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Published byHubert Hines Modified over 9 years ago
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© NYSE Blue. All Rights Reserved. NYSE Blue Security Concerns for Offset Registries July 26, 2011
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Security Framework for an Offset Program Registry Technology Know Your Client Procedures Program Legal & Operational Rules Training on User Best Practices
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Registry Technology Encrypted connection (HTTPS) Disable user ID upon 3 incorrect logins Ongoing vulnerability testing for registry Later this year, introduction of two-factor authentication
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Know Your Client Procedures Identify clients and ascertain relevant information about their businesses Request copies of documents confirming identity of legal entity organization documents, memorandum of incorporation, bank accounts, utility bills Become familiar with the principals and ask for identification documents such as drivers license, passports, and birth certificates Review marketing materials and business plan Perform OFAC / AML checks to ensure entities not found on Terrorist Watch lists. Monitor activity to ensure it matches the company profile
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Program Legal & Operational Rules Omnibus accounts – Only a regulated entity can maintain an omnibus account (and these regulated entities must show proof of proper KYC procedures) – Certain unregulated entities can be given the ability to maintain omnibus accounts Retirement of credits in omnibus accounts – Retirement of greater than 99 credits on behalf of a client must be done in an specific client sub-account – Retirement of greater than 99k credits on behalf of a client must be made public
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Registry User Best Practices Use latest anti-virus protection programs Update contact information for users/logins to their account Users should not access The Reserve from public locations where others could capture their confidential information. Diligent monitoring of account activity Perform weekly/monthly account reviews to ensure data is correct Users should pay close attention to the registry notifications for transfer confirmations.
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