production
22
Availability objectives refer to the level of availability of the data centre which is expected to be specified
as an internal policy.
G 18.26 Acquirers are encouraged to appoint a technically competent external third party
service provider to carry out a production data centre risk assessment and set
proportionate controls aligned with the acquirers’ risk appetite. The assessment
should consider all major risks associated with the production data centre and to
be conducted periodically or whenever there is a material change in the data
centre infrastructure. The assessment should at a minimum, include a
consideration of whether paragraphs 18.22 to 18.25 have been adopted. For data
centres managed by third party service providers, acquirers may rely on
independent third party assurance reports provided such reliance is consistent with
the acquirers’ risk appetite and tolerance, and the independent assurance has
considered similar risks and meets the expectations in this paragraph for
conducting the assessment. The designated board-level committee should
deliberate the outcome of the assessment.
S 18.27 Acquirers shall ensure their capacity needs are well-planned and managed with
due regard to business growth plans. This includes ensuring adequate system
storage, central processing unit (CPU) power, memory and network bandwidth.
G 18.28 Acquirers should involve both the technology stakeholders and the relevant
business stakeholders within the acquirers in their development and
implementation of capacity management plans.
23
For example, batch runs and backup processes for the acquirers’ application systems and infrastructure.
S 18.30 Acquirers shall segregate incompatible activities in the data centre operations
environment to prevent any unauthorised activity 24. In the case where vendors’ or
programmers’ access to the production environment is necessary, these activities
shall be properly authorised and monitored.
S 18.31 Acquirers shall establish adequate control procedures for their data centre
operations. These control procedures shall include procedures for batch
processing management to ensure timely and accurate batch processes,
implementing changes in the production system, error handling, as well as,
management of other exceptional conditions.
S 18.33 Acquirers shall maintain a sufficient number of backup copies of critical data, the
updated version of the operating system software, production programmes, system
utilities, all master and transaction files and event logs for recovery purposes.
Backup media shall be stored in an environmentally secure and access-controlled
backup site.
G 18.34 In regard to paragraph 18.32 and 18.33, acquirers should also adopt the controls
as specified in Appendix 3 or their equivalent to secure the storage and
transportation of sensitive data in removable media.
24
For example, system development activities shall be segregated from data centre operations.
Network Resilience
G 18.36 Acquirers are encouraged to design a reliable, scalable and secure enterprise
network that is able to support their business activities, including future growth
plans.
G 18.37 Acquirers should ensure the network services for their critical systems are reliable
and have no SPOF in order to protect the critical systems against potential
network faults and cyber threats.
G 18.38 Acquirers should establish real-time network bandwidth monitoring processes and
corresponding network service resilience metrics to flag any over utilisation of
bandwidth and system disruptions due to bandwidth congestion and network
faults. This includes traffic analysis to detect trends and anomalies.
S 18.39 Acquirers shall ensure network services supporting IT systems are designed and
implemented to ensure the confidentiality, integrity and availability of data.
G 18.40 Acquirers should establish and maintain a network design blueprint identifying all
of their internal and external network interfaces and connectivity. The blueprint
should highlight both physical and logical connectivity between network
components and network segmentations.
S 18.41 Acquirers shall ensure sufficient and relevant network device logs are retained for
investigations and forensic purposes for at least three (3) years.
G 18.43 Acquirers are encouraged to appoint a technically competent external third party
service provider to carry out regular network risk assessment and set
proportionate controls aligned with its risk appetite. The assessment should be
conducted periodically or whenever there is a material change in the network
design. The assessment should consider all major risks and determine the
current level of resilience.
S 18.45 The board and senior management of the acquirers shall exercise effective
oversight and address associated risks when engaging third party service
providers for critical technology functions and systems. Engagement of third party
service providers, including engagements for independent assessment, does not
in any way reduce or eliminate the principal accountabilities and responsibilities of
acquirers for the security and reliability of technology functions and systems.
S 18.46 Acquirers shall conduct proper due diligence on the third party service provider’s
competency, system infrastructure and financial viability as relevant prior to
engaging its services. In addition, an assessment shall be made of the third party
service providers’ capabilities in managing the following specific risks –
(a) data leakage such as unauthorised disclosure of customer and counterparty
information;
(b) service disruption including capacity performance;
(c) processing errors;
(d) physical security breaches;
(e) cyber threats;
(f) over-reliance on key personnel;
(g) mishandling of confidential information pertaining to the acquirers or its
customers in the course of transmission, processing or storage of such
information; and
(h) concentration risk.
S 18.47 At a minimum, the outsourcing agreements with the acquirers’ third party service
providers shall contain arrangements for disaster recovery and backup capability,
where applicable, and IT system availability.
S 18.48 Acquirers shall ensure their ability to regularly review the outsourcing agreements
with their third party service providers to take into account the latest security and
technological developments in relation to the services provided.
S 18.49 Acquirers shall ensure data residing in third party service providers are
recoverable in a timely manner. The acquirers shall ensure clearly defined
arrangements with the third party service providers are in place to facilitate the
acquirers’ immediate notification and timely updates to the Bank and other
relevant regulatory bodies in the event of a cyber-incident.
S 18.50 Acquirers shall ensure the storage of their data is at least logically segregated
from the other clients of the third party service providers. There shall be proper
controls over and periodic review of the access provided to authorised users.
S 18.51 Acquirers shall ensure IT system hosted by third party service providers have
adequate recovery and resumption capability and provisions to facilitate an
orderly exit in the event of failure or unsatisfactory performance by the third party
service providers.
Cloud Services
S 18.52 Acquirers shall fully understand the inherent risk of adopting cloud services. In
this regard, acquirers are required to conduct a comprehensive risk assessment
prior to cloud adoption which considers the inherent architecture of cloud services
that leverage on the sharing of resources and services across multiple tenants
over the Internet. The assessment shall specifically address risks associated with
the following –
(a) sophistication of the deployment model;
S 18.53 The risk assessment as outlined in paragraph 18.52 shall be documented and made
available for the Bank’s review as and when requested by the Bank.
S 18.54 Acquirers shall demonstrate that specific risks associated with the use of cloud
services for IT systems have been adequately considered and addressed. The risk
assessment shall address the risks outlined in paragraph 18.52, as well as, the
following areas –
(a) the adequacy of the over-arching cloud adoption strategy of the acquirers
including –
(i) board oversight over cloud strategy and cloud operational management;
(c) the degree to which the selected cloud configuration adequately addresses the
following attributes –
(iii) scalability;
(iv) portability;
G 18.55 Acquirers should consider the need for a third party pre-implementation review on
cloud implementation that also covers the areas set out in paragraph 18.54.
Access Control
S 18.57 Acquirers shall implement an appropriate access control policy for the identification,
authentication and authorisation of users (internal and external users such as third
party service providers). This shall address both logical and physical technology
access controls, which are commensurate with the level of risk of unauthorised
access to its technology systems.
G 18.58 In observing paragraph 18.57, acquirers should consider the following in accessing
the control policy –
(a) adopt a “deny all” access control policy for users by default unless explicitly
authorised;
(b) employ “least privilege” access rights or on a “need-to-have” basis where only
the minimum sufficient permissions are granted to legitimate users to perform
their roles;
(c) employ time-bound access rights which restrict access to a specific period
including access rights granted to third party service providers;
(d) employ segregation of incompatible functions to ensure that no single person
is responsible for an entire operation that may provide the ability to
independently modify, circumvent, and disable system security features. This
may include a combination of functions such as –
(i) system development and technology operations;
(ii) security administration and system administration; and
(iii) network operation and network security;
(e) employ dual control functions which require two or more persons to execute
an activity;
(f) adopt stronger authentication for critical activities including for remote access;
(g) limit and control the use of the same user ID for multiple concurrent sessions;
(h) limit and control the sharing of user ID and passwords across multiple users;
and
(i) control the use of generic user ID naming conventions in favour of more
personally identifiable IDs.
S 18.59 Acquirers shall employ robust authentication processes to ensure the authenticity of
identities in use. Authentication mechanisms shall commensurate with the criticality
of the functions and adopt at least one or more of these three (3) basic
authentication factors, namely, something the user knows (e.g. password, PIN),
something the user possesses (e.g. smart card, security device) and something the
user is (e.g. biometric characteristics, such as a fingerprint or retinal pattern).
G 18.60 Authentication methods that depend on more than one factor typically are more
difficult to compromise than a single factor system. In view of this, acquirers are
encouraged to properly design and implement (especially in high-risk or ‘single
sign-on’ systems) multi-factor authentication (MFA) that is more reliable and provide
stronger fraud deterrents.
S 18.61 Acquirers shall periodically review and adapt their password practices to enhance
resilience against evolving attacks. This includes the effective and secure
generation of passwords. There shall be appropriate controls in place to check the
strength of the passwords created.
G 18.62 Acquirers are encouraged to adopt dedicated user domains for selected critical
functions, separate from the broader enterprise-wide user authentication system.
S 18.63 Acquirers shall establish a user access matrix to outline access rights, user roles or
profiles, and the authorising and approving authorities. The access matrix shall be
periodically reviewed and updated.
G 18.65 In fulfilling the requirement under paragraph 18.64, large acquirers are encouraged
to –
(a) deploy an identity access management system to effectively manage and
monitor user access to enterprise-wide systems; and
(b) deploy automated audit tools to flag any anomalies.
S 18.66 Acquirers shall ensure that the IT systems are not running on outdated systems with
known security vulnerabilities or end-of-life (EOL) technology systems. In this
regard, the acquirers shall clearly assign responsibilities to identified functions –
(a) to continuously monitor and implement latest patch releases in a timely
manner; and
(b) identify critical technology systems that are approaching EOL for further
remedial action.
G 18.67 Acquirers should establish a patch and EOL management framework which
addresses among others the following requirements –
(a) identification and risk assessment of all technology assets for potential
vulnerabilities arising from undeployed patches or EOL systems;
(b) conduct of compatibility testing for critical patches;
(c) specification of turnaround time for deploying patches according to the
severity of the patches; and
(d) adherence to the workflow for end-to-end patch deployment processes
including approval, monitoring and tracking of activities.
S 18.68 Acquirers shall implement robust technology security controls in providing digital
services which assure the following –
(a) confidentiality and integrity of customer and counterparty information and
transactions;
(b) reliability of services delivered via channels and devices with minimum
disruption to services;
G 18.69 Acquirers should implement controls to authenticate and monitor all financial
transactions. These controls, at a minimum, should be effective in mitigating man-in-
the-middle attacks, transaction fraud, phishing and compromise of application
systems and information. Acquirers should deploy MFA technology and channels
that are more secure than unencrypted short messaging service (SMS).
S 18.70 Acquirers shall ensure sufficient and relevant digital service logs are retained for
investigations and forensic purposes for at least three (3) years.
G 18.71 Acquirers should ensure that the use of more advanced technology to authenticate
and deliver digital services such as biometrics, tokenisation and contactless
communication 25 comply with internationally recognised standards where available.
The technology should be resilient against cyber threats 26 including malware,
phishing or data leakage.
25
Such as QR code, Bar Code, Near Field Communication (NFC), Radio Frequency Identification (RFID).
26
For example, in respect of QR payments, acquirers shall implement safeguards within its respective
mobile applications to detect and mitigate risks relating to QR code that may contain malware or links to
phishing websites.
G 18.73 Acquirers should ensure authentication processes using biometric technology are
secure, highly resistant to spoofing and have a minimal false acceptance rate to
ensure confidentiality, integrity and non-repudiation of transactions.
G 18.74 Acquirers should perform continuous surveillance to assess the vulnerability of the
operating system and the relevant technology platform used for its digital delivery
channels to security breaches and implement appropriate corresponding
safeguards. At a minimum, acquirers should implement sufficient logical and
physical safeguards for the following channels/devices –
(a) payment acceptance device;
(b) QR code;
(c) Internet application; and
(d) mobile application and devices.
In view of the evolving threat landscape, these safeguards should be continuously
reviewed and updated to protect against fraud and to secure the confidentiality and
integrity of customer and counterparty information and transactions.
G 18.75 With respect to paragraph 18.74, acquirers should adopt the controls specified in
the following Appendices for the respective digital delivery channel –
(a) Appendix 4: Control Measures on Payment Acceptance Device;
(b) Appendix 5: Control Measures on Internet Application;
(c) Appendix 6: Control Measures on Mobile Application and Devices; and
(d) Appendix 7: Control Measures on Quick Response Code.
G 19.1 Acquirers should ensure that there is an enterprise-wide focus on effective cyber
risk management to reflect the collective responsibility of business and technology
lines for managing cyber risks.
S 19.2 Acquirers shall develop a Cyber Resilience Framework (CRF), which articulates the
acquirers’ governance for managing cyber risks, its cyber resilience objectives and
its risk tolerance, with due regard to the evolving cyber threat environment.
Objectives of the CRF includes ensuring operational resilience against extreme but
plausible cyber-attacks.
G 19.3 The CRF should be able to support the effective identification, protection, detection,
response, and recovery (IPDRR) of systems and data hosted on-premise or by third
party service providers from internal and external cyber-attacks. The CRF should
consist of, at a minimum, the following elements –
(a) development of an institutional understanding of the overall cyber risk
context in relation to the acquirers’ businesses and operations, their
exposure to cyber risks and current cybersecurity posture;
(b) identification, classification and prioritisation of critical systems, information,
assets and interconnectivity (with internal and external parties) to obtain a
complete and accurate view of the acquirers’ information assets, critical
systems, interdependencies and cyber risk profile;
(c) identification of cybersecurity threats and countermeasures including
measures to contain reputational damage that can undermine confidence in
the acquirers;
(d) layered (defense-in-depth) security controls to protect data, infrastructure
and assets against evolving threats;
(e) timely detection of cybersecurity incidents through continuous surveillance
and monitoring;
(f) detailed incident handling policies and procedures and a crisis response
management playbook to support the swift recovery from cyber-incidents and
contain any damage resulting from a cybersecurity breach; and
(g) policies and procedures for timely and secure information sharing and
collaboration with other acquirers and participants in financial market
infrastructure to strengthen cyber resilience.
G 19.4 In addition to the elements provided in paragraph 19.3 above, large acquirers are
encouraged to —
Cybersecurity Operations
G 19.5 Acquirers should establish clear responsibilities for cybersecurity operations which
should include implementing appropriate mitigating measures in the acquirers’
conduct of business that correspond to the following phases of the cyber-attack
lifecycle –
(a) reconnaissance;
(b) weaponisation;
(c) delivery;
(d) exploitation;
(e) installation;
(f) command and control; and
(g) exfiltration.
G 19.6 Where relevant, acquirers should adopt the control measures on cybersecurity as
specified in Appendix 8 to enhance its resilience to cyber-attacks.
G 19.7 Acquirers are encouraged to deploy effective tools to support the continuous and
proactive monitoring and timely detection of anomalous activities in its technology
infrastructure. The scope of monitoring should cover all critical systems including
the supporting infrastructure.
S 19.8 Acquirers shall ensure that their cybersecurity operations continuously prevent and
detect any potential compromise of their security controls or weakening of their
security posture. For large acquirers, this shall include performing a quarterly
vulnerability assessment of external and internal network components that support
all critical systems.
S 19.9 Acquirers shall conduct annual penetration tests on their internal and external
network infrastructure as well as IT systems including web, mobile and all external-
facing applications. The penetration testing shall reflect extreme but plausible cyber-
attack scenarios based on emerging and evolving threat scenarios. Acquirers shall
engage suitably accredited penetration testers and third party service providers to
perform this function.
G 19.10 In addition to the requirement in paragraph 19.9 above, large acquirers are
encouraged to undertake independent compromise assessment on the technology
infrastructure of their critical systems at least annually and ensure the results of
such assessment are escalated to the board and senior management in a timely
manner.
S 19.11 Acquirers shall establish standard operating procedures (SOP) for vulnerability
assessment and penetration testing (VAPT) activities. The SOP shall outline the
relevant control measures including ensuring the external penetration testers are
accompanied on-premises at all times, validating the event logs and ensuring data
purging.
S 19.12 Acquirers shall ensure the outcome of the penetration testing exercise is properly
documented and escalated in a timely manner to senior management to identify and
monitor the implementation of relevant remedial actions.
G 19.13 Acquirers should ensure their technology systems and infrastructure, including IT
systems outsourced to or hosted by third party service providers, are adequately
protected against all types of DDoS attacks (including volumetric, protocol and
application layer attacks) through the following measures –
(a) subscribing to DDoS mitigation services, which include automatic “clean
pipe” services to filter and divert any potential malicious traffic away from the
network bandwidth;
(b) regularly assessing the capability of the service third party service provider to
expand network bandwidth on-demand including upstream third party service
provider capability, adequacy of the third party service provider’s incident
response plan and its responsiveness to an attack; and
(c) implementing mechanisms to mitigate against Domain Name Server (DNS)
based layer attacks.
G 19.14 Acquirers should establish a clear DLP strategy and processes in order to ensure
that proprietary and customer and counterparty information is identified, classified
and secured. At a minimum, acquirers should –
(a) ensure that data owners are accountable and responsible for identifying and
appropriately classifying data;
(b) undertake a data discovery process prior to the development of a data
classification scheme and data inventory; and
(c) ensure that data accessible by third parties is clearly identified and policies
should be implemented to safeguard and control third party access. This
includes having in place adequate contractual agreements to protect the
interests of the acquirers and their customers.
G 19.15 Acquirers should design internal control procedures and implement appropriate
technology in all applications and access points to enforce DLP policies and trigger
any policy violations. The technology deployed should cover the following –
(a) data in-use – data being processed by IT resources;
G 19.16 Acquirers should implement appropriate policies for the removal of data on
technology equipment, mobile devices or storage media to prevent unauthorised
access to data.
S 19.17 Acquirers shall ensure their SOC, whether managed in-house or by third party
service providers, has adequate capabilities for proactive monitoring of its
technology security posture. This shall enable the acquirers to detect anomalous
user or network activities, flag potential breaches and establish the appropriate
response supported by skilled resources based on the level of complexity of the
alerts. The outcome of the SOC activities shall also inform the acquirers’ reviews of
its cybersecurity posture and strategy.
G 19.19 Acquirers should ensure that the SOC provides a regular threat assessment report,
which should include, at a minimum, the following –
(a) trends and statistics of cyber events and incidents categorised by type of
attacks, target and source IP addresses, location of data centres and
criticality of applications; and
(b) intelligence on emerging and potential threats including tactics, techniques
and procedures (TTP).
For large acquirers, such reports should be provided on a monthly basis.
S 19.22 Acquirers shall establish comprehensive cyber crisis management policies and
procedures that incorporate cyber-attack scenarios and responses in the
organisation’s overall crisis management plan, escalation processes, business
continuity and disaster recovery planning. This includes developing a clear
communication plan for engaging shareholders, regulatory authorities, customers
and employees in the event of a cyber-incident.
(b) Detection and analysis: Ensure effective and expedient processes for
identifying points of compromise, assessing the extent of damage and
preserving sufficient evidence for forensics purposes;
(c) Containment, eradication and recovery: Identify and implement remedial
actions to prevent or minimise damage to the acquirers, remove the known
threats and resume business activities; and
(d) Post-incident activity: Conduct post-incident review incorporating lessons
learned and develop long-term risk mitigations.
G 19.24 Acquirers should conduct an annual cyber drill exercise to test the effectiveness of
their CIRP, based on various current and emerging threat scenarios (e.g. social
engineering), with the involvement of key stakeholders including members of the
board, senior management and relevant third party service providers. The test
scenarios should include scenarios designed to test –
(a) the effectiveness of escalation, communication and decision-making
processes that correspond to different impact levels of a cyber-incident; and
(b) the readiness and effectiveness of CERT and relevant third party service
providers in supporting the recovery process.
S 19.25 Acquirers shall immediately notify the Bank of any cyber-incidents affecting the
institution. Upon completion of the investigation, the acquirers are also required to
submit a report on the incident to the Bank.
G 19.26 Acquirers are strongly encouraged to collaborate and cooperate closely with
relevant stakeholders and competent authorities in combating cyber threats and
sharing threat intelligence and mitigation measures.
S 20.1 Acquirers shall ensure that the scope, frequency and intensity of technology audits
are commensurate with the complexity, sophistication and criticality of technology
systems and applications.
S 20.2 The audit function shall be adequately resourced with relevant technology audit
competencies and sound knowledge of the acquirers’ technology processes and
operations.
G 20.3 Acquirers should ensure their technology audit staff are adequately conversant with
the developing sophistication of the acquirers’ technology systems and delivery
channels.
G 20.4 In addition to paragraph 20.2, large acquirers are expected to establish a dedicated
technology audit function that has specialised technology audit competencies to
undertake technology audits.
S 20.5 Acquirers shall establish a technology audit plan that provides appropriate coverage
of critical technology services, third party service providers, material external system
interfaces, delayed or prematurely terminated critical technology projects and post-
implementation reviews of new or material enhancements of technology services.
G 20.6 The audit function (in the case of paragraph 20.2) and the dedicated technology
audit function (in the case of paragraph 20.4) may be enlisted to provide advice on
compliance with and adequacy of control processes during the planning and
development phases of new major products, systems or technology operations. In
such cases, the technology auditors participating in this capacity should carefully
consider whether such an advisory or consulting role would materially impair their
independence or objectivity in performing post-implementation reviews of the
products, systems and operations concerned.
S 21.1 Acquirers shall provide adequate and regular technology and cybersecurity
awareness education for all staff in undertaking their respective roles and measure
the effectiveness of its education and awareness programmes. This cybersecurity
awareness education shall be conducted at least annually by the acquirers and
shall reflect the current cyber threat landscape.
G 21.2 Acquirers should provide adequate and continuous training for staff involved in
technology operations, cybersecurity and risk management in order to ensure that
the staff are competent to effectively perform their roles and responsibilities.
G 21.3 Acquirers should provide their board members with regular training and information
on technology developments to enable the board to effectively discharge its
oversight role.
S 22.1 Newly registered acquirers shall conduct a post-implementation review no later than
six (6) months after the implementation of the acceptance of payment instruments.
The review shall include the identification of issues, gaps, fraud incidents and
implementation of action plans to resolve any shortcomings identified.
S 22.2 Acquirers shall notify the Bank in writing, to the Director of the department in charge
of oversight/supervision of payment services on the following –
(a) any proposed changes to their merchant acquiring services model which are
significant or changes the risk profile of the business model, which includes but
is not limited to any changes in target market, mode of payment acceptance,
as well as, payment and settlement flow, by providing the details within thirty
(30) days prior to the effective date of the proposed changes; and
(b) any change in average MTV that would cause changes from recognition as a
small to large acquirer or vice-versa, not more than sixty (60) days from such
occurrence.
S 22.4 The information required in paragraphs 22.3(b) and (c) shall be submitted to
STATsmart Integrated Submission Portal on the 20th day of the following month.
27
Based on at least the acquirer’s management account and covering the acquirer’s merchant acquiring
services only, if the acquirer also conducts other business activities.
Share premium
plus Audited Profit for the period (or less Unaudited Loss for the period)
(a) clearly defined roles and responsibilities as well as obligations of the service
provider;
(b) provisions to ensure that the service provider ensures security and confidentiality
of information shared with the service provider at all times, including –
(i) responsibilities of the service provider with respect to information security
and confidentiality as well as scope of such information;
(ii) for the service provider to be bound by confidentiality provisions stipulated
under the contract even after the engagement has ended;
(iii) for the service provider to maintain compliance with applicable security
requirements and established security standards (e.g. Payment Card
Industry Data Security Standard (PCI DSS)) at all times;
(iv) provisions on corresponding liability obligations arising from a security
breach attributable to the service provider; and
(v) notification requirements in the event of a security breach;
(c) clear provisions on access rights for the Bank or any party appointed by the Bank
to examine or conduct audit on the activity conducted by the service provider or
its sub-contractor for the acquirer. This shall include access to any system,
record, information or data related to the acquirer, as well as rights to enter the
premises of the service provider or its sub-contractor to conduct such
examination or investigation;
(d) continuous and complete access by the acquirer to its data held by the service
provider in the event of a dispute with the service provider, or termination of the
arrangement;
(e) ability of the acquirer and its external auditor to conduct audits and on-site
inspections on the service provider and its sub-contractors, and to obtain any
report or finding made in relation to the outsourced activity;
(f) dispute resolution process in the event of default or non-performance of
obligations, including remedies and indemnities where relevant;
(g) measures that the service provider would take to ensure continuity of the
outsourced activity in the event of an operational disruption or failure on the part
of the service provider;
(h) conditions under which the outsourcing arrangement may be terminated, with
sufficient time for an orderly transfer of the outsourced activity to the acquirer or
another party;
(i) allow the acquirer the right to modify or terminate the arrangement when the
Bank issues a direction to the acquirer to that effect under the FSA; and
(j) where relevant, terms governing the ability of the service provider to sub-contract
to other parties, which will not dilute the accountability of the service provider.
Acquirers should ensure adequate controls and measures are implemented for the
storage and transportation of sensitive data in removable media, including –
1) Deploying the industry-tested and accepted encryption techniques;
2) Implementing authorised access control to sensitive data (e.g. password protection,
user access matrix);
3) Prohibiting unauthorised copying and reading from the media;
4) Shall there be a need to transport the removable media to a different physical
location, acquirers should —
(a) strengthen the chain of custody process for media management which
includes –
(i) the media must not be under single custody at any point of time;
(ii) the media must always be within sight of the designated custodians;
and
(iii) the media must be delivered to its target destination without
unscheduled stops or detours;
(b) use secure and official vehicle for transportation; and
(c) use strong and tamper-proof containers for storing the media with high-
security lock (e.g. dual key and combination lock);
5) Ensuring third party service providers comply with the requirements in paragraphs 1
to 4 of this Appendix 3, in the event third party services are required in undertaking
the storage management or transportation process of sensitive data in removable
media.
1) Acquirers should ensure all relevant risks associated to the use of merchant’s
payment acceptance device are mitigated, including but not limited to the following
-
(a) ensuring the payment acceptance devices are –
(i) adequately hardened and securely configured using methods that
ensure its integrity and authenticity;
(ii) protected from tampering and cyber threats such as malware
attacks, key logger, and etc;
(iii) designed for the protection of PIN data;
(iv) certified to be fully compliant with applicable security standards, e.g.
PCI PIN Transaction Security (PCI PTS), Software-based PIN Entry
on COTS (PCI SPoC), etc.; and
(v) used solely as the payment acceptance device.
(b) ensuring PIN entry process and cardholder verification method (CVM)
applications are secured and protected against manipulation or sabotage;
(c) providing guidance for merchants to ensure the PIN is entered in a way that
it cannot be observed by an unauthorised party;
(d) PIN data must be encrypted upon entry and remain encrypted when
transmitted to protect against malicious activity and attacks;
(e) ensuring data is protected at all times to prevent data leakage and no data
is stored on the payment acceptance devices;
(f) ensuring only dedicated merchant staff are allowed to perform system
administration functions (e.g. performing correction) of the payment
acceptance device; and
(g) for PIN Entry on COTS –
(i) ensuring PIN CVM applications run only on secured and supported
versions of operating systems which have not been compromised,
jailbroken or rooted i.e. the security patches are up-to-date; and
(ii) use of automated monitoring and attestation system to detect
potential compromise of payment acceptance devices and ensuring
that all components in the payment acceptance devices are always
in a secure state.
1) Acquirers should ensure the adequacy of security controls implemented for Internet
application, which include –
(a) ensuring Internet application only runs on secured versions of web browsers
that have continued developer support for security patches to fix any
vulnerabilities; and
(b) putting in place additional authentication protocols to enable customers to
identify the acquirers’ genuine websites.
1) Acquirers should ensure digital payment services involving sensitive customer and
counterparty information offered via mobile devices are adequately secured. This
includes the following –
(a) ensuring mobile applications run only on the supported version of operating
systems and enforce the application to only operate on a secure version of
operating systems which have not been compromised, jailbroken or rooted
(i.e. the security patches are up-to-date);
(b) designing the mobile application to operate in a secure and tamper-proof
environment within the mobile devices. The mobile application shall be
prohibited from storing customer and counterparty information used for
authentication with the application server such as PIN and passwords.
Authentication and verification of unique key and PIN shall be centralised at
the host;
(c) undertaking proper due diligence processes to ensure the application
distribution platforms used to distribute the mobile application are reputable;
(d) ensuring proper controls are in place to access, maintain and upload the
mobile application on application distribution platforms;
(e) activation of the mobile application must be subject to authentication by the
acquirers;
(f) ensuring secure provisioning process of mobile application in the user’s
device is in place by binding the mobile application to the user’s profile such
as device ID and account number; and
(g) monitoring the application distribution platforms to identify and address the
distribution of fake applications in a timely manner.
2) In addition to the guidance above, acquirers should also ensure the following
measures are applied specifically for applications running on mobile devices used
by the acquirers, appointed parties or intermediaries for the purpose of processing
customer and counterparty information -
(a) mobile device to be adequately hardened and secured;
(b) ensure the capability to automatically wipe data stored in the mobile devices
in the event the device is reported stolen or missing; and
(c) establish safeguards that ensure the security of customer and counterparty
information (e.g. Primary Account Numbers (PAN), Card Verification Value
Numbers (CVV), expiry dates and Personal Identification Numbers (PIN) of
payment cards), including to mitigate risks of identity theft and fraud 29.
29
This includes risks associated with malwares that enable keystroke logging, PIN harvesting and other
malicious forms of customer and counterparty information downloading.
2) Ensure QR codes do not contain any confidential data and are not stored in
endpoint devices.
3) Ensure all relevant risks associated with the use of static QR codes at participating
merchants are mitigated, including but not limited to the following –
(a) all information from the scanned QR codes shall be transmitted to payment
instrument’s host server for authentication;
(b) educate merchants on fraud risk related to static QR codes and the
preventive measures to effectively mitigate such risk (e.g. merchants shall
regularly inspect the displayed static QR code to ensure it has not been
tampered with); and
(c) enforce masking of sensitive customer and counterparty information when
displayed on mobile devices.
1) Conduct periodic review on the configuration and rules settings for all security
devices. Use automated tools to review and monitor changes to configuration and
rules settings.
2) Update checklists on the latest security hardening of operating systems.
3) Update security standards and protocols for web services encryption regularly.
Disable support of weak ciphers and protocol in web-facing applications.
4) Ensure technology networks including mobile and wireless networks are segregated
into multiple zones according to threat profile. Each zone shall be adequately
protected by various security devices including firewall and Intrusion Prevention
System (IPS).
5) Ensure security controls for server-to-server external network connections include
the following –
(a) server-to-server authentication such as Public Key Infrastructure (PKI)
certificate or user ID and password;
(b) use of secure tunnels such as Transport Layer Security (TLS) and Virtual
Private Network (VPN) IPSec; and
(c) deploying staging servers with adequate perimeter defences and protection
such as firewall, IPS and antivirus.
6) Ensure security controls for remote access to server include the following –
(a) restrict access to only hardened and locked down end-point devices;
(b) use secure tunnels such as TLS and VPN IPSec;
(c) deploy “gateway” server with adequate perimeter defences and protection
such as firewall, IPS and antivirus; and
(d) close relevant ports immediately upon expiry of remote access.
7) Ensure overall network security controls are implemented including the following –
(a) dedicated firewalls at all segments. All external-facing firewalls must be
deployed on High Availability (HA) configuration and “fail-close” mode
activated. Deploy different brand name/model for two firewalls located in
sequence within the same network path;
(b) IPS at all critical network segments with the capability to inspect and
monitor encrypted network traffic;
(c) web and email filtering systems such as web-proxy, spam filter and anti-
spoofing controls;
(d) end-point protection solution to detect and remove security threats including
viruses and malicious software;
(e) solution to mitigate advanced persistent threats including zero-day and
signatureless malware; and
(f) capture the full network packets to rebuild relevant network sessions to aid
forensics in the event of incidents.
8) Synchronise and protect the Network Time Protocol (NTP) server against
tampering.
For the purpose of paragraph 14, arrangements which entail procurement of services 30,
leveraging common industry-wide infrastructure driven by regulatory requirements, and
involvement of third parties due to legal requirements, are generally not considered as
outsourcing arrangements. These include –
(a) services for the transfer, clearing and settlement of funds or securities provided by
an operator of a designated payment system or an operator of an approved
payment system under the FSA or IFSA;
(b) global financial messaging network services provided by an operator that is owned
by its member financial institutions and is subject to the oversight of relevant
regulators;
(c) independent consultancy service (e.g. legal opinions, tax planning and valuation);
(d) independent audit assessment;
(e) clearing and settlement arrangement between clearing houses and settlement
institutions and their members;
(f) agent banking;
(g) trustee arrangement;
(h) credit or market information services;
(i) repair, support and maintenance of tangible asset;
(j) purchase or subscription of commercially available software;
(k) maintenance and support of licensed software;
(l) marketing and advertising;
(m) telecommunication, postal and courier service;
(n) physical security, premise access and guarding services; and
(o) catering, cleaning and event services.
30
Where an acquirer acquires services, goods or utilities, which are not expected to be performed by the
acquirer.