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Category: IT Audit (Page 4 of 13)

PCI-DSS: Estimating the Effort

January 31, 2021 / / 0 Comments
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pci-compliance

One of the most often asked question whenever we have a first call on PCI-DSS would be: How much effort will it take? The other question would be, how much would it cost? Let’s take a look at the first question first.

Misconceptions aside, which we have written on (whether PCI is a training program, a certificate, a license, a subscription etc), effort dedicated to PCI-DSS has always been a question for clients and potential clients (and ex-clients) of ours. And I admit – it’s not an easy thing to get hold of. Because, like costing and pricing, there is so much variable. But we do have some common guideline one can take – especially when it comes to initial budgeting and estimation of effort. It’s common this is needed and although it isn’t all the time accurate, it at least provides you with some idea on how this PCI-DSS standard is approached.

Before we start – we assume that you will be undertaking PCI-DSS the proper way. We say ‘proper way’ as we’ve seen a few consultants or advisors out there that just tell our client that PCI-DSS is just sorting out documentation, and sell a bunch of policy and procedures templates for RM2K and say bye. That isn’t the proper way. That’s amounting to modern day charlatans. Or some other companies knowingly decide to do a self signoff when their controls are not in place, or have any clue what a firewall is, but still mark firewall reviews as “Compliant”. If you are planning to go down this path, good luck and God speed.

So now – the best way to look at effort is (like pricing) split it into two. This makes it less overwhelming when you are evaluating vendors, because like pricing (effort generally has a direct correlation to pricing anyway) – it can vary A LOT. We see companies that price extremely high and we see companies that price extremely low. For anyone in procurement without an iota of understanding in technical projects, it’s going to be very overwhelming. Just by looking at pricing or effort by itself on paper and not understanding what it is puts you into a position of comparing apples to oranges, or potatoes to durians. Making a decision to go for the lowest price (which is common practice in Malaysia) works if you are evaluating a product, because the specifications are standard. Not so much for PCI projects as they vary significantly. So here’s a break down for procurement who may have some challenges understanding the project. Again, this is a guideline we use to help our clients and there is no ‘standard’ approach to measuring effort for PCI-DSS.

The two main portions of PCI-DSS for effort estimation are:

a) Advisory/Consulting/Audit Services

b) Implementation/Technical Services

a) Advisory/Consulting/Audit Services

This constitute a few parts :

i) Scoping and Optimisation of Scope

This is a critical part of advisory. Scope is generally determined by the customer, but most customers have no idea what the scope is. The critical thing about scoping is that it’s easy to either miss out things to do for PCI-DSS, or to ‘over-do’ it. An example here of missing things out would be: “Oh crap, I didn’t realise we had 15 other servers in scope for PCI-DSS penetration testing, and now only 2 weeks left to the deadline.” An example of overdoing it would be: “We just purchased this wonderful DLP system for PCI-DSS for RM5 million and busted our entire technology budget for the next year and a half. Cool eh? What? PCI doesn’t mandate it? We could have other processes in place to address that control? Ooops.”

ii) Gap Assessment

Nobody starts from a zero. Well, at least that’s our experience. In some form or another, most companies already have controls in place. The purpose of this assessment is to find out how close these controls are to the baseline requirements of the standard – hence the word “gap”.

iii) Remediation Support and Pre-Audit

Not to be confused by implementation services. Remediation support is the advisory work that comes during the remediation. A lot of services will be done during the remediation period and it’s often quite overwhelming, even for someone with project management background. Evidences need to be collated and submitted in specific formats. Evidences also need to be validated first before submission, as evaluation of evidences for PCI is a key part of the whole program. Often times, this is missed out and clients just submit lock, stock and barrel whatever they have and cry foul when the whole batch is rejected and they run out of time. It’s critical for evaluation of evidences to be done properly and in a proper methodology, whether by milestone a’la Prioritized approach , or based on the QSA’s approach. A pre-audit is usually done as well to ensure clients are well and prepared for the final certification audit. This pre-audit acts like an internal audit review for ISO equivalent. A good consultant here should also provide monthly healthchecks to ensure the implementation isn’t go wayward. In fact, we spend almost 2-3 days a week with our clients onsite around a month before the actual audit starts to ensure they have everything in place for a successful audit.

iv) Certification audit and post audit

Cert audit is what the QSA does. After that, there may be a period of 2 -3 weeks to clean up whatever non-compliances found during the audit. During this time, the Report of Compliance is also prepared for level 1 clients. The process of RoC can take up to 4 – 6 weeks from the QSA, so be aware of this timeline.

b) Implementation/Technical Services

The reason this should be separated from the advisory/consultation portion is because this is actually done during stage a.iii above. It can be done by your vendor, but it also can be done internally if you have the resource. PCI-DSS doesn’t specifically require stringent standards to do services. We have customers insisting that PCI-DSS requires CREST certified penetration testers to pass. That’s simply not true at all. If you have qualified individuals (and this may not even mean they need to have certifications) who can demonstrate aptitude in doing testing in both usage of tools, experience and methodology, it’s considered acceptable, as long as they are independent enough and free from conflict of interest, for instance they shouldn’t be the application developers doing the penetration testing for the app. While it’s all fine and well to have an experienced company certified with a dozen certification to do testing, the baseline interpretation of PCI has always been agnostic to these specific certifications. So now you know. On the other hand, you also can’t just do the remediation services as and how you please. Firing up OpenSSL scanner and calling it a web application pentest won’t cut it.

There are a whole lot of other services here to be done – firewall reviews, patching, logging and monitoring, physical security, encryption, policies and procedures, web app testing, secure code review, SDLC, card data scans and the list goes on. There is a lot of work here, and how you estimate the effort should depend on what sort of gaps you get.

This is the hardest portion to estimate.

For Cert and Advisory, the effort is usually based on two factors:

a) Processes – is authorisation/settlement in scope? Is backend processes in scope? Is call center in scope? Is POS /ecommerce scoped? Is managed Service scoped? etc

b) Locations – is your DC/DR in place? Are branch offices scoped in? What about outlets (for merchants like retailers/fast food/oil and gas) etc?

The more processes in place for PCI, the more needs to be audited. The more locations, the more time. One may think, what about systems in scope? Wouldn’t auditing 10 servers vs 200 servers be vastly different? The answer is: it depends. Because technically, if you have a large amount of assets, we revert to sampling basis so we can still have a control of how many systems to audit. Some QSAs will deal with either 10-15%, but it really ranges depending on the distribution, the error variance, the type of systems, the standardisation of processes etc. So because of sampling, auditors and consultants have a measure of control over the effort required for large/small projects. Locations are similar, but locations oftentimes need a physical audit, so it’s not just remotely looking at screenshots or evidences, but actually going onsite – which requires time and effort.

For implementation/technical services, there is no sampling. A lot of confusion stems from clients thinking that implementation of controls are also on a sample basis. No. If there are 250 servers in scope, all need to have PCI controls (patched, pentested, secured, hardened). The auditor may select 20-50 systems from that set to review, but that doesn’t mean you just implement controls on 20-50 subset of the systems. So for implementation, the effort is directly related to how many assets/systems are in scope to implement. Furthermore, these should be broken down into

a) Services that can be done in-house – anything that can be done in-house, whether services or with products like logging and monitoring system etc

b) Services that require external vendors(like an ASV scan or any services you may not be able to do in-house)

c) Services that require product purchases or implementation – this is important as there would be effort for implementation, migration, testing. Somewhat similar to b), but there may be products you can actually implement yourself.

Putting it all together

Whew. That’s a lot of ground.

As you can see, the budgeting process can actually be:

Advisory/Cert Budget –> after gap assessment –> Implementation Services Budget.

Because only after the gap, would we know what we need to fix, right?

Unfortunately, procurement is often faced with the prospect of budgeting for ALL phases from the get go. This produces a lot of problems, and a LOT of variations. Procurement runs the risk (without them knowing) of getting consultants/QSA on board for advisory and cert and under-budgeting/over-budgeting for the implementation service. Any QSA/consultant worth their salt should be able to do ALL the services listed above under Advisory/Cert portion. Many QSAs only do certification only with a sprinkling of support. This is a problem because their involvement is often too late and because their price point is so low, they generally don’t do any internal advisory support, healthchecks etc. This is basically you get what you pay for concept.

As for the implementation – budgeting BEFORE knowing what is wrong is akin to giving medicine before having a diagnosis. So you could either give the right medication or the wrong one. A wrong one could be providing panadol for someone facing terminal brain cancer, or providing a liver transplant to someone having stomache from eating too much nasi lemak. Both bad.

Instead, procurement should give some standard guidelines as much as possible – number of assets estimated, number of locations, number of processes, number of firewalls, number of applications etc. The more information provided, the more accurate the effort is. Also, request for a breakdown of each, so at least you know if they quantity changes later, how much would it be more or less. Armed with this, it may be worthwhile to guestimate that the implementation cost if majority services are outsourced, would be around 1 – 1.5x the cost of the advisory. That is an extremely liberal estimate, but at least that’s what we see mostly.

We do have clients that insist on us passing them a ‘generic’ PCI cost without them providing us any information. I don’t know why. But mainly because they don’t know what’s happening. In this case, we just interpret the scope for them from an external perspective and make assumptions and send to them an estimate. But because of this, the effort and price range varies INCREDIBLY.

Remember – least effort doesn’t mean that PCI-DSS is being achieved. Because this isn’t a product, there is a huge amount of variation in effort estimation by different companies. Procurement needs to get onboard and understand the process and not just look and say – oh, why does this guy give me only 10% effort of yours? Because, Mr/Mrs Procurement, they are giving you 10% of what you need. Or, on the flip side, someone is giving you 200% more than what you need.

The next article, we will have a look at price points and see what’s really there to budget for in a PCI -DSS program. Before that, drop us a note at pcidss@pkfmalaysia.com for any enquiry and we will get back to you immediately! Be safe!

PCI-DSS: The AoC Problem

November 28, 2020 / / 0 Comments
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pci-compliance

Recently we were reminded once again why we constantly state that PCI-DSS must chuck away the Certification of Compliance for good. Not only it’s an unacceptable documentation to the PCI Council, but it presents a lot of problems for auditors and assessors, as well as organisations seeking PCI-DSS compliance evidence from their service providers.

Let’s go back to how PCI-DSS flows in the first place.

PCI-DSS applies to all organisations that store, process and transmit credit/debit card under the umbrella of Visa, Mastercard, Amex, JCB and Discover/Diner.

Requirement 12.8 further extends the need to manage service providers where card data is being shared, and where “they could impact the security of the customer’s cardholder data environment”. That word is key because many service providers we have spoken to retorts they are out of scope of PCI-DSS of their clients because:

a) They only provide infrastructure and has no access to card data

b) They only store physical copies of forms that are sealed in boxes and they don’t access it

c) They only provide hosting

d) They only provide customer service support

e) They only provide toilet cleaning services

Of the 5 most popular services above, only the last one, we can probably surmise, does not require PCI-DSS. The rest – not to say they are 100% applicable – would require at the very least a bit of scoping to determine if they are applicable or not for PCI. Such is the problem here.

Having established that even, say a cloud service provider that only provides IaaS, requires PCI-DSS, what is then the next problem?

We call it the problem of the AoC. Or rather, the lack-of-AoC. Or more accurately, the-refusal-of-service-providers-to-provide-AoC-since-they-already-have-the-Certificate-of-Compliance problem. Its a very long problem name, so we will just call it the Problem of the AoC.

The AoC is the Attestation of Compliance, which is basically a shortened version of the Report on compliance (ROC) or the Self Assessment Questionnaire (SAQ). So in ALL PCI-DSS Compliance, whether assessed by 3rd party or self assessed, there is an AoC. 100%.

This AoC will describe in summary what are the processes in scope of PCI-DSS AND services that are NOT in scope of PCI-DSS. This is absolute key. In Part 2 of the SAQ, it states the type of service and the name of Service included in the PCI-DSS compliance (below):

Right after that, we need to ensure there may be services being offered that for some reason is NOT assessed for PCI. An example here could be a company offering BPO services, but at the same time offering a payment gateway service. They could be PCI compliant for payment gateway but not compliant for their BPO – even though both would deal with credit cards. So we need due care in determining whether the service we are procuring from them is indeed, PCI Compliant.

This is very important. And the fact that most “Certificate of Compliance” actually does not state the scope of services under PCI-DSS, presents a problem for assessors.

We once had a very animated discussion with a large service provider providing a customer support application to our client that collected credit card information. The service provider insisted they are PCI-DSS compliant and they showed their ‘Certificate of Compliance’. The said their AoC is private and confidential and all of their customers have accepted their Certificate as proof of their compliance, which meant, we are obligated to accept it as well (according to their very animated representatives).

Now, we all know the Certificate of Compliance is as valuable as toilet paper (actually, maybe less, since toilet paper can sometimes be VERY valuable during the pandemic and panic buys) – so we insisted on them showing us their AoC. For the simple reason:

They offered the on-prem application to our client, i.e installed onsite to our client’s environment. Our client says since this application is ‘PCI-DSS’ compliant, we should not need to assess their application under Requirement 6 of PCI-DSS. Hmm.

This doesn’t sound right. The vendor kept insisting that PCI-DSS only requires them to show their Certificate, and that the information in their AoC are private and confidential and we have no right to request from them.

PCI-DSS is applicable to an environment, process and location. You can see these ALL clearly in the AoC. Not in the nonsensical and utterly useless Certificate of Compliance. Why we didn’t believe this was that, because the application was installed in our client’s environment, there shouldn’t be an instance where this application is “PCI-DSS” compliant. At most, they could claim an application to be PA-DSS compliant (or the new SSF compliant) – but that is also impossible as their application wasn’t a payment application related to settlement or authorisation – so it’s not eligible for PA-DSS! So how can this be ‘PCI-DSS Compliant’?

We were at an impasse. Because they refused to give their AoC, we refused to accept their Certificate of Compliance. They lodged a complaint, we stood firm. We were not going to pass our customer on the basis of some hocus-pocus documentation which was clearly NOT acceptable to the PCI council!

Finally, they relented, and gave us a redacted, valid AoC and telling us how wrong we were in insisting on this and we did not know what we were doing. But all we needed to see was the page above – where the scope of compliance was summarised. And in it, stated “XXXX Customer Service Cloud Solution”.

Cloud solution.

We asked the customer, did they subscribe to the cloud solution?

No, they didn’t. It was an on-prem. Installed, lock stock and barrel application into the VM managed by our client. In an environment and location secured by our client.

Wait, said the vendor. The on-prem solution is the same as the cloud solution backend they were using and have been assessed for PCI. So what was our problem? The only difference was that their ‘cloud solution’ was now installed on customer side, so this should still be acceptable.

So, well, that isn’t a cloud solution then, is it? I mean, if you have a secured safe and you put it into your high-security house, would that also mean you can put the same safe in the middle of Timbuktu somewhere and still have the same level of security? (No offense to Timbuktu, we are just using that as a reference…we should stop using it actually but oh well.) Wouldn’t the cloud solution also be assessed for its environment, processes and policies? Would this be the same on the customer end?

The point here, is that based on the AoC, we can clearly say that the PCI compliance isn’t applicable to the on-prem solution. So we still have to assess the application as it is, under Requirement 6, under the client’s PCI program.

This isn’t any ‘victory’ or whatever we can claim, but it is so extremely frustrating to waste so much time on matters that would not be any issue at all, if the problem of the AoC is resolved. Just HAVE THE AoC TO ATTEST PCI-DSS! And stop this Certificate baloney! Because of this, we end up behind schedule and we have to chase up again and again.

So, read the AoC thoroughly before you decide on a vendor/service provider – because the certificate they provide to you could very well be invalid to the services they are actually offering you. Insist on the AoC.

Drop us a note at pcidss@pkfmalaysia.com to know more about your compliance. We will respond to you immediately!

PCI-DSS:Say No to Certificates

October 31, 2020 / / 0 Comments

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 kerfuffle? 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.

Is PCI-DSS the most confusing standard?

June 24, 2020 / / 0 Comments

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!

Clarifying ASV Scans

April 3, 2020 / / 0 Comments

It has been a while since our last post but as we are getting back up to speed to restart our work, our email engines are churning again with a lot of queries and questions from clients and the public on PCI-DSS, ISMS, ITSM, GDPR matters. We even have an odd question or two popping up regarding COVID-19 and how to secure against that virus. I don’t know. It’s a multi-billion dollar question which nobody can answer.

So while all these things are going, the one relentless constant we are still facing is: PCI-DSS deadlines. Despite the worldwide pandemic, we still get clients telling us they need to get their certificate renewed, their ASV scans done, their penetration testing sorted within x number of days. The reality of course is a bit more difficult. For example, once you have tested or scan, how does one remediate the issue when we cannot even get onsite to do proper testing? What about the development team, or the patching process, or the testing procedures and change management that needs to be done? The reality is simply, due to the pandemic, DELAYS will occur.

One of the main concerns are ASV scans, because ASV scans need to be done quarterly, there may be actual issues in remediation delays that may cause the company to miss the quarter.

How do we overcome this?

The main step is to always check with your QSA on this. I cannot repeat this ENOUGH. An organisation undergoing PCI-DSS, no matter what your size, especially if you are undergoing QSA certified program (Level 1 or Level 2 SAQ signoff from QSA) – ENGAGE your QSA to assist you. The QSA isn’t just supposed to come in at the end of your certification cycle, start poking holes into all your problems and tell you – you can’t pass because you missed our your internal VA back in Quarter 1. Or state your segmentation testing is insufficient at the end of your certification cycle. Or tell you that your hardening procedures are inadequate, with 1 month left to your certification cycle. The QSA needs to be in engagement at all times – or at the very least on a quarterly basis. Get them to do a healthcheck for you – all QSAs worth their salt should be able to do this. The mistake here is to treat your QSA as just an auditor and not onboard them throughout your certification cycle. An example is in the supplementary document from the council “Penetration-Testing-Guidance-v1_1” shows the possible involvement of the QSA:

In order to effectively validate the segmentation methodologies, it is expected that the penetration tester has worked with the organization (or the organization’s QSA) to clearly understand all methodologies in use in order to provide complete coverage when testing.

Pg 10 PCI Data Security Standard (PCI DSS) v1.1

It’s essentially critical to understand the relationship the QSA must have and the involvement they have, especially in the scoping part of PCI-DSS. The problem we often see is there is a disconnect between the company and their QSAs in terms of scope, or expectation, or evidences, which generally leads to A. LOT. OF. PAIN.

For ASV scans, a QSA may also provide ASV services provided these are properly controlled that there is proper segregation of duties and independence within the QSA/ASV company itself.

However, we have also done many companies whereby we provide the ASV scan and another QSA does the audit. Or the other way where we provide the QSA audit, and ASV is done by another company.

There is one example whereby we were auditing a company, and the ASV scans were done by another firm. We have been engaged from the start on a quarter basis and we highlighted to them that their Q1 ASV scan isn’t clean. We got on a call with the ASV company and worked together to ensure that the next quarter, these non compliant items would be remediated. So even with Q1 ASV not passed, at the end as QSA we still accepted the PCI recertification. PCI Council addressed this in FAQ 1152 – “Can an entity be PCI DSS compliant if they have performed quarterly scans, but do not have four “passing” scans?”

Without early engagement of the QSA and ASV, there would be a lot of problems once the recert audit comes around. In this case we could set the proper expectation early in the cycle for the customer to address.

Another possible instance is whereby the ASV themselves can pass a quarter scan with non compliant findings with compensating controls. This procedure is detailed out in section 7.8 of the ASV program guide, whereby within the quarter scan itself, before the expiry of that quarter, compensating controls are provided and validated and the ASV is able to issue an acceptable report for that quarter. This is important, because QSAs like to see 4 quarterly clean reports, and they throw a tantrum if they don”t get what they want. So in short, for ASV scans, do the following in this order:

a) Remediate all and get a clean report for the quarter; or

b) If you have non compliant for the quarter, engage your ASV, provide acceptable compensating controls, and attempt (not influence) with the ASV to accept/validate these controls and provide a clean report for the quarter but documented under Appendix B of the scan report summary; or

c) If for whatever reason, a clean report cannot be provided for the quarter, work closely with the ASV and the QSA to ensure that at least the next quarter or quarter after next remediation is correctly done. This is tricky because once the quarter report is out, it’s out of the ASV’s hands and into the QSA – on whether they can accept these reports or not. You can hang on to FAQ 1152 – but remember, FAQs are NOT the standard, so you are essentially in the hands of the QSA.

Those are your options for ASV, if there are any delays. DO NOT, in ANY CIRCUMSTANCE, MISS Your quarterly scan. Missing your scan is NOT THE SAME as getting a non compliant report. Missing your scan means there is no recourse but to delay your certification until you can get your 4 quarters in.

Finally before we sign off – let’s clarify here what a ‘quarter’ means. Some clients consider ‘quarterly’ scans to be their actual calendar year quarter. No. It’s not. Essentially a quarter is 3 months of a cycle of 12 months compliance year. A compliance year is not your calendar year (it could be, but it doesn’t have to be). So let’s divide this into two scenarios:

a) Where the ASV scans are required for the compliance year

In the case – the compliance year first needs to be defined, and this is usually done by identifying the signoff date of your AoC. For example if the QSA signed off your certification on April 1st, then that is where your quarter 1 begins. April – June; July – September; October – December; January – March. 4 quarters. You need to perform your ASV scan within the quarter, resolve the issues, and get the clean report out. This is CRITICAL to understand. Because many organisation fail this portion where they do not even perform any scans for the first few quarters and only pick up their PCI-DSS again mid way through and everyone is like: “Oops.” So while drinks and celebration are in the works once you signoff the AoC – your quarter 1 has also begun, so don’t drink too much yet.

So know your quarters. Start your scan early in the quarter, rescans must be done after remediation, and in case you need compensating controls, you need to get ALL THESE DONE within the quarter. If you perform your rescans in the next quarter, you are doomed. You MAY perform the rescan in this quarter and the clean report comes out next quarter for the current quarter – but all scans must be done within the quarter itself.

a) Where we have NO clue when the quarters are

As funny as this may sound (in a tragic way), there are many instances where we (wearing the ASV hat) gets plopped into situations where the client HAS NO CLUE when their compliance quarters are. I don’t know why this occurs. When I request them to check their AoC, or their QSAs for guidance, some can’t provide it. This is as great a mystery as the Sphinx itself. We call these internally, ‘Orphaned ASV scans’. These are projects where we are given the IPs and just told to shut up and scan the IPs. In this case because we onboard all ASV scans with quarters to define when we need to remind our customers, or escalate issues if the quarter runs out – we generally just use the date of the scan as a reference for quarters. So for instance, we provide a clean scan on April 31st. Since they are orphaned scans, without a compliance year/cycle for reference, we use the date of the scan report itself – meaning this scan expires 31st July.

By and large, we are seeing less and less of these orphaned ASV scans issues. Because QSAs these days are more engaged with customers and their customer service has also improved, it’s rare we find a client who isn’t aware of these cyclical requirements. Most clients, not just the large ones, are serviced by QSAs who themselves are reinventing themselves not just as auditors coming in once a year to observe and audit, but provide separate, independent units/consultants to assist healthchecks and support as well to enquiries pertaining to clients.

And a final note on this article – when we refer to ‘QSA’ or ‘ASV’ – we mean ControlCase International (QSA and ASV), whom PKF have been working with for close to a decade. We are not their representatives nor partners, but as our vendor, we’re keenly aware of how they do their certification and we try to manage our projects according to their expectations. As to why we do not want to become QSAs ourselves, we take independence and segregation of audit and operations seriously, as accounting and audit is our DNA. An article has been written at lenght on this:
http://www.pkfavantedge.com/it-audit/pci-dss-so-why-arent-we-qsa/

So – drop us a note at pcidss@pkfmalaysia.com for any queries on ASV scans, PCI-DSS or compliance in general. And no, we don’t know how to solve the resolve the Coronavirus yet, but I hope we get there soon. Stay safe and stay well!

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