Category: Risk Management (Page 1 of 3)

Is PCI-DSS the most confusing standard?

After being involved in PCI-DSS for almost a decade as well as other standards and guidelines like ISO27K, 27017, 9001, PDPA, GDPR, CMMI and a partridge in a pear tree, we can almost unanimously say: PCI-DSS is probably the most confusing standard out there. Not so much of the content itself – it’s fairly easy to understand in terms of the technical controls. The confusion begins at the start: Applicability and Scope.

Now scoping for PCI-DSS has been hammered by us in many articles over the years, so for this article, we will look at Applicability.

So what is applicability?

It simply means, who does this standard apply to? This is different from ‘scope’. A scope is basically what is being assessed? Applicability is basically: Do I need to do this thing?? For instance for simplicity:-

a) GDPR = Applies to entities processing EU personally identifiable information. Entities that may have a more global presence or require to deal with customers with a larger market distribution may end up being applicable to the GDPR.

b) PDPA = applies to entities in Malaysia processing personal information, which basically means almost everyone.

c) ISO27001 = guideline that can be used by any entity to cover their core processes. This may also be required by some governments on certain industries, e.g the government requiring CNII (Critical National Information Infrastructure), so simply, if you are CNII, then you should be doing the ISO27K.

d) CSA Star Alliance = standard for our data centers to apply, but it’s not mandatory (as far as we know).

e) TVRA = based on MAS (Monetary Authority of Singapore) requirement for financial institutions, so generally if you are regulated by them, then you need to get this done. It’s actually a subset of their Technology Risk Management Guidelines. It’s pretty much a mirror of Malaysia’s RMiT (Risk Management in Technology) subset of data center resilience section. As an aside it seems slightly comical that these two countries, tied so closely together in terms of history and economy would sit down and decide to name their federal bank’s IT standard so closely to each other. I mean, it’s like:

i) Singapore – Let’s call our technology standard Technology Risk Management!

ii) Malaysia – Hmm, we can’t sound the same otherwise we might look like we aren’t original. Let’s flip it around and call it Risk Management in Technology!

Back to the subject, most standards out there has a reasonably clear idea of who it applies to. Even Bank Negara’s e-money guidelines or their baseline IT security requirements – apply to those regulated by them. HIPAA (not in Malaysia) applies to medical and healthcare entities.

Which leaves us with PCI-DSS.

From the onset, PCI-DSS applicability is actually very clear:

PCI DSS also applies to all other entities that store, process or transmit cardholder data (CHD) and/or sensitive authentication data (SAD).

PCI-DSS Standard

So in general, whenever you are storing, processing or even transmitting any part of the card holder data (PAN) or the sensitive authentication data, e.g track data, CVV etc, then PCI applies to you.

The confusion begins when these exact terms are used by those who are NOT doing any of these 3 (Store, Transmit, Process or STP) –lets call them NON STP– but still gets pulled into scope kicking and screaming like a child on his first day of kindergarten or adults on their first day of work after a holiday in the Bahamas. Examples are data centers, hosting providers, physical security storage companies (storing secure boxes for companies) – in their business model, they don’t deal with credit cards at all. But their customers may. Or may not. They don’t know. So for instance, if an insurance company decides to store their policy files with credit card information physically into a box and ship it to the physical storage company, how does the storage company gets yanked into ‘applicability’ of PCI?

The problem of section 12.8.2:

12.8.2 Maintain a written agreement that includes an acknowledgement that the service providers are responsible for the security of cardholder data the service providers possess or otherwise store, process or transmit on behalf of the customer, or to the extent that they could impact the security of the customer’s cardholder data environment

pci dss standard

The last part is where QSAs hook on – ‘impact the security of the customer’s CDE’. Now, just to be clear, 12.8.2 by itself has no indication that PCI is a requirement for these “NON STP” providers. It comes later in 12.8.4 and 12.8.5 where it states

12.8.4 Maintain a program to monitor service providers’ PCI DSS compliance status at least annually.

PCI dss standard

Argument on whether this relates to PCI-DSS compliance as a program or just service providers adhering to the PCI-DSS controls internally is an argument beyond time and space itself and requires a thesis to be written on it. Hence for now, simplicity wise, going by the standards and how many QSAs interpret it, multi factor authenticating providers gets pulled in. Hosting and cloud providers get pulled in. Storage vendors get pulled in. Cloud HSM and security providers gets pulled in. Fraud management gets pulled in. The whole thing about who could impact the security of customer’s environment gives QSAs a field day in including everyone in the party.

So applicability isn’t so straightforward after all. After determining anyone that stores, transmit and process credit/debit card with the PCI council members badges — now we have anyone that influences the security of the first group’s card data environment. This basically pulls almost everyone into applicability.

It doesn’t end there, however.

Because of the way PCI is structured, the PCI council actually washes their hands to determine who should be PCI compliant, and how they should be compliant. They pass that over to the individual card brands (I guess that’s themselves), who passes it to their banks connecting to their network, who in turn passes it on to their payment providers and who in turn passes either to their service providers or to their merchants. This is looked into in FAQ #1473, #1126, #1212 and a whole lot of other references. They always have this statement:

The PCI SSC recommends that entities contact their acquirer and/or the payment brands directly, as applicable, to understand their validation reporting requirements. Please contact the payment brands directly.

Everywhere to ensure everyone knows

When we were kids we used to play a party game whereby two teams have everyone sitting in two long straight lines. At the front of the line, the gamekeeper passes them a message, for instance “There is a blue wolf sitting in the Artic, looking at you with yellow, hungry eyes tonight” or something like that. Each kid will then need to whisper that message to the person behind him until it reaches the last person and that last person will have to go to the front and declare the message aloud, which invariably ends up something like “There comes wind that blew into the attic and sitting at me with fellow grey ice to the right.”  And everyone laughs.

This is how it is in PCI. The message gets passed down and somehow along the way, the message gets so jumbled that we can only shrug and go, “OK…” Some messages we have heard (from customers who claim their banks said):

a) “You need to show us their SAQ and ROC together! The AoC is not enough” – Not really. If you are doing SAQ, there’s no ROC (Report of Compliance). Likewise, if there is a ROC, it’s not SAQ. Both have AoC though.

b) “Physical storage companies that store physical card data like forms needs to do SAQ C-VT” – We’ve seen this, where storage company gave a SAQ C-VT (virtual terminals) to their banks and was accepted. No, you can’t. A physical storage company, being a service provider should look at the SAQ D and then mark of the irrelevant controls (such as firewall etc) as Not Applicable.

c) “You can do SAQ A – as a payment gateway!” – A permutation of b) – whereby a payment provider gave us an SAQ A as proof of their PCI compliance. I think they just scanned through which is the shortest SAQ A and go, OK, let’s go for the easiest. No, SAQ A isn”t applicable to service providers. SAQ D needs to be done and controls that are relevant to be identified.

d) “You can store hashes with truncated data, its more secure!” – This is more of our previous post, where a company we spoke to started arguing on the merits of implementing truncation, encryption, hashing and storing everything together. No, it doesn’t work like that. If Truncated information and simple hashing is stored together, without a random salt, it may be easier to determine the card information through common sense brute force (please don’t talk about rainbow tables).

e) “They need me to be a level 4 certified gateway provider since I do less than 6 million transaction.” – In general service provider levels are only level 1 and level 2, according to visa and mastercard and amex. Secondly, the transaction levels for level 1 Visa and Mastercard are 300,000 volume, significantly lower than 6 million (which is for merchants). Amex has a higher threshold (2.5 million) but in general, we look at Visa/Mastercard since they are the most widely distributed.

f) “They insist on seeing a certificate of compliance – other documents are not allowed” – This has become so common that it’s painful. There is no such thing as certificate of compliance. These are all conjured up in the imagination of QSAs and PCI-DSS never issues certificates. It is technically as useless as showing your birth certificate to your bank. Yet, your bank insist upon it. FAQ #1220 of PCI addresses it below. So while it’s not wrong to issue certificates, but these are not considered “official documents”:

Because certificates and other non-authorized documentation are not officially recognized, entities that receive these documents to indicate their own compliance (for example, from a QSA or ASV) or another entity’s compliance (for example, from a service provider) should request that official PCI SSC documentation be provided. Any organization issuing, providing, or using certificates as an indication of compliance must also be able to provide the official documents. 

FAQ #1220

g) “Since you only transmit and process card data and not store, no need for PCI-DSS” – We get this a lot from banks. Technically if you transmit or process card data , you should be PCI applicable. However, since banks have a big say in your compliance (for instance they may force you to be level 1 compliant even if you have zero transactions), on the flip side, if they say they don’t need it, then well, you don’t need it. You could probably argue with them and say you actually do need it from a technical point of view, but most customers just take the bank for their word and move on. The bank has made their risk assessment, and if they insist we don’t need to be PCI compliant and gives a black and white stating they don’t need – essentially they (the bank) is absorbing all the risk of non-compliance, aren’t they? Remember – PCI-DSS is generally a contractual obligation between parties. If the bank says contractually you are not required for PCI-DSS, then what’s the argument? In this case, we usually advice our clients to still undergo a self assessment to ensure they are aware of the security practices and we then get a nod of wise agreement before they shoo us out of the room, never to be heard from again. If they had a trapdoor button that drops us into the Rancor’s pit, I guess they would have used that.

h) And finally, most recently – “they say the since we only store PAN and without expiry and CVV, they said PCI-DSS isn’t applicable to us” – this is a bit mind boggling since this bank was an international bank and we think they should know better. But that doesn’t mean local banks know less, we’ll take it back. It’s just that international banks, being exposed in so many countries, would probably have the mindshare larger than local banks to know more about these things. But this one was – “You don’t store CVV and expiry date? OK – no problem, just go ahead and store PAN for all we care! Yeay!” Granted, the use of card information without information like CVV, expiry etc may not be as useful, but there are still other ways for PAN to be used – identity theft for one. Or, it can be used in combination with other information they already have. Or they just want to sell it on the dark web. PCI-DSS puts a big premium on PAN storage, so much so saying, if PAN is stored, all other information must be protected. And oh – CVV is considered Sensitive Authentication Data (SAD), and no, it cannot be stored post authorisation for whatever reason.

There are a whole lot more of strange things we have heard over the years from banks and service providers but those are the main examples. Again, I do not think it’s due to them purposely misinterpreting the standard, but like that party game, once the message gets passed down the line so many times, eventually it’s just going to end up like garbage. It’s like how I had to deal with my wife’s instructions to buy stuff from the grocery. It’s sanskrit to me…I mean how many different pasta brands are there and why must we buy such a specific one? Pasta’s pasta, no?

If you need us to help un-garble PCI-DSS for you, drop us a note at pcidss@pkfmalaysia.com and let us get to it!

PCI-DSS Cheatsheet

As we approach the end of the decade, we are approaching 16 years since PCI-DSS was first introduced back in 2004. 16 years. That’s probably a full dog lifetime. I would imagine the guys back in 2004 would have thought: “Let’s just get version 1 out this year. I’m sure our next generation of brilliant minds will figure everything out by 2020.”

So now we are a few ticking days away from 2020 and yet, at the end of the line, I am still answering calls that are increasing as the days go by: What is PCI-DSS and how do we get it?

Most of these callers are generally calling because our names are listed pretty high on the internet when someone types in PCI-DSS Malaysia. Apart from that, a majority of these callers are calling because we were reference by one of our clients. We have faced different variations of callers coming in: Some requests us to provide them with a PCI-DSS ‘license’ in order to operate for their clients. Some requires a ‘certificate’, some are literally clueless as to what it is but their banks have mercilessly dumped this whole requirement to them.

Step 1: Who’s Asking?

First of all, take a deep breath, here is a simple cheatsheet. Whoever is asking you to be PCI-DSS, take note of it. Here are the Usual Suspects:

Bank – Very likely you are connecting to them doing some sort of payment processing like a payment facilitator, a TPA etc. Or you could be a service provider and your client just happens to be a bank, which brings us to

Customer – your customer for some reason is dealing with credit/debit cards, either directly or indirectly, and they require you to do PCI-DSS because you are servicing them or they have outsourced to you, like BPO, Data Center, hosting, call center, or even network transit

Internal – One of your internal managers have read up about PCI-DSS and decided that your company will sound very cool if you are PCI-DSS certified. Now, in this case, you could or could not be PCI. Because PCI is a contractual obligation dealing with credit/debit cards badged with Visa, Amex, Mastercard, JCB, Diners/Discover – if you don’t deal with this or have any clients dealing with it but your company just wants to get any standard out there – my suggestion wold be to go for something like ISMS (ISO27001) as that’s a better guideline rather than a contractual standard like PCI-DSS. If you still insist – well, you could still go through the SAQ but a lot of it will be not applicable to you since you are Non-CDE for everything.

Those 3 are mainly the motivations behind PCI-DSS. Why is it important to determine who is asking, is because of the next step:

Step 2: Determine your Level

Now there are guidelines out there for which level you should be at. If a service provider, then anything over 300,000 volume of card processing will bump you into level 1. For merchant, anything over 6 million for level 1 and anything over 1 million for level 2. I can’t count the times people get mixed up with Service provider levels and merchant levels. Even banks. I have banks telling our payment gateway that they are Level 4 . There is no such thing. It’s either one or 2. For merchants there are level 1,2,3 and 4 but the volumes are different.

Now while the guidance is cool and all, at the end it’s your bank or customer determining your level. If your bank decides to only deal with you if you do a full certification and RoC with a QSA, then even if you are processing ZERO transactions, they have deemed you as level 1. You can then decide to either say OK, fine, or tell them you are taking your business elsewhere. In that case, they may decide not to play hardball. I don’t know. Same as your customer. Your customer may decide you need to be assessed by a QSA, so it’s best you determine this with whoever is asking you.

The secret sauce is this: Most of the time, your bank/customer won’t have a clue what they want. They will just say, Oh, be PCI compliant. In this case, approach them with some tact. Your mission, should you choose to accept it, should be to avoid level 1 certification as much as you can, if your volume is low. It’s not justifiable. Look, if you want to be assessed by a QSA, by all means, but at least, know that you have a choice if your volume is low, and your bank/customer isn’t fussy about it. Just tell them: “OK, I’ll be PCI-DSS compliant, and I will fill up the Self Assessment Questionnaire (SAQ) and our management will sign it off and send it over to you. Is this OK?” If yes, then great, do your own self assessment. You can save up some money.

Step 3: Determine your Controls

This is probably the trickiest part of PCI-DSS. You see, being level 1 or level 2, self assessed or third party assessed, SAQ or RoC does NOT make any difference on what controls you need to have in place. An example: Level 1 compliance may require you to do ASV scans for 3 external IPs and 20 Internal IP Penetration testing. Guess what? Even if you are doing an internal self signed SAQ, you are supposed to do the SAME THING. No difference. No “Oh, since I am level 2, I will do ASV scans for 1 IP and maybe take 5 Internal IP for Pentest instead of 20.” In theory, all controls are the same, the only difference is WHO assesses and attests these controls.

Now, of course, realistically, this is not happening. Like I always illustrate, some companies consider a firewall as a wall on fire and they sign themselves off as PCI-DSS. Hence the whole passing the buck, passing the risk thing about PCI that I won’t go into discussion here. But in theory at least, same controls apply. But how do you determine what applies to your business? Well, based on your business flows of course.

Determine above all whether you are storing credit card information. If you are not, roughly 35% of PCI-DSS is not applicable (I am plucking that % out of no where, so don’t quote me). But a big chunk isn’t applicable. Second, determine whether you even interact with credit card or not. Look into all your channels. It could be complex like a call center, or simple like a network transit. In most case if you can determine that you have no access to credit card PAN or don’t store, and don’t process, the controls that are applicable to you are minimal. You should STILL be PCI compliant, but minimal controls apply.

Step 4: Determine your vendors and outsourcers

We had a client who cancelled an ongoing PCI-DSS with us because they have deemed themselves PCI-DSS compliant because they are using a PCI-DSS software. I cannot count the number of times I have to correct them – NO. Just by using a software which is PA-DSS compliant or even PCI compliance (like Cloud) DOES NOT make you PCI-DSS compliant. Will it help? Sure it will, but can you piggy back on someone else’s compliance? No. You can’t. So either you go through PCI yourself, or stay non-compliant, but don’t say you are compliant when you are only using a software that is compliant. That’s like saying you are certified to fly a plane when you are a passenger of a plane flown by a certified pilot. Or something similar.

Get your vendors on board for PCI if possible. If they refuse you can still use them, but you now have to include their processes under YOUR PCI-DSS program. Why would you want to spend extra days getting your vendor compliant when there are OTHER vendors who already are compliant?

So there you have it:- When someone requests PCI compliant – first, review your options. There is no ONE way for PCI. Go with the least resistance – self signed SAQ if your volume allows it. That saves you a lot of time and money as opposed to getting a QSA to come in.

If you have any queries on PCI-DSS, drop us a note at pcidss@pkfmalaysia.com and we will attend to it right away! Merry Christmas!

The Criticality of Project Management

Project management over the years have gone through somewhat of a bad rap for technology projects, especially. They always seem like a luxury afforded by management, and whenever things go south in a tech project, the first stop for blame is always on the project manager. It’s a tough life. On one hand you need to appease the forces that hold the budget (the business) and on the other, you need to deal with a bunch of geeks who are talking binary stuff and whom you know would rather not have you in the room because you don’t talk tech as much as them.

We used to have a Project Management Office, receiving work from other large projects looking for business analysts, project leaders, program managers etc. It’s not cheap upkeeping these guys, what’s with their PRINCE and PMP certifications and their training and hours. The problem was also when the project ended, then basically we had to go look for other projects to take them on. It’s an expensive affair, unless you have a constant pipeline of internal or external projects to keep them busy. The thing was, we noticed project managers tend to stay as project managers. You couldn’t get them to go into tech audits, or develop software or do compliance work. At least, for the ones we hired.

In the past, Project Managers are fairly agnostic in terms of technical capability. They have a set of domains they are good at (whether they are good at telco projects, compliance projects, migration projects), but overall, the discipline more or less remains constant. Methodologies used by these managers include lean, SCRUM, Agile etc, or simply PMI/PMBOK guidelines, which some of our managers tend to gravitate to. But aside from this basic competency of managers, there is inherently a personality that project managers need to have. Leadership is obvious, decision making capability, the ability to stand strong when being questioned and able to communicate the project properly. The ability to pull people together, from technical to consultants to internal business, and yes, the inherent charisma that one must have to become a successful project manager. He or she needn’t be the most technical in the room, but they must be able to sniff bullshit and weed it out. Time, budget and quality are the basic triangles of forces that need to be met, and good project managers are aware of this.

Due to cost and lack of demand, we shuttered our PMO a few years back, but our guys still practice basic PM work in our compliance project, and in some smaller companies, we actually end up taking the informal role of the project leads. We wouldn’t call ourselves project managers, because not everyone who calls themselves project managers are actually project managers. However, for larger companies, we do defer to the project manager in charge, and in our time we have had some experience with some of the best in the business, and some of the absolute worst. The problem is because being a good PM or absolute garbage is so difficult to assess.

It MAKES A HUGE difference who you put as a project manager. It spells either success or complete doom to your project the moment you assign a good or a garbage project manager.

For a compliance like PCI-DSS, there are some specific traits a manager should have, as PCI is a fairly technical project. And most PCI projects tend to drag on past 4 months or so. Some even a year plus. It does require a fair bit of technical knowledge, persistence and goodwill to successfully manage the project. Here are some of what we observed, and having experience good ones, and the bottom of the barrel type of project managers, we can probably give a fair opinion of what are the points of success (between good manager (GM) and hapless manager (HM)):

a) Technical Capability

This is more of a trait than a skill.

The GM know they don’t need to be experts, but they also know they need to put their backs and time into understanding the whole thing and trying to absorb the technical matters of it. They would attend training sessions and they would ask very good questions. The hapless managers go: OK, everyone knows their spot here. Consultants, I will look to you to answer all PCI related questions. I am here to gather information for all parties, so I want everyone to come for every meeting we are going to have moving forward.

The hapless one basically just comes in, fires off a few questions on project matters, and then sidles down and constantly have a far away look in their eyes when we start talking about the project tasks and updates. Or glued to their phones or laptop, furiously typing out stuff with their brows knotted up. Their strategy is that everyone else will carry their own load so they don’t need to know anything technical because they are too busy with other more important things, like buying food for their cats online. Occasionally, they bark out some orders here and there but you can tell, they know jackshit. After 4 – 5 sessions, they are still clueless and that’s when they start losing grasp of reality, and if the consultants are not available, the whole project is stuck, and then they move into the stage of looking to blame people for their ineptitude. Oh yeah. We have had plenty of these experiences for sure.

b) Communication

This seems a given, and a good manager ensures everyone is on the ball and the scoreboard is known to all. They know how to manage downlines (the people that need to get things done), horizonlines (the peers who are managing other downlines) and uplines (the business or sponsors pressuring the project). This innate ability isn’t bestowed on the hapless one. The hapless manager’s basic modus operandi is to take whatever the team gives, and being questioned by uplines and peers, decide that they don’t know how to explain it and comes back to the team again to ask for more information on how to deal with the questions. There is a complete lack of awareness in these managers that they are unable to overcome. They are unable to argue their points succinctly and always give in when there is pressure. Because of their lack of skill and understanding, they have no clue what positions to take and often waste the entire project timeline by going back and forth hopelessly like grass (or lalang) swaying in the wind.

c) Responsibility

One of the true strengths of character is when things are not going right, the good ones take up the responsibility of the situation and face the issues head on. The hapless ones find a way out, and find a way to blame others. To them, it’s always someone else at fault and never them. This stems from their utter lack of confidence in the project, that the only way they can reverse the situation is by saying, “It’s not my fault.” They usually will turn to consultants, as they are external to the company, and seek to pin the blame on them. It’s tough, but it is what it is. Most companies, given the choice of an external party and an internal person, would side with their own regardless of facts.

d) Time Management

The LLB (Look Like Busy) Trait is a big problem with these hapless managers. Because of their lack of a), b) and c) above, they are running around like headless chickens, being pulled from one meeting to another, unable to resolve any issues properly. So their heads are constantly in their phones or laptops instead of properly leading the project. Firefighting, or looking to assign blame. You can also tell when they are not able to manage meeting times. Many times, we have received calls from project managers requesting either immediate meeting at their office, or to come onsite within the next day and they wail because we tell them we are either overseas or assigned to other audits and we can do a phone. Most don’t understand that (unless we are properly paid and engaged), we are not their outsourced compliance unit so they blame us for non commitment. We are their consultants and there is no service level that requires us to stay in the clients office all the time for their beck and call. Unless, again, if they pay us, but most don’t pay for consultants to sit down and wait for inept project managers to scramble around looking for ad-hoc meetings.

Because they are scrambling and blaming instead of working,these PMs now think they are utterly important because they are so busy, but the fact is because of the ineptitude, they are being forced to seek responsibility, communicate or have technical explanation of the project – all which they are unable to do. So it’s one excruciating, meaningless and useless meeting after another. It’s horrible to exist in that manner for a career, but we’ve seen this many times.

Once you solve a), b) and c), Time Management solves itself.

Bonus points: While this may not be always true, the way project managers approach meetings and projects can actually say a lot. If a PMP or PRINCE PM comes in, there is usually a methodology on the table, tools and actual project management software they utilise for reporting. They are able to standardise our reports to a point where it goes straight to the point and to what they know their uplines need to know. Some hapless PM comes in, not certified in anything, not having knowledge of any tools, software or methodology, but basically armed with an excel sheet they took from another project manager who took from another project manager who used it to make sandwiches. That’s how senseless we see some of these methods and tools sometimes an we just look at everyone across the table and everyone goes like: “What is going on?”

In conclusion, never underestimate the importance of Project Managers, especially in a long drawn project like PCI-DSS. While we have known some excellent ones in our time, we have also worked with yahoos out there that single-handedly managed to trainwreck projects. From this article, it may seem our experience is more on the latter, but the opposite is true – we have the privilege to have worked with some really excellent ones that have also helped us get better, over these years. They are absolutely precious resources in a project, trust me. It’s just that when we do face one or two hapless PMs, it stands out a little bit more because we are so used to working with good ones!

Yes, we have shuttered our PMO as an advisory a few years back, but we also recognise the need for great PMs that might be able to help us out in our projects. If there is any interest, drop us a note at avantedge@pkfmalaysia.com and we will get in touch wth you.

PCI-DSS and the problem of Email

When we first started with PCI-DSS many years ago, most of our clients were service providers – payment gateways, financial institutions, and two banks. They had their challenges – in some cases, their scope were containable (payment gateways) due to the limitation of locations – and in the bank’s cases, at least they understood the massive headaches they faced in getting their entire environment compliant (with ATMs etc all in scope).

We saw a shift over to service providers OF service providers – hosting companies, Data Centers, BPO, outsourced call centers etc. Their challenges were somewhat different – call centers especially, because of their central hub of connectivity – their telephony system, and another big problem: Email. Email issues in PCI are longstanding and absolutely difficult to resolve – and it reaches to most businesses – travel agencies, hospitality, healthcare, insurance and so on .

When email first came out in the late 60s and early 70s, I can almost imagine how excited the users were. I wasn’t born then. But I recall back in the Uni days, early days when IRC/ICQ first came out, the level of excitement we had in communicating with an actual human being a thousand miles away INSTANTANEOUSLY was so mind numbingly out of this world. Back then, we spend countless hours in the school lab, playing these text based dungeons and dragons online called Multi-User Dungeons or MUDs for short, and completely almost failing all our subjects in the process. But the excitement was there: communication.

In that sense, email is almost half a century old and is still going strong. Primary communications are still through email, for business and personal communications. Email was never built to be secure. In fact, like the wonderfully robust (but now phasing out) SMS, when it was first used, no one imagined it would become the backbone of world communication as it is today. Nobody decided back then: hey, let’s prioritise security! Hey, let’s ensure that nobody can tap into this email of ours and see our messages! Email was like the conversation in the bar. Anyone could be standing around you, or sitting next to you and listening in to your conversation — and it was ok.

Until now, it isn’t.

Well, at least from PCI-DSS perspective.

“Never send unprotected PANs by end-user messaging technologies (for example, e-mail, instant messaging, SMS, chat, etc.” – Requirement 4.2 (PCI v3.2)

Unfortunately, a lot of business utilises email as the primary channel for PCI information. Hotels we deal with, travel agencies we have worked with – call centers etc – email is sent with card data because of the convenience and the efficiency of the whole process. When we enter these environments and suggest them to look for alternatives to e-mail, we invariably face a force so strong, it’s like hitting the stone wall of Helm’s Deep: Business.

Try as we might, we often end up talking about how we can use email AND pass PCI-DSS.

Now, it’s not impossible. But by the time we are done, we are basically looking at something so extraordinarily difficult or so expensive we invariably end up taking the path of least resistance (and least cost).

But how would you have EMAIL AND PCI-DSS?

First of all, we need to understand that like water, email exist in many forms. Or rather many locations.

First of all, it’s on the endpoints. This is where the email containing card data is sent and received. So, you have data at rest. All endpoints, whether agents or cashiers, or call center workstations are in scope as CDE (card data environment). All endpoints need to have their data encrypted. You could opt for a full disk encryption, folder encryption or simply data encryption: either way, your key needs to be managed appropriately as well. If you allow devices like iPads or phones to access, you are in a world of hurt, because basically it becomes impossible to secure these devices.

The second form is in transmission. Because email isn’t point to point, it hops through multiple relays, and multiple routing points to get to where it needs to be. At any point of the journey, your email could be sniffed, or leaked. Thankfully, many email services like Office 365 is able to encrypt TLS1.2 on transmission. Obviously this helps a lot – but that’s still only on transmission.

The third form is on the interim server(s) – mail servers, relays or anything else in between before the message ends up in the recipient’s mail boxes. Whether you are running your own mailserver or using a separate provider’s, the challenge is the same. How do you ensure that the messages at rest, be it temporary or permanent, are protected?

Pretty Good Privacy (PGP) has been often offered as a solution by kindly QSAs to assist in this matter. The problem with PGP is numerous. One, it’s very old. And more importantly, it’s very difficult to use. To make it easier, some email clients had tried to simplify it, but in doing so may render it vulnerable to attacks (see the recent EFAIL attacks here: https://efail.de/). And what if we don’t send over our public key? Or forget to encrypt the communication? At best, it’s similar to the problem that QSAs have with the manual muting int telephony systems. In theory, it might work (if vulnerabilities are removed, and if users use text-based only encrypted messages), but practically is a different story. Even before the recent researches to PGP’s vulnerabilities, everyone basically knows that PGP doesn’t encrypt meta-data (the information needed to route email) – so subject lines etc are all visible. It may not look like much, but a resourceful hacker will find these information gold.

If PGP is not used – how about some of the recommended secure messaging systems like Signal or Telegram? The problem is that these are not email technologies and these have issues of their own. How do you filter out Signal? If you do receive Signal/Telegram messages on your phone, it brings your devices all in scope. How do you run a PANScan on your phone? How do you secure every phone device there as per PCI requirement?

So how do we use Email for PCI?

The only solution it seems now, is to have a PCI-DSS service provider for Email and to use them. As we don’t represent any service provider, we won’t list them down here, but a simple google search will give you some alternatives. Be aware though, to go through their AoC and ensure that their email service is fully certified. It may be likely as well for the QSA to request more information on the encryption and key management as well, as to whether keys are managed by clients on (likely, such as in the case of cloud services), managed by the provider, or they can provide a client-managed key cloud solution.

That’s only half the solution (if that manages to pass). The second problem you have is to limit the endpoints accessing the PCI compliant service as these are considered CDE. Now remember, everything connecting to the CDE becomes PCI scope. So for the rest of the organisation using email for other purposes or needing email on their phone etc (let’s call this corporate email, vs the secure email for PCI) – the corporate email needs to be segregated from the secure email. This means separate solution. This means separate emails for corporate and secure – in most cases, meaning separate email addresses. While theoretically you can split email through subdomains, the main domain still needs to accept the initial email before forwarding – so for instance if you want to have pcidss@mycompany.com come to your specific secure email provider, unfortunately, it will still hit the MX record (Mail Exchange) of mycompany.com, which means your corporate email gets into scope. It’s an endgame there. Once corporate email is in scope, it’s over. Everything else becomes impossible to be compliant.

So you need to have mycompany2.com for secure email. It doesn’t seem too difficult and it might be possible – but let’s say you have 10,000 agents or clients or service providers in the field – how do you re-educate an entire workforce to get them to resend? Remember, you can’t incrementally ‘migrate’ – i.e continually use the old email and then forward it over to the secure email – you need to completely move over to the new email service and shut down processing card on the old email. This means a lot of lost business, a lot of customer experience issues, a lot of complaints – all adding up to business issues.

After that, isolating receiving end points becomes an issue as well. All endpoints come in scope so depending on your business, this could be a secure room with only a few systems, or a distributed nightmare if you have 200 branches or outlets receiving these emails. This isolated segment is CDE, so anything it touches becomes NON-CDE in scope. Yes. It’s a nightmare. Any shared services will be pulled into non-CDE but in scope. If you want them to also use their corporate email, corporate email comes in scope. All endpoints subjected to full PCI controls. On top of that, most QSAs will likely require additional controls like data loss prevention to be present in the gateway or endpoints if let’s say the CDE systems are hooking on to another potential channel to send email (like the corporate email). Key management also comes in play for the full-disk, folder encryption at rest in the endpoints.

Overall, the massiveness of using email for PCI is difficult. I think the whole point that business wants to use email for PCI data is either the ease of use, or not changing the current way of doing business. Both are not on the cards – even if email is continually being used, the ease of use is no longer there for PCI. Also, the customer experience and frustration could be ten times worse that searching for another solution like secure repository or customer portal, or tokenisation or something. The amount of complaints foreseen in implementing new procedures, new techniques, new solutions etc – these are not just operational security nightmare, it’s a business nightmare. Plus your entire business becomes hinged on the service provider being PCI certified. What if they decided not be? Or they fail their next audit? Or they get acquired by a competitor?

If a business is willing to embark on the complexity of getting email in scope for PCI, a humble suggestion we have would be to look for alternate solutions and have them on the table as well. Because once everything is scrutinised and risk is assessed, then they would have the full picture of what they are dealing with.

For more information on PCI-DSS or any compliance or IT advisory, please drop us an email at avantedge@pkfmalaysia.com.

Penetration Testing and Vulnerability Scans

In our compliance services, oftentimes, we are tasked to assist our clients in security testing – either conducting those ourselves, or to verify previously conducted tests for compliance purposes. There are many occasions where clients decide to perform the scanning on their own, aside from the obvious option of engaging another party to do this. When we receive the test reports from our client to verify, that’s when the excitement begins.

The fundamental question we often face is, what should a penetration testing report look like? What does a vulnerability scan looks like? This age old question has been haunting PCI-DSS for years, so much so that the council decided to publish a guidance on this, found: https://www.pcisecuritystandards.org/documents/Penetration_Testing_Guidance_March_2015.pdf

It’s a good read, if not fairly simplified, but it seeks valiantly to answer the question of what is a penetration testing vs vulnerability scans. This is important, because in PCI-DSS, the latter needs to be done quarterly, while the former needs to be done annually. When you multiply that by the costs and number of assets in scope, we could be looking at a decision involving tens of thousands of dollars.

In the document, section 2.1 dives into this and attempts to seek a differentiation between these two. In the basic concept of penetration testing methodology, these two activities serve specific purposes, for instance in the activities of Discovery, Enumeration, Footprinting, Exploitation, Cleanup etc, depending on which approach you take. And while there are many ways to explain the differences, to summarise:

A penetration test can be a vulnerability assessment (or scan, we will use interchangeably for the sake of this article) and beyond, while a vulnerability scan is not a penetration test.

A Penetration test can be initiated with a vulnerability assessment. The result from the vulnerability assessment will be used by the tester to penetrate or perform a more detailed assessment to circumvent controls or exploit the discovered vulnerabilities. In the process, the tester will also use manual methods to “test” the vulnerable system and likely during this process of poking around, discover more vulnerabilities or loopholes in the system that may not be detected during the initial scan. In the presentation of the findings of a penetration testing report, typically the ‘Proof of Concept’ (POC) detailing how the vulnerability was exploited will be documented.

Vulnerability assessment is the process to find out known vulnerabilities by using an (oftentimes) automated method (such as scanning software or scripts) against the targeted system. The result of the scanning will detail down the vulnerabilities, the risk exposures and action that can be taken to remediate these vulnerabilities. There is typically no manual proof of concepts that is done in the penetration test. The objective of a vulnerability assessment is to discover and report known vulnerabilities, not to exploit them.

A penetration test will normally take longer time to complete, i.e. few days, considering the manual verification or activities that need to be carried out to ‘penetrate’ the vulnerabilities. A vulnerability assessment can be completed in a shorter time frame, depending on the size of scope and software installed on the target system and it can be run on automated or scheduled basis. In our vulnerability scans, we also refine the results further by eliminating false positives, such as a patch that might not have been applied, but other secondary controls like virtual patching are in place to mitigate the risks. In either case, these are different activities, and in PCI, we need to understand what is NOT Penetration Testing.

We once received a 250 page report from our client who proudly said this was a professional work done by an outsourced security testing company offshore. Surprised as such a tome, which we assumed must have excerpts of Tolkien’s Lord of The Rings in there for good measure – we went through it. We found that it was nothing more than a raw report of the entire software inventory of the entire scope of around 50 plus assets. Meaning it listed down in excruciating detail what are the software installed in each of these systems, the licenses the OS versions etc. It was nothing more than a dump of the system’s software and nothing more. Not even the courtesy vulnerability scan. We told our bright eyed customer that we cannot accept this, and while this is a good book to have in terms of detailing the software they have, it has nothing to do with penetration testing, or vulnerability assessment. From singing praises of the offshore company, he ended up throwing them invectives that would make a pirate cringe.

We do need to be careful. We are not saying that the entire industry is filled with such charlatans peddling so called pentest services for a song and giving you a report that only provides you with the figurative emperor’s clothing for your security needs…but we must be able to differentiate what is, and what is not, security testing.

If you have further questions on security testing, drop us a note at avantedge@pkfmalaysia.com and we can quickly assess your needs and advice you on your next options to take.

« Older posts

© 2020 PKF AvantEdge

Theme by Anders NorenUp ↑