Tag: pci council

PCI-DSS v3.2 is officially published

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After some back and forth on the draft versions, PCI v3.2 is now officially published. You can go ahead and download it here, and click on the nice little link saying 3.2 and agree to all sorts of terms and agreements nobody ever reads about.

Anyway, a little bit of background on this release. Usually, versions for PCI are released in the later stages of the year in November. In fact, even I mentioned this to a few clients that version updates were done in November, until PCI recently announced that v3.2 is to be released in March/April timeline due to a few factors as described in this article. So yeah, now I need to admit I was bamboozled. PA-DSS v3.2 is likewise to be released sometime in May or June.

So here’s how it works: 3.2 is now officially effective. PCI v3.1 will be retired end of October 2016 (basically to allow everyone to sort of complete the v3.1 if you are already in the final stage of completing it). So all assessments/audit that occurs AFTER October will be version 3.2. This is important to note, because if any gap assessments begin now, and has a timeline to complete AFTER October, you want to use 3.2. For ongoing projects, it is best we scurry and get it all done before October! Chop chop!

There is a bunch of ‘best practices’ that will become requirements by February 2018. Other dates you need to be aware of:

a) June 30, 2016 – for companies not migrated yet out of SSL/early TLS, you will need to have a secure service offering (meaning an alternative service utilising TLS.1.1 and above. I will go out on a limb here and suggest to use TLS1.2 knowing how volatile PCI guys are in changing stuff).

b) June 30, 2018 – SSL/early TLS becomes extinct as far as PCI is concerned. No more mitigation plan! The exception is on POS terminals that has no known exploits.

c) January 31, 2018 – This is the deadline where new requirements graduate from being ‘best practices’ to ‘mandatory requirements’.

OK, now that’s out of the way, here’s a snapshot on the main stuff of v3.2 and what we are facing:

a) New Appendix A3 covers the Designated Entities Supplemental Validation. This basically means that if any acquirer or VISA/Master deems that a service provider needs to go through ADDITIONAL requirements on top of the torture they have endured for PCI, they can. These victims could include companies making ridiculous amount of transactions, aggregators or companies that are constantly breached. So PCI has a whole bunch of extra stuff for you to do, mainly to deal with BAU activities, incident response, documentation and logical access controls.

b) Additional cryptographic documentation – Service providers are not going to enjoy this. We will now need to formally document the protocols, key strength, cryptoperiod, key usage for each key and HSM inventory. This should technically be done anyway in your key management procedure document, but now its a requirement. Take a look at NIST SP800-57 for the key concepts to get you started.

c) 8.3 is significant : Multifactor login. Whereby previous versions stated that 2 factor authentication is required for remote access from non-secure networks, now 3.2 shifted this requirement to “all personnel with non-console administrative access, and all personnel with remote access to the CDE”. Wait, what? This means, even if you are accessing an administrative UI or page (non-console) from a secure environment, multi-factor (2 factor is good enough) is required! I think there would be some pushback on this as this requires a fair bit of effort. We have until February 2018 to implement this.

d) Another big one is 11.3.4.1 – segmentation PT now needs to be done every SIX months as opposed to a year. This is not good news for some clients who have segments popping up like acne on a pubescent face. That’s quite a lot of work for them to do and this might give them more cause to think of a completely isolated network just for PCI-DSS with its own link and architecture, as opposed to sharing with multiple not in scope segments. Again, we have some grace period till Feb 2018.

e) New requirement 12.11 is interesting. I have always been an advocate to do constant checks with clients to make sure they are at least practicing PCI. We have this free healthcheck service every quarter for clients who take up our other services and we are checking exactly this: daily log reviews, firewall is clean, new systems are documented and hardened, incidents are responded, proper approval for changes etc. It’s nice to see that our efforts now have something formal tied to them. Feb 2018 is the deadline.

f) Here’s a downer. Appendix A2. We all know there was some sort of escape loop for those who were caught with SSL and early TLS in their applications. They created mitigation documents which may or may not be true. Just saying. Now, if you take this route, this is no longer a free pass for your ASV scans or vulnerability scans. If you have these protocols in place, your mitigation plan must fully address A2.2 requirements. If you are a service provider, take note of A2.3: YOU MUST have a secure service option in place by June 30, 2016! Not 2018. 2018 is when you stop using SSL/early TLS. So this timeline is slightly confusing. Like X-Men:Days of Future Past confusing.

Some main clarifications include:

a) Secure code training now officially needs to be done annually – you won’t want to guess how much push back I get on this when I tell clients it’s annual, and not something that is done when they have the budget for it (which is never).

b) Removing the need to interview developers to ‘demonstrate’ their knowledge – I do programming a bit, but I’ll be foolish to think I can go up against a senior developer who eats, breathes and … lives for coding. How awkward I’ve seen some younger QSAs struggle to do this (determining whether the senior dev guru is good enough), when its obviously not something they even know about. Let auditors audit and let developers code.

c) Finally, note added to Req 8 to say that authentication requirements are not required for cardholder accounts, but only to administrative or operational/support/third party accounts. We have always practiced this anyway but now its clear.

d) More clarifications on addressing vulnerabilities considered ‘high’ or ‘critical’. I am not a big fan of these. I think every vulnerability should eventually be addressed, just prioritised in terms of timing. Even if it’s low or medium, it’s still important to have a mitigating factor to it. There is a reason why it’s a vulnerability and not something you can sweep under the carpet.

e) A good note on pentesting in 11.3.4c – testing now needs to be done by qualified internal or external resource with independence. Again, we already practice this but it’s good that now it’s official.

So, that’s about it. Of course, there’s a fair bit more. I suggest you to poke through the summary of changes first and then go through the documentation itself.

Be aware of those dates! It’s all over the place (June 2016, June 2018, Jan 2018), and who knows these might change in the future. Have a happy compliance.

 

 

 

The Myths of the Top 10 Myths of PCI-DSS Part Two

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Continuing where we left off yesterday, let’s jump right into the next Myth

Myth 6 – PCI requires us to hire a Qualified Security Assessor

Technically true. Once again for merchant level 3 and below, SAQs are good enough to be compliant. Here’s how it works: merchants complete an SAQ, the management signs it off and they pass the Attestation of Compliance (AoC) over to whoever is asking – generally either the acquiring bank, or the payment gateway. Some of these SAQs are easy. Which SAQ you choose is a little bit more work. While we are not going into SAQ in this article, a quick comparison of SAQ A (mainly for Ecommerce merchants that outsource all processing functions) and SAQ D-MER (generally for merchants who store, process and transmit card data): 14 questions for SAQ A vs 326 questions for SAQ D-MER. That’s right. It’s 23X more work.

So while this Myth is generally true, for a merchant to undergo SAQ D-MER, most do not have the capacity to do it themselves, hence require expertise from either QSAs or consultants outside of the company. What about this Internal Security Auditor (ISA) option?

Here’s where it gets a little strange. In 2012 Mastercard released a statement stating:

“Effective 30 June 2012, Level 1 merchants that choose to conduct an annual onsite assessment using an internal auditor must ensure that primary internal auditor staff engaged in validating PCI DSS compliance attend PCI SSC ISA Training and pass the associated accreditation program annually in order to continue to use internal auditors.”

And

“Effective 30 June 2012, Level 2 merchants that choose to complete an annual self-assessment questionnaire must ensure that staff engaged in the self-assessment attend PCI SSC ISA Training and pass the associated accreditation program annually in order to continue the option of self-assessment for compliance validation. Alternatively, Level 2 merchants may, at their own discretion, complete an annual onsite assessment conducted by a PCI SSC approved Qualified Security Assessor (QSA) rather than complete an annual self-assessment questionnaire.”

What they effectively are saying is that Level 1 to 4 merchants CAN have an option not to engage a QSA, but the caveat is that for level 1 and 2, they need to be ‘validated’ by internal auditors. Not just any internal auditors, but auditors certified as “ISA”, by the PCI council. Yes, it’s a certification that is created to sign off SAQs.

If you do not have an ISA, you are stuck, and you will need a QSA to validate your SAQ. In most cases, having a QSA validate is as much work as having them certify the environment, so you do end up ‘hiring’ a QSA to validate it.

Why not all join in the ISA bandwagon then?

Well, you need to cough out around USD500 for the PCI Fundamentals course, then around USD3,000 – USD4,000 for the ISA course and then every year USD1,000 for requalification training fee. Only companies going for PCI-DSS can have ISA so if you are consultants like us, you are out of luck.

Large merchants probably might want to invest in an ISA. But note of caution, ISA is NON transferable. So if you are an ISA for Company A, and you move to Company B, your ISA status does not go with you. If Company B wants you to be their ISA, you need to go through the entire course again. Yes, even the fundamentals course again.

It is certainly less expensive to get an ISA to validate your SAQ compared to having an external QSA, so large merchants might opt to have one or two ISAs in their stable and invest in them yearly.

Myth 7 – We don’t take enough credit cards to be compliant

PCI likes to state, even if you take ONE credit card, you are supposed to be PCI certified/compliant. But honestly, unless that one credit card transaction is to buy a Bugati Veyron, the acquirer is likely not going to come knocking on your door to ask you to become PCI compliant. The theory is that everyone who deals with credit cards will happily agree to invest in time to go through the SAQ and 12 requirements. The reality is starkly different. Businesses have 600 different things to look into daily, and most business turn a blind eye to PCI as long as there is no burning platform or pressure from above. The card brands push the acquirers, the acquirers push the payment processors and gateways and large merchants, and the payment processors push their service providers. Somehere down the line, the little travel agency around the corner that collects credit card information, jots down the the PAN and CVV on a log book for recording purposes so they can book online flights in behalf of the customer, is overlooked. As long as there is no massive exercise to push everyone to be PCI compliant, there will be organisations that continue to operate outside the PCI requirements. Yes, your CVV will still be kept in a log book by that little travel agency – still oblivious to why storing CVV is such a big deal.

Myth 8 – We completed a SAQ so we’re compliant

Well – technically, you are. Again “being compliant” is not really an end state itself. How can anyone sustain compliance 100%? When Target was breached, they were just re-certified as compliant. Hence, the word compliant is generally just used as punchline for businesses. For instance – Ecommerce starts online payment system. They register with acquirer, acquirer tells them to be ‘PCI Compliant’. They finish their SAQ and submit. Acquirer is happy with the signoff and allows them to connect. Ecommerce proudly displays “PCI Compliant” Logo (which is not allowed, by the way) prominently on their website. They have actually successfully completed an SAQ and they are ‘compliant’ because the acquirer tells them that they are. If they are not compliant, they wouldn’t be able to connect. By the fact that this is allowed, shows that Myth 8 is actually true!

Myth 9 – PCI makes us store cardholder data

It’s true that PCI would rather you NOT store cardholder data. But this myth doesn’t make any sense. It’s not because of PCI that businesses shape their business processes after. It is because of the business processes, that there is a need for PCI. So, it’s up to the business to store, transmit or process cardholder data or not. Nobody goes into PCI-DSS saying, oh, because of PCI-DSS we now need to store data and need to invest in HSMs and key management, encryption etc. Because of PCI, we now need to have a payment business. I have never seen such a client. It’s always the other way round. Based on your business, PCI might or might not apply.

Myth 10 – PCI is too hard

This is the same argument as Myth 5. The PCI SSC makes a good point by saying, it’s good practice regardless to have controls in place, aside from PCI-DSS compliance. But the myth is here because they are actually stating PCI is not hard, simply because you should be practicing good security in the first place. To many, good security is hard! Turnover of staffs, zero day attacks, business as usual priorities, advancement of technologies, software and hardware being obsolete, pressure from management, costing issues, new vulnerabilities and exploits discovered (and not discovered yet) – and the fact that in the cybercrime world, the bad guys are miles ahead of the good guys – security is hard, make no mistake about it.

So there you have it. You would think with a post like this, PCI-DSS is a fruitless endeavor. Far from it. It’s an excellent repository of security practices that all organisations should consider. While some of the standards in there show their age (Anti virus, anyone? Please.), overall, it’s one of the more direct, implementable standards we have experienced (compared to the labyrinth we know as the ISO27001). The point of the post is to clarify that sometimes, standards in practice can turn out quite different from standards in documentation.

Now – should you check if your CVV is stored by your travel agency?

IPAY88 is now PCI-DSS Level 1 Certified

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Congratulations to IPAY88 for getting certified under PCI-DSS Level 1!

The PCI journey had been an interesting one. We did the gap assessment back in late 2013 and had to chase the compliance for 2014. The major roadblock was that first time PCI-DSS companies often underestimate the amount of work and type of audit required. A lot of companies make the mistake of treating PCI as how they treat ISO27001 (ISMS). These are vastly different animals.

For ISO27001, in general,  a lot of risks can be justified by management. The idea is to sense that there is a ‘management system’ in place. Not so much of a standard. If the management system claims that counting lima beans for customers in their data centre is an acceptable risk, then it is an acceptable risk. Of course, that’s an extreme example – the ISMS auditor still have a say in that obviously.

However, for PCI-DSS, its 300+ controls, in which if you decide that you want to store credit card data, then all of which will apply to you. There is no “Wait, my management accepts the risk of non encryption and storing PAN in a text file.”.

Precisely, the data here is not the company’s. It belongs to the card brands. From PCI perspective, its a standard that benefits only the card brands – VISA, Mastercard, Amex, Discover and JCB. This is the reason why we don’t have Business Continuity in PCI. PCI does not care whether your business can continue or not, it just cares that the credit card data is safe.

To IPAY88’s credit, they adjusted very quickly. They called us in midway into their remediation and we did a sweep of their infrastructure again and started to put their remediation program in place. Policies and procedures is one thing – but you have a whole lot of other things to do as well – penetration test, VA, firewall reviews, training, risk assessments, log reviews, HR review etc. We chased those down within 2 months and managed to hit the onsite audit in October, and successfully navigated the compliance by December.

A special thanks to IPAY88 management and PCI team for such a collaborative and great experience together! For more information of our PCI-DSS program, please email us at pcidss@pkfmalaysia.com.

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