PKF AvantEdge

Month: July 2021

Do or Do Not – ASV for SAQ A

July 24, 2021 / / 0 Comments
pci-compliance

I would have thought this debate died out with the extinction of dinosaurs, but apparently, we are still at this subject in 2021. Still. Going. On.

So in the past weeks, there were some debate between us and some consultants as to whether the SAQ A requires an ASV scan or not. Our position was No. Their position was yes. So let’s look at it.

Now, keep in mind, we aren’t talking about best practice. We are talking about PCI-DSS v3.2.1 and what it says about ASV scans being mandatory for SAQ A. That’s it. That’s the statement. Now, debate.

There is actually no debate. This isn’t some sort of grey area, hard to explain, obscure rule in Sanskrit and written on the Sankara stones. This is just: Look at SAQ A, search for ASV, don’t find it. Thank you.

The ASV requirement is present in item 11.2.2 of PCI-DSS.

SAQ A does not have it.

So why do consultants still insist people do ASV scans for SAQ A?

There could be a lot of reasons, ranging from ‘guideline’, ‘best practice’ and so on. No doubt, having a scan (which isn’t expensive in any case) would be the least effort of security done by the merchant if they are hosting an e-commerce website that is redirecting customers to their payment processor once the “Click here to pay” is clicked. I mean, even if it has nothing to do with PCI, it may seem like common sense to have at least a scan done on your site to ensure it passes the very minimal requirement of security. So do we advocate an ASV scan to be done on any e-commerce site that deals with payment options (not necessarily payment data)? Yes, we do. There are many ways a site may get compromise. A coding error may allow data to be siphoned off, or passwords may be compromised. A re-direct may be vulnerable to man in the middle attacks; or even a total redirect to another page altogether where payment data is inadvertently entered. While the e-commerce site may be outsourcing the payment part to a processor, it still has the job of redirecting traffic to it.

Think of it as an usher (not the singer, but the job); where you enter into a dark auditorium, let’s say Royal Albert Hall to watch Ed Sheeran – and the usher takes you through this row of lights to what is supposedly your seat which you paid RM10,000 for.

When the lights come on, you find yourself in nice cosy room and in front of you someone who seemed to resemble Ed Sheeran but slightly off. His hair isn’t ginger and he isn’t as chubby as you see that guy on TV and he speaks with a slight Indian accent. And isn’t the Royal Albert Hall a HALL? Why are you in this room that resembles a glorified grandmother’s living room? You find out later that the usher had led you through the wrong Hall into a neighboring pub attached to the side of the hall and you are listening to the wonky music of Eddy Shiran.

The point is, the usher is pretty important in leading people to their seats. So as a redirect, even though you aren’t the main draw, you could end up leading your customers to Eddy Shiran instead.

But back to the main debate, whether it is required for SAQ A customers to go through ASV? No, it’s not.

However, there is always a but in everything. There are exceptions.

Some acquirers make it a point to state that they still require an ASV report even if merchants are going through SAQ A. That’s completely fine because the guidelines from Visa/Mastercard are just guidelines. At the end, the acquirer or payment brands may make individual decisions based on merchants, so it’s not written in stone. However, if there are no such requirement, we’re left to interpret the SAQ as it is, and it doesn’t state anything there.

Some may point out within the SAQ A under part 3a, there is a statement

ASV scans are being completed by the PCI SSC Approved Scanning Vendor (ASV Name)

Triumphantly being pointed out as proof of ASv requirement

Take note however, that above, under Part 3a, the instructions do state:

Signatory(s) confirms:
(Check all that apply)

the realisation that asv is still not needed for Saq A (or B)

Even under the title “PCI DSS Self-Assessment Completion Steps” of the SAQ:

Submit the SAQ and Attestation of Compliance (AOC), along with any other requested documentation—such as ASV scan reports—to your acquirer, payment brand, or other requester.

It does seem to be grappling at straws if this sentence was used to justify the requirement for PCI-DSS. “Such as” generally denotes an example, which may or may not exist or is required.

In previous requirements of merchants from Visa, there used to be statements describing merchant levels such as 

 * Merchant levels are based on Visa USA definitions
** The PCI DSS requires that all merchants perform external network scanning to achieve compliance. Acquirers may require submission of scan reports and/or questionnaires by level 4 merchants

And perhaps there is where the myth was perpetuated from. In recent times Visa has updated its site (https://www.visa.com.my/support/small-business/security-compliance.html) to reflect a better understanding, stating:

“Conduct a quarterly network scan by an Approved Scan Vendor (“ASV”) (if applicable)”

In conclusion, SAQ A and B do not require ASV scans. If it’s required by the acquirer then so be it. If it’s supposed to be done out of best practice requirements, so be it. But you don’t want to hear an ASV/QSA telling you that you need to do something that is above and beyond your PCI requirement without them pointing to something in the standards that states so.

Finally – for SAQ B, which usually applies to POS terminals dialing up to the bank for authorisation; we’ve even seen some consultants requiring the merchant’s website to undergo ASV, which has nothing to do with their POS Terminals. Why ASV the website? Don’t know. So the merchants go about scanning their website that hasn’t been updated since 2012 and wonder, what sort of nonsensical requirement is this from PCI-DSS that needs them to pay just to scan something that is built by an 18 year old intern who had left the company 10 years ago? You don’t need to. So don’t do it.

Anyway, that’s it for now. Let us know your thoughts or questions and send to us at pcidss@pkfmalaysia.com and we will get back to you ASAP. Now, back to listening to our Spotify for Eddy Shiran!

PCI Delta Assessments

July 16, 2021 / / 0 Comments
pci-compliance

Let’s start off by saying this isn’t a way for us to make light of the current situation by using the word ‘Delta’ here. We all know how dangerous and virulent the current strain of COVID is and this isn’t a matter of writing an article simply to get a search hit on that word.

That being said, this is a topic that seemed a bit obscure, even to us who have been doing PCI-DSS for more than a decade now.

So the question that can sometimes pop up would be: Great, we got our PCI-DSS certification now, everyone is celebrating and patting each other on the back. In 2 weeks time after our AoC/RoC has been produced, our product management rolls out a new Application XYZ which deals with credit card information along with a new environment, database, systems etc. Is this Application XYZ included in our current PCI-DSS certification or not?

It’s a good question. Because the fact is that many view PCI-DSS as a point in time audit, whereby the audit is done at a certain time and not over a period of time. One might argue that during the audit itself, sampling will be done over a 12 month period, therefore it cannot be categorised as a strictly point in time assessment. Regardless how you categorise it, at the end of the audit, there is the big result: a compliant AoC/RoC pair. Don’t get us started on the dreaded Certificate of Compliance or CoC, or CoC-n-Bull in our terms. Enough of that certificate nonsense. As for the AoC/RoC pair, the scope is stated clearly in it, defining the audit scope, the boundaries, the applications scoped in, locations etc. So this is great. When we get a new application onboard, we just add in that application into the AoC, right?

Right?

Unfortunately, at this point, the QSA will say, not really. Once the AoC is out, it’s out. Unless you want to re-do the audit or to recertify, then yes, that new application can be added in.

Now, we’ve faced such a situation before. And in fact PCI-DSS addresses it nicely at this wonderful piece of work: https://www.pcisecuritystandards.org/documents/PCI_DSS_V2.0_Best_Practices_for_Maintaining_PCI_DSS_Compliance.pdf

In item 3.10.3 it states:

Any change to the network architecture or infrastructures directly related to or supporting the CDE should be reviewed prior to implementation. Examples of such changes include, but are not limited to, the deployment of new systems or applications, changes in system or network configurations, and changes in overall system topologies.

PCI reminding us to stay focus!

So in this case, application XYZ falls under new application. The point of PCI-DSS is that, just because you deploy a new thing or new firewall or new application doesn’t mean you are no longer compliant to PCI-DSS. After all, PCI encompass the practice and process as well, so the council understands and advice that these changes be implemented into the PCI program and PCI processes ensures that this stays compliant. So in short, if you have application XYZ coming in, make sure the PCI controls apply to it and it will then be reviewed under the next audit and included into the PCI AoC of the coming year. Let’s just update the current Aoc and we all go home now, right?

Right?

But wait, you aren’t listening, says the auditor, you still can’t update the current AoC. The AoC is already fixed for that year, unless you want to do an audit. Again. Like a month after you have done and dusted your recertification audit for that year.

In most cases, these changes for our clients go through the maintenance cycle without and issue and the following AoC simply gets updated to include it. But what if the customer insist on having the CURRENT AoC updated? This could be due to requirements from their client, regulatory or what not. How do we put that application into the current AoC without spinning off the whole audit all over again?

In short, you can’t. You either wait it out for the next year audit OR you re-do your certification audit and nullify the previous one. However, this is where that little obscurity comes in. Delta assessment.

Now I’ve heard of Delta assessment for PCI, but it’s almost invariably related to PA-DSS (SSF now), PCI PTS, P2PE where basically, vendors who had completed, let’s say their SSF, can validate low risk changes to their application and do a delta assessment. In PTS, the delta is done by the PTS Lab, but for SSF, the SLC vendor can basically do a self attestation. However, we don’t see any such item or recourse for PCI-DSS.

Discussing with the auditors, we find that indeed, there are possibilities of a delta assessment to be done, although rare, and not exactly cost effective, since whatever the delta is doing, it’s would just have a short lifespan before the changes get swallowed up by the main PCI program once the yearly audit cycle rolls in. That’s why we rarely see this done. But I rarely see a tapir doing a jig in a tutu, but that doesn’t mean it doesn’t exist.

So what happens is that the auditor will formally audit this application and its environment and go through the certification process as would normally be done – except that this is limited to the application and systems. Once assessed, a formal delta AoC/Roc pair is released to supplement the existing AoC/RoC pair. And so that’s it, these supplement documents can then be shown together with the current AoC/Roc for verification purpose and in the next cycle, it’s consolidated back into the main RoC.

Now, this is fairly new to us. The logic of it is still beyond us somewhat because the whole point of PCI is for an environment to be able to handle changes and not have it audited everytime there is a significant change that occurs. Because every audit is costly and I’m sure every organisation has already got its hands full trying to sort out budgets during these times, without worrying about delta assessments.

The above is basically what we gather from discussions with auditor and not really from experience, because at the end, once the proposal was put out, our client thought better of it and decided not to pursue. So really, it’s still in the realms of theory and we may not be accurate in our assumptions. However, it’s still something interesting to keep in mind, though rare – like the tapir in tutu – it helps to know that this option does possibly exist.

Drop us a note at pcidss@pkfmalaysia.com and we will try to address all your concerns on PCI or other compliance matters like ISO27001, ISO20000 etc!

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