2014; this was the year where PCI DSS really took off for many companies and organisations in Malaysia. More and more banks have pushed their merchants to be compliant and certified with PCI DSS. While a few merchants require Level 1 certification or Level 2 validation, a bulk of them will fall under Level 3 and Level 4 Merchants. That means a lot of ASV scans, and a lot of Self-Assessment Questionnaire (SAQ) Advisory. I was asked this question: why are these banks, who are traditionally so dormant and make corporate decisions slower than a crippled sloth, half blind and halfway to the grave, now have suddenly become so actively engaged in PCI DSS? Perhaps this is due to the pressure they get from the card brands – especially VISA and MasterCard.
After what happened to the infamous Target retailer during the 2013 – 2014 and other high profile hacks, card brands are now in caution mode and have become more stringent to entities connecting to them. This, in line with the new PCI-DSS V3.1 means that controls are more stringent and auditees are more frustrated. Like everything in PCI – it’s a top down domino effect – VISA insists on banks being certified – banks claim that they cannot be certified but they are in the process, and they in turn insist their third party processors or merchants be compliant. I call this ‘passing the buck’ philosophy. It’s an open secret that no banks in Malaysia are certified. They will claim they are compliant, the same way my 25 year old refrigerator is compliant to green and environmental friendly regulations. It’s not.
Because banks push this compliance downstream, this “passing the buck” effect has caused many entities to start actively looking in every direction to be certified or compliant because they don’t want to lose connection with the bank. Is it fair? As one of our merchant client bluntly puts it: “It’s like being blamed by tobacco companies for polluting the planet with our smoking.” While drawing in a long drag on his Marlboro Lights and looking wistfully into space.
Should banks be certified? Of course.
However, for them to get certified in a specified period of time is difficult due to their ever changing business nature and an overly large scope of systems, people and processes under PCI requirements. Therefore they will need more time to remediate all the gaps and guess what – one of gaps would invariably be getting their third parties (like my client with his Marlboro Lights) certified.
At the end, the service providers and merchants and payment gateways are forced to be more aware that PCI is needed for them to ensure the continuity of their business especially if it involves VISA and MasterCard. So why aren’t they getting certified?
The answer lies in the implementation cost. Smaller to medium merchants, emerging payment gateways who have limited funds, limited clients – they might consider that the cost of them to pay for any breach is lower compared to certification. For example the need for an IDS/IPS (Intrusion Detection/Prevention System), the need for a system logging server, the need to perform daily log review and review reports. All of these require either additional effort or cost in terms of time, human resource or investment to acquire new devices.
With problems, there will always be solutions. We are keenly aware not all clients can afford the expensive solutions such as having separate devices for IDS, FIM (File Integrity Monitoring), syslog and etc. Or to build a Security Operation Center ground up. We have crafted out different solutions to serve our customer’s needs, from providing an all in one system for compliance to even having them outsource their compliance headache to us. Yes, we love to transfer headaches from clients to ourselves. We call our solution PCI Panadol. Just kidding, but it’s a great name.
Our solution starts with this question: How do we get you compliant with the least effort, least time and least money possible – and to maintain compliance with these 3 LEASTS (effort, time, money)?
Overall, awareness of PCI DSS has grown a lot in Malaysia. PKF Avant Edge does monthly PCI Awareness training (HRDF Claimable) and we have served large clients through such training. As for implementation, it is just as important to know what is UNNECESSARY for PCI than what is necessary. It starts with the scope. Start right, and you might just cross the other side of certification and celebrate with a party. Start wrong, and you are looking at a very, very, very long journey with very little happiness in it.
For PCI scoping or advisory on how we can help you in your PCI-DSS journey, drop us an email at firstname.lastname@example.org or contact us at +603 6203 1888.
by Wafiy Karim, PCI Consultant.