Category: Technology (Page 1 of 9)

The Biggest (Real) Myths of PCI-DSS: Part 2

pci-compliance

So, continuing the Real Myths of PCI-DSS, lets move down the list.

Real Myth 5: All PCI-DSS services must be outsourced

Now, this is a very important myth to clear up. Because it directly relates to the usually biggest concern of all: cost. A while ago, we provided an idea on how to cost PCI-DSS, and break it up into certification/advisory costing and implementation cost. While the certification-advisory cost is easier to gauge based on locations, processes, card storage, activities covered , implementation cost is harder to gauge. Because number one – you don’t know your scope yet. This means, you may have 10 or you may have 200 systems in scope, you don’t know. Some go, “Ah but we know, because we have already decided our scope!” and we go, “Ah, but that’s the Real Myth 7, that you can decide your own scope…read on, intrepid adventurer of PCI!”

In any case, one way to cap a cost or save cost is to in-source your work, i.e have your own people provide the implementation services. There are no “PCI-certified” company to actually do the implementation services. All services – except for ASV scans – can be performed by your own, if you are qualified enough to do it (more on that later). I’ll throw in some services that for a typical PCI project, is a must:- Penetration testing, Internal Vulnerability assessment, secure code review and code training, patching, logging and monitoring and daily review of logs, card data scan, application testing, systems hardening, segmentation penetration testing, encryption, key management etc. These are fairly typical activities you will find in PCI – and you can do it all on your own if you have the resources and knowledge to do it. So, don’t feel cornered by any firms or consultants stating that these services must be done by them in order to pass PCI-DSS!

Real Myth 6: All service providers MUST be certified to do implementation services

This is an extension of Real Myth 5. So once the company decides to outsource the PCI services, in the case where they do not have the resources to do it internally – they go about requiring “PCI qualified” service providers to do these services. We’ve seen this requirement before where the requirement was to be a “QIR – Qualified Integrator and Reseller” to do services like penetration testing and code reviews and such. QIR isn’t created for that. QIR is created for implementing merchant payment systems and has nothing to do with the services mentioned. Aside from that, there is a growing call for PCI services to be only performed by “Certified Penetration Testing Companies” with CREST or individuals with certifications like Certified Ethical Hacker etc. Now, while these are all well and good, and certainly mentioned even by the PCI-DSS as a guidance in selecting your vendors, these are by no means a requirement by the standard. Meaning, the QSA cannot enforce all your testing to be done by the above said certified entities if you have ready, qualified and experienced personnel on your end to do it. Again – this doesn’t mean any Tom, Dick and Harry, Joe and Sally can perform testing or activities in your environment. The above certs and qualifications obviously carry weight and we should not dismiss the fact that if an organisation takes the trouble to go through CREST, versus a company that was set up two days ago, and employ 2 testers working in Elbonia – which you should prefer or which one will the QSA has less of an issue of – that’s pretty obvious. What I am stating here is that, we’ve seen many veterans who are far more efficient or experienced in systems testing and security testing than we can ever hope to be and for whatever reason, they don’t bother much about these paper chase or certifications.

At the end, the QSA may raise a query on who carried out the test and may choose to check the credentials of the testers, but in most cases, if the testing seems to be in order, most QSAs are OK with it.

Real Myth 7: PCI scope and application of controls can be determined by the customer

This one is my favourite. Because it played out like an episode of a slapstick comedy. I was called one day by one of our clients who had a new group handling their PCI-DSS program. You see, we’ve been doing their program for four plus years and we’ve been servicing them fine for years – but the new group handling PCI now isn’t well versed with PCI. It’s frustrating because no matter how many “knowledge transfer” sessions we gave, we still ended up with the same questions. We realised we were stuck in a Groundhog Day scenario, where things never change no matter what we do. The group wasn’t technical, which was an obstacle but overall, I think maybe they just have too many things on their plate.

So on this call, they said they were going to compare our quote to other providers this time around and I said, yeah, it’s fine. They then proceeded to give me a scope to quote and I commented, “Hold on, this is the wrong scope. This is the list of assets two years back. You have now changed your scope, and there is a new list of assets under scope for PCI.”

From there, the proverbial excretion hit the fan. They maintained how did I know their scope? I said, well, we helped you guys work it out. Your operations team is aware of it, that every year we help you validate your scope (as per PCI-DSS guidance). And they went: “Why must the scope come from you? We are the owners of the environment and the project, so we decide the scope!”

Aha. This is where our points diverge. You see, while the organisation does have the overall responsibility in setting the scope for PCI, PCI-DSS also has a guidance document “Guidance-PCI-DSS-Scoping-and-Segmentation” that defines how that scope should include assets and networks and therefore affecting how and where services should be implemented. So for illustration:

Company A says, “Well, we have a payment gateway and a payment switch business. We also have a call center and a merchant business that accepts credit cards through kiosks or direct POS acceptance in our outlets. Now, getting our merchant environment to be certified is going to be a pain. We have decided to just certify our payment switch environment which is isolated in a cloud, and not related to our payment gateway at all which we are just about to launch a few months from now, so there are no transactions yet.”

So there you go, Company A has set their scope and from the outset, it kinda looks fine. Yeah, if these are all isolated environment, it’s ok. In any case, in the report of compliance, the QSA would detail any services offered by the company that are NOT assessed, making clear what are the services NOT PCI compliant for that company.

However, what Company A cannot decide are the services and the assets involved in their scope. There is a method to scoping defined by PCI-DSS and we have written at length in this article here.   There are a few ways to minimise the scope by segmentation and so on, but for instance if you run a flat network and insist on it being flat, then everything within that network comes into scope – be it it’s your payment gateway, your merchant business servers, your call center laptops etc. So you can ‘define’ your scope, but what gets sucked into your scope to do hardening, pentesting, patching and all the PCI controls – that is already defined by the PCI on how it’s done. And we just have to identify these assets and systems and networks that get sucked into scope. PCI is a like a giant vortex or blackhole. Everything that is sitting on the same network or touches the systems in CDE, gets pulled into scope.

So there you have it. We will be exploring the final 3 Real Myths of PCI soon, but for now, if you have any queries on PCI-DSS, or ISMS or Theory of Relativity and Blackholes, drop us a note at pcidss@pkfmalaysia.com. Till then, be safe!

Alienvault: Working with Decoders and Rules

When we started out with Alienvault years ago, they were just a smallish, start up company and we worked directly almost with the engineers and sales team in Cork. Of course, a lot has changed since AT&T took over, but during the early days, there were a lot of knowledge and mindshare done directly between us and them. So much so that if you were to check their partner site, they still list us as the only Malaysian company as their reseller, due to the early days of listing. What attracted us to the product was that we could lift the hood and see what was underneath. Alienvault (or OSSIM) was previously a hodgepodge of many working parts that were glued together and somehow made to work. The agent was a product called OSSEC, which is an open-source HIDS. The IDS is Suricata/Snort and if you look closely at the availability tool, you would see the backend is a Nagios running. NFSen is used for their netflow data display, and PRADS for their asset discovery. OPENVAS is their vulnerability scanner and best of all, they allow you to jailbreak the system and go into the OS itself and do what you need to do. In fact, most of the time, we are more comfortable on the command line than through the actual UI itself.

The history aside, the downside of adding in these different applications and getting them all to play nice together, is that you would have to understand the interworkings of these pieces.

For instance, if you were to send logs via Syslog to Alienvault, you would have to know that the daemon rsyslog (not an Alienvault product) is the one being used to receive these logs. If you were to use the agent, then the application receiving these logs is different – it’s the OSSEC server that receives it. So it depends how logs come in, and from there you can decide what you wish to do with it.

The challenge is oftentimes to filter and ‘massage’ the logs when it hits Alienvault. There are a few approaches to this:

The basics are at stage 1 where the client (server, workstation etc) send logs (or have logs to be collected) to Alienvault. The initial filtering should theoretically happen here if possible. Many applications have the capability to control their logs – Windows server being one of them. Turning on debug logs on Linux for instance would cause a fair bit of log traffic across the network. Applications as well, have options of what to log and what not to log. We see firewalls logging traffic logs, proxies logging every single connection that goes through – this causes loads of logs hitting the Alienvault.

AV (especially the All In Ones) isn’t designed to take on heavy loads the way Splunk or other enterprise SIEM like ArcSight, that chews through 100,000 EPS like Galactus chews through planets. The AV approach has always been, we aren’t a SIEM only, we are a unified security management system, so security logs are what we are after. Correlation is what we are after. APT are what we are after. Their philosophy isn’t to overload and do generic Business Intelligence with millions of log lines, but to focus on Security and what is happening to your network. That being said, it’s no pushover as well, being able to work with 90 – 120 million events and going through 15,000 EPS on their enterprise.

The reality however is that most clients just turn on logs at Item 1 and plow these logs over to Alienvault. So it’s really up to Alienvault to start filtering these logs and stopping them coming in. At layer 2, is what we call the outer layer. This is the front line defence against these attacks of logs. These are where the engine running these log systems (OSSEC, rsyslog etc) can filter out and then trickle what is needed to Alienvault main engine itself in Layer 3. The AV main engine also has its form of defence, in policies, where we can create ‘junk’ policies to simply ignore logs coming in and not process them through the resource intensive risk assessment calculations.

So, we are going to assume that Layer 1 filtering wasn’t done. What we are going to look at is sorting out Layer 2 and we will assume that logs are coming in via OSSEC. We will have another article on Rsyslog filtering because that is a whole different novel to write.

When it hits OSSEC, it’s going via default port 1514/udp. Now remember, when logs first enters Alienvault, it doesn’t immediately go into the SIEM event display. It first needs to be logged, before it can be turned into events, before it can trigger alarms. So the basic rule is to get it logged:

Make sure you are receiving logs first.

This may seem juvenile in terms of understanding but we have been through enough to know that no matter WHAT the client says, oftentimes, their systems are not even sending the logs to us! A simple tcpdump -Xni eth0 “udp port 1514” will see if the logs are getting in, so go ahead with that first to ensure you are receiving. Just add a “and host <ip address>” if you need to filter it by the IP address.

Another way that Alienvault allows, when you are getting logs via HIDS/OSSEC is by enabling the “logall” on USM HIDS configuration, which we covered in the previous articles here. But be aware turning on logall potentially will bring a lot of logs and information into the box so we generally avoid this unless it’s really needed.

Once you are seeing logs coming into Alienvault, for OSSEC at least the next thing to do is to move these logs to “alerts.log” and from there, Alienvault can start putting it into the SIEM display.

For this to happen, you need to understand 3 things here, aside from the fact that we are currently now working on layer 2 from the diagram above – OSSEC:

a) Decoders

b) Rules

c) /var/ossec/bin/ossec-logtest

The above are actually OSSEC terminologies – not strictly Alienvault. What this means is that if you were to decouple OSSEC from Alienvault, you can. You can just download OSSEC. Or you could download other products like Wazuh, which is also another product we carry. Wazuh runs OSSEC (its own flavor) but has a different presentation layer (Layer 3 in our diagram above) and integrates with ELK to provide a more enterprise ready product but the foundation came from the same OSSEC principles. So when we talk about Rules and Decoders and using the ossec-logtest script to test your stuff, it’s not an Alienvault specific talk. Alienvault specific talk we can go later with plugins and stuff. In the actual ACSE course from Alienvault (at least the one I passed 5 years ago), there is really no mention on decoders and rules – it basically just focus on the core Alienvault items only.

At this point, we need to make the decision on whether to have the filtering done on OSSEC level (2) or on Alienvault level (3)? As a rule, the closer the filtering is done to source, the better…however, in our opinion, the filtering by Alienvault plugins is a lot more flexible and intuitive in design, compared to OSSEC (and because we are biasedly trained in Alienvault, but not so much in OSSEC). So for this article (which is taking VERY long in getting to its point), we are tasked to simply funnel the logs into /var/ossec/logs/alerts/alerts.log because that is where OSSEC sends its logs to and where we can get our AV plugins to read from.

The logs in /var/ossec/logs/archives/archives.log (remember, we turned on the logall option in the OSSEC configuration for this illustration) aren’t monitored by plugins. Because in a production environment, you won’t have that turned on. So, once you have logs into the alerts.log file, you are good to go, because then you can sit down and write plugins for Alienvault to use in the SIEM display.

OK – Firstly Decoders. OSSEC has a bunch of default decoders (like plugins in Alienvault) that is able to interpret a whole bunch of logs coming in. Basically, the decoder is set up with Regular expression to go through a particular file and just grab the information from the file and drop it into fields like IP address, date, source IPs etc. Similar to the AV plugin, but for this illustration, we are not going to use much of the OSSEC filtering, but simply to ensure we select the right logs and send them over to the alerts.log file.

So ok, let’s take the previous article example of having MySQL logs into Alienvault. Let’s say we have this example query log coming into our Alienvault (archive.log, if we turned it on)

2021 Feb 21 00:46:05 (Host-192-168-1-62) 192.168.1.62->\MySQLLOG/db.log 2021-02-22T09:41:42.271529Z        28 Query     SHOW CREATE TABLE db.persons

So the above doesn’t really offer much, but you can technically see there is the date and time, and the command line etc and a decoder will need to be created to parse the incoming log.

Picking up from where we left off at the Alienvault link, Task 4 covers the steps to create the decoder:

a) Edit /var/ossec/alienvault/decoders/local_decoder.xml and add in the following:

<decoder name="mysql-query">
        <prematch> Query</prematch>
</decoder>
<decoder name="mysql-connect">
        <prematch> Connect\s*</prematch>
</decoder>
<decoder name="mysql-quit">
        <prematch> Quit</prematch>
</decoder>

The above is simplistic decoder to catch the 3 important events from the logs coming in from MySQL – Query log, i.e

2021-02-22T09:41:42.271529Z        28 Query     SHOW CREATE TABLE db.persons

Connect Log

2021-02-20T16:35:28.019734Z        8 Connect   root@localhost on  using SSL/TLS

Quit

2021-02-20T18:29:35.626687Z       13 Quit  

Now of course, for those aware, the Query logs have many different types of query – Query Use, Query Show, Query Select, Query Set, Query Insert, Query Update and so on. The idea of the decoder is simply to catch all the queries, and we will theoretically log all Queries into Alienvault.

Now, remember to tell Alienvault you have a new decoder file

In the USM Appliance web UI, go to Environment > Detection > HIDS > Config > Configuration.

Add <decoder>alienvault/decoders/local_decoder.xml</decoder> after <decoder> :

Adding the "local_decoder.xmll" setting to ossec_config

Adding this setting enables the usage of a custom decoder. Save it and restart HIDS.

So that’s it for the decoder.

Now, on the CLI, go to /var/ossec/bin and run ./ossec-logtest

Paste the following “2021-02-20T18:29:43.189931Z 15 Query SET NAMES utf8mb4”

And you should the get result as below

linux:/var/ossec/bin# ./ossec-logtest
2021/03/29 09:50:10 ossec-testrule: INFO: Reading decoder file alienvault/decoders/decoder.xml.
2021/03/29 09:50:10 ossec-testrule: INFO: Reading decoder file alienvault/decoders/local_decoder.xml.
2021/03/29 09:50:10 ossec-testrule: INFO: Started (pid: 25070).
ossec-testrule: Type one log per line.
2021-02-20T18:29:43.189931Z 15 Query SET NAMES utf8mb4
**Phase 1: Completed pre-decoding.
full event: '2021-02-20T18:29:43.189931Z 15 Query SET NAMES utf8mb4'
hostname: 'linux'
program_name: '(null)'
log: '2021-02-20T18:29:43.189931Z 15 Query SET NAMES utf8mb4'
**Phase 2: Completed decoding.
decoder: 'mysql-query'

So basically, any logs that come into archive.log that has that sample line “Query” you will be lumping it in as mysql-query decoded. Of course you can further refine it with Regular expression to get the exact term you wish, but for the illustration, we want to catch the queries here and it’s fine for now.

The next item is the rules. Again, referring to the Alienvault writeup above, go ahead and edit
/var/ossec/alienvault/rules/local_rules.xml.

What we will do is to add the following in

<group name="mysql-connect">
<rule id="192000" level="0">
<decoded_as>mysql-connect</decoded_as>
<description>Connect log is enabled</description>
</rule>

<rule id="192001" level="1">
<if_sid>192000</if_sid>
<regex>Connect\s*</regex>
<description>Connection is found</description>
</rule>
</group>


<group name="mysql-query">
<rule id="195000" level="0">
<decoded_as>mysql-query</decoded_as>
<description>Mysql Query log is enabled!</description>
</rule>


<rule id="195001" level="0">
<if_sid>195000</if_sid>
<match>SET</match>
<description>Query set is found and ignored!</description>
</rule>


<rule id="195002" level="1">
<if_sid>195000</if_sid>
<regex>Query\s*</regex>
<description>Query is found</description>
</rule>
</group>


<group name="mysql-quit">
<rule id="194000" level="0">
<decoded_as>mysql-quit</decoded_as>
<description> Quit log is enabled</description>
</rule>

<rule id="194001" level="1">
<if_sid>194000</if_sid>
<regex>Quit\s*</regex>
<description>Quit command is found</description>
</rule>
</group>

So what the above does is to decide what to do with 3 types of MySQL logs you are getting: Connect, Query and Quit. We want to dump these logs into alerts.log so that we can work on it with Alienvault’s plugin. We don’t want to do any fancy stuff here so it’s pretty straightforward.

Each of these 3 have a foundation rule

a) Connect – 192000

b) Quit – 194000

c) Query – 195000

Each rule has a nested rule to decide what to do with it. Notice you can actually do Regex or Match on the rules which really provides a lot of flexibility in filtering. In fact, if it wasn’t for Alienvault’s plugins, OSSEC’s filtering would probably be sufficient for most of your custom logs requirement.

For this illustration, our job is simple – for each of these rules, find out the key word in the log, and then escalate it to an alert. An alert is created when you create a rule ID with level = 1, i.e <rule id=”195002″ level=”1″>

If you run ossec-logtest again, and paste the log there, you would be able to see

**Phase 1: Completed pre-decoding.
full event: '2021 Feb 21 00:46:46 (Host-192-168-1-62) 192.168.1.62->\MySQLLOG/db.log 2021-02-22T09:42:21.711131Z 28 Quit'
hostname: '(Host-192-168-1-62)'
program_name: '(null)'
log: '192.168.1.62->\MySQLLOG/db.log 2021-02-22T09:42:21.711131Z 28 Quit'
**Phase 2: Completed decoding.
decoder: 'mysql-quit'
**Phase 3: Completed filtering (rules).
Rule id: '194001'
Level: '1'
Description: 'Quit command is found'
**Alert to be generated.

Once you see “alert to be generated” you will find that same alert in the /var/ossec/logs/alerts/alerts.log

AV - Alert - "1613881201" --> RID: "197011"; RL: "1"; RG: "connect"; RC: "Quit Command found"; USER: "None"; SRCIP: "None"; HOSTNAME: "(Host-192-168-1-62) 192.168.1.62->\MySQLLOG/db.log"; LOCATION: "(Host-192-168-1-62) 192.168.1.62->\MySQLLOG/db.log"; EVENT: "[INIT] 2021-02-22T09:42:21.711131Z        28 Quit       [END]";

From there, you can go about doing the plugins and getting it into the SIEM.

Whew. That’s it.

You would notice, however, there is another sub-rules in there for Query:

<rule id="195001" level="0">
<if_sid>195000</if_sid>
<match>SET</match>
<description>Query set is found and ignored!</description>
</rule>

This is set above the “alert” rule and you notice that this is Level=0. This means whatever Query that is decoded, first runs this rule and basically if I see there is a Query “SET”, I am going to ignore it. I.e it’s not a log I want and I am not going to put it into the alerts.log. Level 0 means, not to alert.

I am ignoring Query Set because in this case, we are finding millions of query set as it is invoked a lot of times and mostly it is false positives. I am interested in Query Selects, Inserts and Updates etc.

Once you have this rule put in, it will filter out all Query Sets. This is basically the only filtering we are doing so we don’t have those millions of Query Sets jamming up my alerts.log file in Alienvault.

alienvault:/var/ossec/logs/archives# ossec-logtest
2021/03/14 12:36:33 ossec-testrule: INFO: Reading decoder file alienvault/decoders/decoder.xml.
2021/03/14 12:36:33 ossec-testrule: INFO: Reading decoder file alienvault/decoders/local_decoder.xml.
2021/03/14 12:36:33 ossec-testrule: INFO: Started (pid: 12550).
ossec-testrule: Type one log per line.
192.168.1.62->\MySQLLOG/db.log 2021-03-14T16:22:58.573134Z 19 Query SET NAMES utf8mb4'
**Phase 1: Completed pre-decoding.
full event: '192.168.1.62->\MySQLLOG/db.log 2021-03-14T16:22:58.573134Z 19 Query SET NAMES utf8mb4''
hostname: 'alienvault'
program_name: '(null)'
log: '192.168.1.62->\MySQLLOG/db.log 2021-03-14T16:22:58.573134Z 19 Query SET NAMES utf8mb4''
**Phase 2: Completed decoding.
decoder: 'mysql-query'
**Phase 3: Completed filtering (rules).
Rule id: '195001'
Level: '0'
Description: 'Query set is found and ignored!'

So you see, from the above, all Query Sets are ignored. You can basically do whatever you wish by using either Regex or Match and ignore certain log messages from OSSEC itself. It’s very powerful and flexible and with enough time and effort, you can really filter out only the needed logs you want into Alienvault, which is really part of the fine-tuning process for SIEM.

So there you have it. What you have done now is to take those logs from archives.log and make sure you only put the logs you want in alerts.log (Quit, Connect, All Query except for Query Set).

The next thing you need to do is to go down to Alienvault (layer 3) and do the heavy lifting in writing plugins and get these events into the SIEM display.

For more information for Alienvault and how it can help your compliance, send us an email at alienvault@pkfmalaysia.com and we will get back to you ASAP!

PCI-DSS: Estimating the Cost

Ah money.

This is how most conversations start when we receive calls from PCI. How much will it cost?

I think this is one of the toughest subject for PCI, because it really depends on what is being done by the service provider/consultant for you, and how much you can actually do the implementation of PCI-DSS on your own. And obviously it also depends on your scope, and on top of that, depends on compensating controls if any, or any current controls you have in place. And then it also depends on the validation type – SAQ vs RoC and so on.

So, in the classic riposte to this classic question, it would be “It depends”.

Where we really need to clear the air though is the myth that once you have done PCI-DSS the first time, everything gets easier on the renewals and everything gets cheaper year on year going forward. That is for another article. There is a lot of things going on in PCI-DSS, and if you approach it from a product perspective (like most procurement do), you end up either sabotaging your entire compliance, or getting an auditor willing to sign off on God knows what, and later on realise that you’ve been out of compliance scope all the while.

To start with the pricing, you should understand a bit on the cost of PCI-DSS. And we should start with the QSA, because after all they are the focal point of the PCI program. They are the Qualified Security Assessor. Of course, you can opt to do your PCI (if allowed) without a QSA involvement (Merchant level 3 or 4) and just fill up an SAQ with or without assistance from consultants; but for the most part, a QSA would be involved in the signoff for larger projects, and this is where the cost questions take life.

Lets look firstly at the base cost of becoming a QSA. It’s very helpfully listed for us here: https://www.pcisecuritystandards.org/program_training_and_qualification/fees

So here are the maths. Imagine you are a QSA with projects in Malaysia: to start off, you will need to set aside over RM100K just to get you qualified to to audits in the Asian Region. We’re not talking about Europe or Latin America or USA here. Just APAC. That’s qualifying the company. A company, to service any region properly will probably need a bunch of QSAs trained and ready, let’s say around 3 to start off with. Each QSA will need to go for a training costing around RM12 – 13K, so let’s say you have 3 (which is very few), you are setting aside around MYR 50K for that. On top of that, there are obligations such as Insurance Coverage that is specified in the QSA Qualifications Requirement document. So it depends on which insurance you are taking, but it could be in the region of around MYR6K or above premium (spitballing). There is a requalification each year as well.

QSAs then can make their own calculations on how fast/long they need to recover their cost, but let’s say they set aside 200K just to get things set up with 3 or 4 QSAs, then they need to recover that cost. A man day of a QSA/Consultant may range from quite widely in this region but let’s say you decide to price it at “meagre” MYR2K, depending on how senior you have, so overall, you would need to have almost around 1.5 months of engagement of their QSAs just to recover the cost of setting up shop. That’s why its not unreasonable to see higher rates, because of the cost it takes.

You have salaries to consider as well. You also have to consider if something happens to one of your clients, where you happily audited them remotely and believed everything they said, and found out that they have done jack-shoot in their actual environment and you have to handle the fallout of liabilities.

Some procurement compares QSA engagements to firewall engineers. No knock on other technical engineers, but the cost of getting a Checkpoint firewall engineer and the cost to maintain one QSA is a different proposition. I am not saying one is better than another technically (I’ve seen a lot of firewall engineers who could put any auditor into their place, due to their extremely proficient technical skills), I am stating the underlying cost behind the position, which is why PCI-DSS is priced at a rate that’s comparable to say, CMMI, as opposed to say, the ISO9001.

On top of just auditing cost, QSAs take into account the actual support they are giving year on year. Some of them unburden this cost to partners and consultants who have been trained (such as PKF – and there are also other matters such as independence of audit vs implementation advisory which we will discuss later), or some of them take it upon themselves. But you must know the QSAs job is not easy. Aside from auditing and supporting, there is evidence validation and report writing. Then there is the matter of undergoing the Quality Assurance process, which brings more resources/cost to the QSA company. All this while travelling to and from audit sites, reviewing etc – the life of a QSA (ask any QSA) is itinerant and often travel heavy. Burnout may also be a concern, so if the QSAs are involved in the day to day or week to week assistance to their client’s PCI program, this isn’t sustainable.

Understanding all these underlying cost will allow the procurement or whoever is evaluating to understand how to look at projects. If a QSA is pricing extremely low, the question you will need to ask is: What’s being offered? Because all QSAs have more or less the same baseline cost and if a QSA priced themselves at RM800 per man day, and they are a small shop with less than 5 QSAs, what would then be their recovery rate? 200 man days of engagement to recover their initial cost? Most procurement wouldn’t think of things like this and they would just go to their “BAFO” Best and Final Offering – but when you break it down on what is expected, then you would understand that not all PCI offerings are the same. I could simply quote a client 3 man days of QSA work for the final audit and be done. That would be the best and final offering that would win. But what about the healthchecks, the management of the evidences and how they are submitted, the quality checking, the scope optimisation process, the controls checking etc etc?

And in line with our effort estimation, one should also split the pricing into two: Audit and Consultation vs Implementation service and products.

Because if let’s say we find your Requirement 10 is completely empty, and you are thinking to purchase a QRadar SIEM to address it, you could be looking upwards of RM60,000 just to get the product in. Couple that with training for engineers, usage, hiring etc, and you are well over the six figure stage just for Requirement 10! How about testing and application reviews? If you don’t have the personnel on this, then you have to consider setting aside another RM50K etc depending on how many applications/mobile applications/ systems you have in place. So it’s highly essential to have the QSA/consultant assist you in scope reduction. Most may not view it that way, so it’s essential to find an auditor who is experienced and who looks after your interest.

Finally, understand that cost of audit/consulting would be different depending on how you go through PCI-DSS. Level 1 certification requires the effort of validating evidences, doing gap assessments and auditing and writing the RoC. Level 2 SAQ with QSA signoff is slightly easier, as there is no RoC to write while the last option of self signed SAQ without QSA is obviously a lot less costly as you are basically doing a self-signoff. Those are just broad guidelines and not how QSAs may price it, because as I say, due to variables.

You could opt to use the rule of 1/3 when it comes to estimating these costs, although your mileage may vary. For instance, if the QSA throws a RM100K audit fees (comparing it to CMMI fees) for a Level 1 Certification, then a RM60-65K (2/3 of the Level 1) for a SAQ Signoff could be reasonable; and furthermore if you just need them in for consultancy for the non QSA signoff SAQ, it could be 30K (1/3 of the level 1) or so. But note, the SAQ self signoff can be carried out entirely on your own, so the cost could be close to zero as well.

I know its a tough one to place this as pricing varies so often. We aren’t selling a product with specific hardware/software. We are selling a service that will take you through 6 months of work to cover scoping exercise, project meetings, changes, consultancy and advisory, pre-audits and post audits checks, evidence and artefacts sample validations, audit, report writing, training and all the variables in between.

Let us know if you need us to look at your PCI today, drop us a note at pcidss@pkfmalaysia.com and we will attend to you immediately!

ASV Scans /= PCI Compliance

There is an old story about a chicken and eagle. I hear this story being told by life coaches or motivational trainers trying to get through to our thick, jaded, technical skull that there is something more to life than coding and technology.

The abbreviated version is this: A farmer was walking and finds an eagle’s egg fallen out of the nest. He picks it up, brings it back to his farm, and puts it into the chicken coop. Soon, it hatches, and joins the other chickens in the farm and learns how to be a chicken, even though its an eagle. So this is where some of the version diverges.

a) The chicken and the eagle starts talking one day and the eagle notices another eagle flying high in the sky and he goes, “Dang, I wish I could be an eagle,” and his chicken-pal looks at him scornfully and says, “You are a chicken. How can you be like the king of all birds, soaring through the sky?” So the eagle keeps thinking he is a chicken and the next day he gets roasted for dinner. And the farmer finds his meat a bit tough and doesn’t taste like chicken at all. The moral here is: Don’t let your limitations inhibit you or you will end up a cooked and eaten. This is probably the original version before the other two came along below:

b) The farmer is visited by a naturalist who observes this ‘chicken’ and immediately knows he is an eagle. So he takes this chicken up to a high cliff, and throws him over, shouting: “Spread your wings and fly! Soar like the eagle you are meant to be!” And the eagle soars through the clouds and sky and become the king of all birds. The moral of the story: All of us are eagles, even if you think you are a chicken. All you need is a life coach or a motivational trainer to throw you off the ledge and you will soar. This is the preferred version for life coaches and motivational speakers. For obvious reason.

c) Same as story b) above, but instead of soaring, the naturalist throws the ‘chicken’ off the ledge, and it falls 100 feet and splatters its brains all over the bottom of the ledge and dies since it doesn’t know how to fly. And gets cooked and roasted for dinner. The moral of the story (and this is by far, our more preferred, realistic and risk-averse version): Don’t do something you may be destined for but not ready for. Or you will end up smashed, cooked and eaten.

All three versions have this theme in common: The eagle isn’t a chicken and the chicken isn’t an eagle. The chicken may have commonalities of an eagle, like wings and a beak, but just because it has those doesn’t make it an eagle.


Yes, I am aware that the anecdote above isn’t a very good illustration of the point I am trying to make, but I couldn’t think of a better one. And in a roundabout way, what I want to illustrate here is that ASV scans do not make you PCI Compliant.

We get this a lot.

A company would come and say they are PCI-compliant. Or we have a client who outsources certain portion of their operations to another company and that company comes back and shows us their ASV compliant scan and says this is all they need to show us. We (The auditors/consultants) are compelled to accept this because the ASV scans demonstrate their PCI Compliance, they say.

Let’s make a point here: ASV questions and subquestions in the SAQ D covers around 14 queries. Out of around 600. That means ASV covers 2.33% of PCI-DSS. There is a massive load of other controls and items covering PCI-DSS Other than those precious ASV quarterly scans. What about your patching? Hardening? Firewall security? HR policies? Logging and monitoring? Logical access? MFA? Hardening of systems? Anti-virus and host firewalls? What about service provider management? What about vendor default passwords? What about storage, encryption, key management? Software development? Application and penetration testing? Internal vulnerability scans? Training?

You can see how impossible it is to accept just the ASV report as an evidence of PCI compliance, much like how we cannot accept the chicken as an eagle, but yet, we are constantly berated upon that we don’t know what we are doing and that their Banks have accepted their ASV scans as a sign of PCI compliance, so we should to. But we can’t. We can’t accept 2.33% as a 100% of something. It’s simply mathematically not possible.

So there you go – banks. Why do banks perpetuate this myth that PCI compliance = ASV scans? Why? It’s 2.33% of PCI-DSS! You can’t accept something as an eagle just because it has wings and a beak! There’s really no argument about it.

Here is what 2.3% feels like:

a) The number of Jazz music of all US Music sales in 2013

b) Increase in slot machine spending in New Zealand in 2018 Q1

c) Auto parts industry against the US GDP in 2013

d) Android 6.0 Marshmallow installation for all Android devices in July 2016

e) Thats lesser than the % of freshwater we have on this planet (2.5% of water on the planet is freshwater)

I am sure there’s a lot of 2.33% out there on this planet, but the point we are making is this: It’s not compliance. It’s a small but important part of compliance but it’s not compliance. So no matter what your banks tell you, we can never accept the ASV scan as a sign of PCI compliance. It can be accepted as one of the evidences of PCI compliance amongst many, but not as an evidence of complete compliance.

Now, stop calling a chicken an eagle. Let us know about your questions for PCI or any compliance at pcidss@pkfmalaysia.com.

PCI-DSS:Say No to Certificates

For those who have been reading this blog long enough, you would know that we are absolutely, completely, mind-numbingly devoted to the anti-certificate movement within the PCI-DSS. Really. And every single month, almost, it never fails that we get enquiry that our customer or their acquirer are demanding to see the precious certificate of compliance. And rejecting the AoC. Rejecting the RoC.

It has truly become so farcical in PCI-DSS when acquirers – banks! – demand this of our customers. To an extent that even our customers give a wry shrug at us, the way my wife and I would shrug at each other when my kid tells us that he just witnessed an elephant doing hoola-hoops in a tutu in his kindergarten that morning.

We have written it before and will keep writing it till the horn sounds for the second coming: Compliance ‘certificates’ are NOT recognised by the PCI-SSC! PCI-DSS seals with those wondrous badges (like the police etc) are not recognised by the PCI-SSC. In the words of the council:


The only documentation recognized for PCI DSS validation are the official documents from the PCI SSC website. Any other form of certificate or documentation issued for the purposes of illustrating compliance to PCI DSS or any other PCI standard are not authorized or validated, and their use is not acceptable for evidencing compliance. 

PCI COUNCIL REMONSTRATING TO ALL PRO-CERTIFICATES TO STOP DOING THIS NONSENSE

So banks – please, please, for the sake of all that is good and worthy in our God given Earth – DO NOT demand your providers/customers/merchants to show the certificate of compliance. It’s ridiculous and it demonstrates that you, an entity that should know PCI first and foremost, are absolutely not doing your job well. You are making demands for things that are considered unauthorized and unacceptable!

We are not saying certificates are illegal or those peddling these certificates are cheating anyone. By far and large, all QSAs generally provide these so called certificates as an easy way to illustrate compliance, or just to have the customer frame it up and put it onto their wall. This is perfectly, absolutely fine. Even our QSAs do it. It’s not the problem with the QSAs putting these certificates out. The problem are with the acquirers or those demanding to see PCI compliance from their merchants/providers etc. Banks, financial institutions etc who refuses to see anything else but the ‘certificate’ as evidence of PCI-DSS compliance. It’s frustrating. Yes, most clients will be able to provide these ‘certificates’, but where it boils us up is when the acquirer refuses to accept the RoC and AoC as evidence of compliance! WHY NOT? Because likely the person in the bank requesting PCI-DSS have zero clue what PCI-DSS is , or what it’s supposed to be, in the first place.

Banks, here is a simple illustration:

Would you accept the below as proof of compliance:

Or would you accept the one below:

If you answer the first one, then the question is why do you reject the second one?

“Well because it looks fake and it looks like its scrawled by a two year old, or a random hamster running around on a paper with ink on its paws,” you reply.

Well, guess what?

Both should either be rejected, or accepted because both are of the same value. SAME VALUE. Just because one certificate isn’t designed as aesthetically nicer than the other doesn’t make it less of a certificate. Why? Because the baseline worth of the certificate is zero. There is ZERO value to the certificate on paper. The only value attached to it is from the viewpoint of the person looking at this worthless piece of paper and going, “Hum, that looks nice.” or “Hmm, that color looks off.”

I know this may sound like an over-reaction, because at the end, since Certificate of Compliance is now the norm (due to these demands) – everyone who has an AoC would probably have a certificate as well, right? Well, what about those doing their own SAQ? Do they design their own Certificate then and say this is a self attested cert? So, Mr Bank, how do you wriggle yourself out of this scaffafle? Why do you place so much value into something that (according to PCI SSC) is absolutely worthless, and do not focus on the actual documents that are worth something? And worse of all – to actually reject the documents that are formally from PCI-SSC and accept only these glorified certificates that are worth as much as the paper its printed on!

I think, the only resolution to this is to completely do away with PCI certificates. The next person touting these certificates as the only means of PCI validation, we are going to show them that certificate that’s drawn by the hamster and see what they say.

Jokes aside – let us know if you have any questions on PCI-DSS or any security compliance in your company – we are always willing to help out – drop us a note at avantedge@pkfmalaysia.com.

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