Month: May 2017

IATA PCI-DSS: What Exactly is Required?

pci-compliance

Continuing our series on Merchant program for PCI-DSS. Why this is (or will be) so important is that in around 12 – 15 months, if you are a merchant, very likely you will be getting a call from your acquirer.

About 2 months back, Mastercard announced that all acquirers must have in place a risk assessment program for Level 4 merchants by March 31, 2019. This basically means that there is a great concern that 99% of Level 4 merchants out there are blissfully unaware of this PCI-DSS nonsense they need to comply. It is the acquirer’s duty, but the pain starts all the way at the merchants.

One industry feeling the pinch here is the travel industry. But don’t worry, travel agents, soon, the other industries like your cousins at the hotels and hospitality will be going through the same process as you are going through now. It’s just who is going through first. And the faster you get through the better.

Travel agents across the world has been mandated by IATA to be PCI compliant. Please read our previous post here.

We have gone through the requirements in that post, but we’ve been hearing a lot of things coming to us from the travel agencies recently, namely:

a) All Travel Agents need to engage a QSA to formally sign off their SAQ.

IATA should be able to give a formal statement on this. QSAs or consultants or PCI experts cannot dictate or mandate the validation requirements. Mostly this is by the processor (IATA) or the acquiring bank. If they can’t make a statement, then it would fall back into the card brand validation requirements. Which it has so far, unless IATA comes forward to clear this up. We can’t seem to find anywhere that IATA has had special requirements other than listed in the card brands requirements.

There might be further explanation needed based on their PDF at http://www.iata.org/services/finance/Documents/pci-dss-compliance-procedure.pdf

The procedure first states

Travel Agents are encouraged to contact their merchant bank (acquirer) or the applicable payment brand(s) to identify the appropriate procedures based on their eligibility.

But then at the bottom it implies that for assessment, it needs to have a QSA perform ‘on-site’ PCI assessment – which is not exactly accurate as it depends on their level. Further on right at the bottom, it states:

Depending on the number of card transactions handled those can be:
– PCI DSS Attestation of Compliance (AOC) which must be completed by a Qualified Security Assessor (QSA).
– Self-assessment questionnaire signed by an authorized officer.
– The results of quarterly vulnerability scans if applicable.

The problem here is that if the AoC is required to be signed by the QSA, so does its corresponding SAQ. These documents have the same signoff (3c for QSA) section. If you read the above you might be tempted to also argue that IATA is saying, depending on the number of card transactions (meaning your level), the requirements can be either:

– PCI DSS Attestation of Compliance (AOC) and ROC or SAQ which must be completed by a Qualified Security Assessor (QSA) – this applies to Level 1 Merchant (they can also use ISA but lets put that aside for now), and also Level 2 if you deal with mastercard.
– Self-assessment questionnaire (SAQ) and AoC signed by an authorized officer. – This applies to level 3 and 4
– The results of quarterly vulnerability scans if applicable.

Now we don’t know if this is what IATA is saying – it’s just the many ways this section can be interpreted so we do hope IATA will have a clarification on this matter. They CAN decide on a more stringent requirement for their agencies (such as ALL levels engaging a QSA to be onsite like a level 1 merchant), but this needs to be clear, so agencies can forge ahead with the proper budget and expectation.

Most travel agents fall under the Level 4 category of merchants, which based on the current requirements of PCI-DSS only requires a merchant officer to sign off the document.

Mastercard’s SDP services recently responded back to us on this with a confirmation as below:

Level 4 merchants are required to ensure they are PCI-DSS compliant by filling in the correct SAQ based on their processing environment and have the evidences prepared , and also to do this each year. There is no requirement from Mastercard to engage a QSA/ISA to signoff their SAQ on part 3c or part 3d of their SAQ/AoC and their executive signoff on part 3b is sufficient. This must be signed by the merchant. Engaging a QSA will be above and beyond their requirement and only done if they require assistance in filling their SAQ. Therefore, using a QSA is entirely optional and based on the discretion of the merchant.

This goes a long way in saying the same thing that has always been said. The logic I would argue here is, if your industry is made up thousands of merchants, how do we build a meaningful program to get all these merchants compliant? If QSAs are supposed to validate all the evidences, how much bottleneck will there be?

This is also inline with the famous PCI-DSS myth document at https://www.pcisecuritystandards.org/pdfs/pciscc_ten_common_myths.pdf. In Myth 6:

Myth 6 – PCI requires us to hire a Qualified Security Assessor
Because most large merchants have complex IT environments, many hire a QSA to glean their specialized value for on-site security assessments required by PCI DSS. The QSA also makes it easier to develop and get approval for a compensating control. However, PCI DSS provides the option of doing an internal assessment with an officer sign-off if your acquirer and/or merchant bank agrees. Mid-sized and smaller merchants may use the Self-Assessment Questionnaire found on the PCI SSC Web site to assess themselves.

Now, I know, there are so-called ‘merchant programs’ out there run by a few QSAs. I’ve spoken to many merchants who deem themselves compliant just because an ASV ran a scan on their external IP address and gave them a ‘certificate’ of compliance (which is not even a recognised document by PCI-SSC!).  If anything, it just makes the merchant falsely complacent and gives PCI a bad name and a bad rep as an on-paper compliance but practically as useful as ice is to eskimoes.

The crux of the matter isn’t whether QSAs need to be involved or not. It would be super if they can get involved, but the matter is cost and time. QSAs programs are not cheap, and also, how much work do they actually do for the client? The counter argument is, if QSAs are not involved, what then? You get a bunch of executives just signing off they have a firewall when in their mind they are thinking, “Man, Which wall am I going to have to set on fire to comply to this stupid request?”. It’s not a knock on their intelligence, but really, a lot of merchants are really good in doing whatever they are doing and they don’t exactly have a CIO to standby to interpret all the requirements of PCI-DSS for them. And PCI, despite its oftentimes banal requirements, is a compliance requiring a lot of technical understanding.

How do we solve this? Awareness.

The SAQs reason for existence serves simply as a baseline document and puts the onus on the merchant to ensure they have the proper security in place. A lot of merchants are not aware of this obligation. The moment they sign off that document, they are saying, I am taking responsibility over this document. I verify and validate this as true. If it’s not…well. If it comes to any breaches or anything, then the merchant takes responsibility.

If they are fully aware of their responsibility, then getting help is likely required. But now, there is no need for a formal QSA to get involved. If you can, then do so as QSAs do theoretically should have more experience in PCI – but consultants, or advisors can take this role. And there are many reasons why it might turn out better this way which I will explore in my next few articles.

b) All Travel Agents need to engage ASV to do their security scans

Man. This is probably the most misunderstood requirement of all time. All time. 100s of merchants have come to us proudly saying their ASV scan proves their PCI compliance. No, it doesn’t. The ASV scan is just one of many requirements you need to go through. It’s like you dressing for work and wearing only your shoes and nothing else and go to work and say, “Hey, I am all dressed!”. Um. No.

And while ASV is important, we have seen our fair share of trigger happy ASVs being done for travel agencies. Oh, you have a website? ASV! Oh, you have an internet facing IP and router? ASV!

Come on. We recently adviced one client who was having trouble remediating an issue on their website. I asked them, wow, for a small company doing internet transactions, its a big deal. And they went like, “What in the good name of **** are you talking about?” And they explained they just had a corporate website and were asked to do a scan. I went and look, and aside from the site looking like it had been designed by a 15 year old drinking too much mountain dew, it serviced no credit card transactions at all. They don’t even have any systems doing that. They just do EDC terminals that connect directly to the bank and completely isolated. So why the scan?

Because we were told, they said.

And so I drafted an email for them and told them to send it over to their QSA (they are level 4 by the way) and the response came back, “Oh thanks man, they told us there is no need to scan anymore! Yay!”.

The problem remains. How many merchants are scanning their completely static websites and receiving a certificate of compliance and pronouncing they are PCI ‘certified’? Is it the ASV or QSA’s problem? No. PCI clearly states that it is the merchant (or scan customers) who ‘defines the scope of the scan’, so merchants are taking a fair bit of the burden if the ASV is done incorrectly. ASV scans are needed if your site does credit card acceptance (SAQ A-EP). It’s also needed on any external IPs you might have if these are transmitting card information (SAQ B-IP, SAQ C). SAQ A, B and C-VT has no scan requirements listed. A lot of clients could possibly fall under the SAQ B and possibly SAQ C-VT, so ASV scans can be further avoided.

c) All Travel Agents will be fined XYZ amount for non-compliance

Now, this might be true but IATA hasn’t really come out to say anything. Frankly I will be very surprised if there is such a requirement. Basically, IATA is just saying, if you don’t become compliant, don’t connect to us. If you don’t connect to us, then you can’t issue tickets. This is a worse threat than being fined. So they don’t have to be overbearing to impose such a condition AND impose a fine for clients who are non compliant. Because technically, if you are non compliant, you are not connected to IATA. If you are not connected to IATA, what are they fining you for?

smartmurphy

d) PCI-DSS is applicable to all Travel Agents even those without credit card acceptance and transactions

OK. I am not sure whether there will be such agencies or not, meaning there is ZERO card acceptance or processing or storage or transmission in your merchant environment. Now do note, even e-commerce when you outsource your ENTIRE payment processing, the fact that you have the credit card payment option on your website puts you in need of compliance. For merchants that do not have any facility whatsoever (either card present or card-non-present), then technically, PCI-DSS should not apply. I say technically. Because if you are connecting to IATA’s processor (BSP) then even if you make zero or a million transactions, the risk is still there. So yes again IATA as the big boss of BSP has the right to ask for compliance from agencies with zero credit card transactions. In this case, my suggestion is to write to IATA  and see what is the next step. I can’t imagine any merchant business now not catering to credit/debit card payment but, wait. OK, my neighbourhood barber actually told me they only accept cash only, or barter trade my iphone for 2 years supply of haircut. So yeah, why not. But really, if no credit/debit card payment is an option and you regularly settle through agency credit or carrying a pile of cash, you technically can ask IATA what’s the next step.

In summary, we are not saying that there is some sort of conspiracy theory going on where QSAs are trying to pull a fast one on customers and creating F.U.D in the industry. After all, we ourselves have been certifying clients for 7 plus years already. But what we need to understand is that wrong information could be worse than no information. We need to get the right information out there so that merchants can make informed decisions. If they want QSAs, then ok all the better. If they prefer in house or specialised consultants, then OK. If they decide to do the hokey pokey instead of PCI compliance, then hey, that’s an informed decision on their side.

So, let’s get this awareness out. Travel agencies have about 10 months to get compliant. It’s not crunch time yet. This is like the start of the 3rd quarter in basketball. Important, but not Michael Jordan clutch time.

If you need more information on PCI-DSS applicability in your merchant business, drop us an email at pcidss@pkfmalaysia.com. We’ll get in touch with you ASAP.

Tonight, I Wanna Cry

There is a country song that goes:

I’ve never been the kind to ever let my feelings show,
And I thought that being strong meant never losin’ your self control
But I’m just drunk enough, to let go of my pain,
To hell with my pride, let it fall like rain, from my eyes,
Tonight I wanna cry.

And cry they did. Almost 75,000 and counting, over 99 countries hit by one of the largest ransomware attacks of all time, “WannaCry” and the other Wanna* variants.

Wannacry was released on the 12th of May 2017. The irony of it all was that we were invited as one of the speakers in a Ransomware event in Putrajaya under Panda Security the day before and we were just warning those in attendance that the next wave of ransomware is due to hit and within 24 hours, bam, we have Wannacry. In Malaysia, there seems to be already infection, thanks to the guys at

https://intel.malwaretech.com/botnet/wcrypt/?t=24h&bid=all

There have been reports of large telecommunication companies, banks and telcos are being affected. Tens of thousands of networks worldwide have been hit and the attacks do not appear to be targeted to any specific region or industry. Once infected, victims are asked to pay approximately $300 by Bitcoin. For the curious, you can check

https://bitref.com/13AM4VW2dhxYgXeQepoHkHSQuy6NgaEb94

This means there is around 5.8348 bitcoins paid already to this. Which translates to around RM46,000 paid so far – which isn’t so much if you think the average of ransom payment is around RM10,000 – RM11,000 for other ransoms.

So what is this?

Wannacry is using the file extension .wncry, and it also deletes the Shadow Copies (which is normal for ransomwares, like Locky) which is a technology introduced into the Microsoft platforms as far back as Windows XP and Windows Vista as the Volume Shadow Copy service. This means that even backup copies produced by this service, such as Windows Backup and System Restore will be screwed. That’s mean. Here is the command executed.

cmd.exe /c vssadmin delete shadows /all /quiet & wmic shadowcopy delete & bcdedit /set {default} bootstatuspolicy ignoreallfailures & bcdedit /set {default} recoveryenabled no & wbadmin delete catalog -quiet (PID: 2292)

The following file is also created in the affected systems: @Please_Read_Me@.txt

How it gets in is just like any other ransomware: email either phishing or spear phshing. Basically, don’t click on any email attachments that are suspicious! It’s easier said than done, especially if you see one coming in stating that you are behind in your payments for your credit card. Resist the urge. One of the things to check on email:

The return email – most phishing doesn’t even attempt to spoof their email, and you will get emails coming from strange domains like maaybank or clmbclicks. Bad language is also a hallmark of a phishing email. “All your base are belong to us” type of english. Anyone asking for passwords, or click on a link etc is nonsense. Don’t click on email links. Don’t click on the attachments, above all.

Back to Wannacry. It exploits a known Microsoft Windows vulnerability to spread. This vulnerability was released as part of the Shadow Brokers leaks back in April. It hits the SMB (Server Message Block) – some people pronounce it as SAMBA, which technically is not so correct, as SAMBA is the SMB implementation on Linux. It basically allows the sharing of files and printers in networked environment. Which means, if one gets infected, the infection spreads through network shares even to systems without connectivity to the internet.

Microsoft released a patch for MS17-010 on March 14th 2017. Obviously, a lot of systems – especially those in healthcare still runs on Windows XP. The case has been deemed so serious that Microsoft has taken the step to release patches for systems already dead like XP! This shows how unusually dangerous this ransomware is.

OK, so if you have been hit, what do you do?

Well, you can pay. Around 41 transactions have been made so you could make the number, but don’t expect too much out of it. In fact, we probably do not recommend this course of action. You need to remove Wannacry and there are plenty of sites that gives details on that. The problem with ransomware is not so much of removing it, its a matter of recovering your files. Here’s a site you can check if there is a decryptor available:

https://www.nomoreransom.org/crypto-sheriff.php

Please be careful – some so called ‘decryptors’ are disguised as further malware and gets you a double whammy of sorts, so you need to ensure these are proper tools and not something you download from torrent.

As an advisory to all our clients, especially PCI-DSS here’s what you can do to protect yourself:

a) PATCH

https://technet.microsoft.com/en-us/library/security/ms17-010.aspx

Now we see how important it is to patch your systems. Most PCI clients struggle on this and the examples can come from: Our servers are not connected to the internet, or If I patch, my application breaks. Well, if your application breaks then you need to get a warranty from your developers or get them to upgrade and improve.

b) Backup

While PCI doesn’t really focus much on backup or BCP (after all PCI’s interest is in the confidentiality of credit card and not the availability of your business) – it’s still good practice to backup your system. And not just online as ransomware hits shadow copies firstly – but offline backup and ensure your restoration has been tested. Remember those grandfather-father-son backup scheme you learnt in college and university? Yup, it can be applied.

c) Antivirus and Antimalware Updates

While it’s known Antivirus is missing a chunk of malware out there, it’s still for many systems the last line of defence and most vendors have released protection signatures for the ransomware so get it updated. It’s like having the final militia protecting against an invasion. It will probably not hold out forever, but at least it buys your administrators some time.

d) Remove SMB v1 support

https://support.microsoft.com/en-us/help/2696547/how-to-enable-and-disable-smbv1,-smbv2,-and-smbv3-in-windows-vista,-windows-server-2008,-windows-7,-windows-server-2008-r2,-windows-8,-and-windows-server-2012

Simply, for Windows 8 for instance, you need to run Powershell in administrator mode and then just issue

Set-SmbServerConfiguration -EnableSMB1Protocol $false

to disable SMBv1

e) Network segmentation

While this is helpful, it still doesn’t save everyone. Segmentation helps because it isolates computers. Vector of attacks usually comes into the access network (where end users access) and if you segment this from the critical systems, you will need the malware to traverse through your firewall or a filtering device in between which leads us to:

f) IDS, SIEM, IPS or any protection systems you have!

If you don’t have any IDS, IPS or SIEM deployed in your environment, it’s time you get one and this is a good argument for your business budget. IDS/IPS are usually available features in most firewalls these days, so if you segregate your networks, you can then enable these features and it should detect or prevent malware coming into your critical environment.

SIEM is critical. Security Information and Event Management systems have been around since the dawn of time but most companies avoid these due to costs, ever relying on the good old free syslog services. No, not allowed anymore, as far as PCI is concerned. We need more visibility over these logs, malicious traffic and even outgoing traffic to check if there is any communications with a command and control (C&C) server, which is the normal operations of these ransomware. SIEM these days are also no longer that expensive, with a Gartner SIEM like Alienvault starting off at a little over RM25K to get it up and running. We recently deployed a very large SIEM deployment over AWS cloud and on-premise on a major airlines with a fraction of the cost compared to traditional SIEM deployments.

There you have it. WannaCry is a very serious outbreak and we will be monitoring this system and also making our visits to our clients to give a short talk and description over it. If you have any questions over this, or on PCI-DSS or SIEM, drop us a note at avantedge@pkfmalaysia.com.

Stay safe!

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