FFIEC: Any system that permits the movement of funds to other parties or access to customer information is deemed high-risk. Leading-edge institutions have implemented a layered approach to online security that incorporates a combination of mutual authentication, device recognition, biometrics, and one-time password tokens. Wells Fargo & Co. has upgraded its consumer online banking with new technologies including real-time risk analysis software that determines if someone is trying to log in from a different PC and location.”]