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Category: PCI-DSS (Page 14 of 20)

The SAQ Bs and how they apply to you

March 31, 2017 / / 0 Comments

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We always say SAQ As and Ds get all the glory and attention.

This is because a majority of our SAQ clients are e-commerce companies and therefore they apply SAQ A or A-EP depending on where their credit card information is collected.

However, recent times, we have been working on a well-known retailer and were told that SAQ D would be the one that applies to us. Now the SAQ was passed to them by the bank and the bank insisted that they do SAQ D-Mer.

Now this post is going to assume that you have some working knowledge on what SAQ’s are in PCI-DSS world. Self Assessment Questionnaires are one of the most misunderstood concepts in PCI. They are like Donald Trump’s foreign policy and the plot of Interstellar all mashed into one misunderstood mess. Often because acquirers find it so hard to understand, they just tell all their merchants that they should go for SAQ D.

Now we have fought for our clients before – where we overturned the acquirer insistence for one of our e-commerce clients to do an SAQ D-Mer, and instead got them to agree that an SAQ A-EP is sufficient. SAQ A-EP = around 140 questions. SAQ D-Mer = around 320 questions. Big difference.

Why is this important? We firmly believed in the concept of overdoing PCI is not a good thing. Why? Because our clients have other things to do and limited time and money to do these. Ideally, sure, everyone should go on Level 1 Certification. But the reason why the PCI Council created a whole bunch of ‘levels’ and then types of SAQs is simply because different businesses face different risks. It doesn’t make sense for a neighbourhood grocery that accepts 10 cards a month to implement the same million dollar controls as, say, Tesco or Exxon Mobil. So. Don’t overdo things, but don’t under-do it as well.

Back to SAQ Bs. So with this client, after talking to them a few rounds we found out that:

a) Their credit card terminals are separate and not integrated with their POS machines and connected via USB.

b) The POS machines are all connected back to the branch switch (let’s call it branch switch) and from there connects back to corporate HQ for reconciliation purposes

c) However – we found out that the Credit Card terminals have their own connectivity to their own ethernet switch (lets call it Credit Card switch) that connects to an ISDN router and directly to the bank.

This means, there are two flows – once the credit card is used on the Credit Card terminal, the card information is sent out directly via ISDN to the bank. Whatever approval etc that comes back, it will go through the USB to update the POS.

The crunch here is that NO CREDIT CARD information is ever sent back to the client’s environment. Everything is out through the bank environment – as the Credit Card Switch all belongs to the bank. It’s only located on the customer premise but the customer has no access to it – physical or logical.

So begin our argument with the acquirer, to overturn their SAQ D to SAQ B or B-IP. Let’s look at SAQ B criteria as per PCI document:

a) Your company uses only an imprint machine and/or uses only standalone, dial-out terminals (connected via a phone line to your processor) to take your customers’ payment card information;

Seems like it. Technically, the question here is whether a credit card terminal connected to a POS machine with USB is considered ‘standalone’. Our argument here is yes, as long as no credit card info flows through that USB connection and only approval/decline/transaction dollar amounts etc. Remember the USB connection connects the terminal to to the POS machine (a Windows box). Credit card info flows out the other way, directly to the bank via a circuit switched technology like ISDN (i.e dial out). For the millenials, ISDN used to be the granddaddy of broadband. If you have ever gone through internet connectivity era with normal dial up 14.4kbps, ISDN is like what God would send to us out of mercy and grace.

b) The standalone, dial-out terminals are not connected to any other systems within your environment;

Again, the argument here is ‘connected’. What does this mean? Is it through IP means, or even an RS232 connectivity is considered connected? Our reasoning is that this is USB connection and no card data flows through this ‘connection’ and we will use this reasoning once we get on the table with the acquirer.

c) The standalone, dial-out terminals are not connected to the Internet;

No they aren’t. They are on ISDN direct to the acquirer.

d) Your company does not transmit cardholder data over a network (either an internal network or the Internet);

No they don’t. In fact, no credit card info is stored, processed or transmitted anywhere in the customer environment. Except for the physical protection over the bank equipments residing on customer premise.

e) Any cardholder data your company retains is on paper (for example, printed reports or receipts), and these documents are not received electronically; and

They do have some credit card info on paper which they need to protect, but these are manual forms they need to fill out for refund process. And the process is dictated by the bank.

f) Your company does not store cardholder data in electronic format.

No, of course not.

So you see, except for the tiny word ‘connected’ in question b), our client does meet all the SAQ B criteria. It’s really ridiculous to have someone go through the entire SAQ D when they do not have card holder data in the environment they control. And what if they have 80 branches, each with 10 POS terminals and servers? That would mean 800 systems in all branches come into scope for pentest, internal scans etc? No wonder I hear some retailers using PCI as a cuss word these days.

So, we don’t know how this is sorted out yet, but we will soon, and perhaps that will constitute another post. For now, if you need any help with your PCI-DSS – SAQ or Level 1 certification, drop us an email at pcidss@pkfmalaysia.com.

Cheers for now!

PCI and Multi Processing Environments

March 31, 2017 / / 0 Comments

PCI

Since our last post, we have received some queries from other companies asking us about their PCI compliance. Just to be clear, we do not charge a fee for replying to your email and assisting you make sense of this compliance. We know how frustrating it is, and no, anyone that tells you that PCI is easy as 1-2-3 isn’t really letting you know the full picture. This is because some emails had been – “I have this question, but wait, if you are going to respond and charge me a fee, then don’t bother.” What are we, mercenaries? Yes we are a company requiring profits and not an NGO, but over the 7 years we have been involved in PCI, we have actually done a fair bit of advisory without charge, just to get PCI awareness out there into the market.

So, to save the trouble, I’ll put up a public post here to sort some of the questions out. This question, we have been getting a fair bit: What if the company has a multiple processing environment? What does this mean?

Let’s say, a retailer. It has a POS environment whereby they run standalone terminals connecting to the bank for purchases in their store. Credit card is used here – card present transactions. Then they launch their e-commerce site, which redirects all card non-present transactions to a PCI certified payment gateway, where the card collection page is hosted by the gateway.

You see here – there are two different channels for credit card interaction. The traditional POS, and the e-commerce site. Both are completely outsourced – one is direct dial up to the bank, the other to the payment gateway. So how do you deal with this?

You have two options – one is to do separate SAQs for both environments. Yes, you can. In the example above, doing an SAQ B for your POS environment and an SAQ A for your ecommerce environment (assuming you are level 3 or 4 merchant) should be able to suffice. The second option is to combine these channels into one SAQ. Once you do that however, you won’t be able to go through the ‘specialised’ SAQs. Specialised SAQs are like A, A-EP, B, B-IP, C, C-VT – meaning they have conditions in which you need to adhere to in order to use them. For instance for A, it says that this will only apply to merchants with card non-present business. And likewise for B, it has condition that you do not store card information electronically and is not applicable to e-commerce merchants. So when you don’t fall into any of these SAQ buckets, you end up with SAQ D-MER, which basically covers everything in PCI. But don’t worry, you a lot of the SAQ would be non-applicable in this case, and only those related to outsourced e-commerce and POS facilities would apply.

Now another related question, and one that I ended up having a 2 hour discussion with a client on = can an entity be both merchant and service provider?

The short answer is yes, you can.

An example would be a telco. Telcos generally have massive merchant business. They accept payments for their pre-paid, post-paid etc from end customers through e-commerce, POS channels etc. But the Telco could also support a manage services and hosting environment whereby other merchants are hosting their payment sites on. Then, now you have a service provider environment.

Or, it could even be within the same organisation, you have your merchant business of a payment portal, Mobile POS, or mobile app, connecting to an outsourced payment gateway. Suddenly you decide you want to set up your own payment gateway and channel all the transactions of your merchant business to your own payment gateway.

In the first instance, if you have separate environments and businesses isolated from each other – you can again opt for separate compliance. You could be a Level 3 Merchant filling up an SAQ B form, and also a Level 1 Service Provider doing an ROC with a QSA.

In the second example where your merchant business connects to your own payment gateway, it’s a little more complicated because in all likelihood, the systems utilised by both business would be common. In this case, isolation and demarcation of type of business is more difficult to attain. Assuming you are eligible for Level 2 service provider, you can technically fill that up and ensure that it includes your payment channels within that SAQ. If you are doing a Level 1, then similarly, the QSA would likely include your payment channels (previously what you would call your merchant business) into your service provider certification efforts. Otherwise, you can still opt for a separate PCI compliance program, whereby you fulfill your merchant compliance, and for your service provider compliance program you do it separately.

For the latter option, the advantage is that if you launch your payment gateway and you provide options for other companies (not just your own) to connect to you, your compliance isn’t dependent on your payment channels (your merchant business). You would treat your own payment channels as just another merchant out of many, that are connecting to you. The downside of this is that you would likely need a clear demarcation and separation of systems between your merchant and service provider business.

Again, there are many ways to skin PCI. The best way (on paper at least) is to get your acquirer on the table or your payment service provider to ask them what is applicable to your business. Unfortunately, around 99% of the time in this region, the acquirers aren’t too knowledgeable themselves and either give wrong information or just tell our clients to do a Level 1 Certification with a QSA.

As part of our job scope – we will assess our client’s environment and provide the options on the table, and in some cases even be present on the table in the discussion with their acquirer – to obtain a clear indication on how to move forward and what PCI options are acceptable.

As always, drop us a note at pcidss@pkfmalaysia.com and we will do our best to accommodate your inquiries!

PCI-DSS Logging in MySQL Community Version with MariaDB Plugin

March 18, 2017 / / 0 Comments

pci-compliance

PCI-DSS is a standard that brings to mind the famous sayings of Jimmy Dugan, the coach of an all-girls baseball team in the movie A League of their own (Played by Tom Hanks):

“It’s supposed to be hard. If it wasn’t hard, everyone would do it. The hard… is what makes it great.”

Well, at least the first part. Whether the banter of it making it ‘great’ is a different story. Most PCI-DSS sufferers will add the word ‘pain’ after the word ‘great’. And, one of the main pains for PCI-DSS is logging and monitoring. That’s requirement 10 for you. So much so that PCI-DSS recently released a document specifically addressing this issue here. So you will be faced with myriads of issues – from the simple to the hard: no we cannot centralise log anything, we do not have logging function in our application, we do not know how to do daily monitoring of our logs, we do not know what to log or how to log, we are all running on DEC VAX from 1974. So many reasons.

One of the challenge we recently faced with the client was that they were using MySQL community version. The challenge was how they can log administrator actions and security INSERTS, UPDATES etc in mysql community version? Logging is totally available in Enterprise, but not the free one – or at least not in its limited form.

Enter Maria-DB Plugin. Now before we go into semantics, MariaDB is an opensource database created by guys who created MySQL. It’s a fork, because MySQL was acquired by Oracle some time back and everyone was afraid that Larry Ellison might gobble MySQL up the way Galactus ate planets. The cutest story here is that MySQL was named after the founder’s daughter – My. And yes, MariaDB is named after his other daughter! But the first daughter’s name is “My”…so it’s like, “Yeah, this is My, My Daughter.”

Anyway. So what we are talking about here is not for them to install MariaDB, but to use it’s ‘plugin’ for MySQL. Make sure the QSA doesn’t get confused on this because ours did and we entered into the twilight zone of communications for a while where nothing made sense.

The Advantages of using MARIA DB AUDIT PLUGINS are:

So this article, we are going to explain on how we install the plugins in MySQL version 5.6.35 that is based on CentOS 7.

  1. Download the latest plugin from the links given above and you should see the download directory as below. Choose the latest version. We used server_audit-1.4.0.tar.gz. in centOS. We can use the wget command that is: 
    wget https://downloads.mariadb.com/Audit-Plugin/MariaDB-Audit-Plugin/server_audit-1.4.0.tar.gz
  2. Extract the tar file by using the command 
    tar -xvzf <file name>
  3.  Login into MySQL and locate the Plugin Directory of MY SQL using the command below 
    SHOW GLOBAL VARIABLES LIKE 'plugin_dir';
  4. Copy the plugin to plugin directory in MySQL based on your linux server (64 bit/32 bit). 
    • cp server_audit-1.4.0/linux-x86-64/server_audit.so /usr/lib64/mysql/plugin/
    • chown -R mysql.mysql /usr/lib64/mysql/plugin/server_audit.so

     

  5. Install the MariaDB Audit Plugin into the MySQL Server by this command inside MySQL 
    • INSTALL PLUGIN ‘plugin name’ SONAME ‘filename.so’;
  6. Once Installation is complete, we’ll start the daemon with the following command in the command line: 
    sudo systemctl start mariadb
  7. The command systemctl doesn’t display the outcome of all service management commands, so to be sure we succeed, we’ll use the following command: 
    sudo systemctl status mariadb

    If MariaDB has successfully started, the output should contain “Active: active (running)”

  8. Next, let's take a moment to ensure that MariaDB starts at boot, using the systemctl enable command, which will create the necessary symlinks: sudo systemctl enable mariadb
  9. Next, we’ll turn our attention in configuring the syslog FormatSet the Type of Action that will be log (within MySQL)
  • Connect: connecting and disconnecting to/from the server will be added to the log. An unsuccessful connect will be logged as a failed connect including the error code.
  • Query: full statement including the values will be logged
  • Table: Any operation on a table triggered by query will result in an event the MariaDB Audit Plugin can catch to log it directly
SET GLOBAL server_audit_events='CONNECT, QUERY,TABLE';

You need to have root privilege to be able to change the Audit Plugin variables.  With this changed we are ready to enable the auditing, which we now will do by using the following command within MySQL:

SET GLOBAL server_audit_logging=ON;

The full set of variables is found on this page: https://mariadb.com/kb/en/mariadb/server_audit-system-variables/

To make the changes to the configuration of the MariaDB Audit Plugin permanent, we now need to add these settings to my.cnf. This ensures that the same configuration will be used after server restart.

Under [mysqld] in my.cnf, add in

server_audit_events=CONNECT, QUERY, TABLE
server_audit_logging=On

There you go, now your MySQL is ready to face the scrutiny of the QSAs in your PCI-DSS compliance program!

Email us at avantedge@pkfmalaysia.com for any enquiries regarding this plugin or PCI-DSS in general and we will get back to you as soon as we can.

We ratted on Amazon Web Services (and made them change!)

February 28, 2017 / / 0 Comments

Just a funny post to include and which I was reminded of by a few of my clients asking this question:

“Can I put a logo on my website or in my marketing material to state I am PCI-DSS Certifed?”

Something similar to this, which we see all the time. It’s nice, it’s beautiful, it’s stately – it basically tells everyone that I have gone through hell and back.

PCI-DSS

Except. You can’t do that.

That is correct – you cannot put a logo like that on your website. Doing so will get you in trouble with the PCI-SSC, it’s basically infringing their copyright of their logo and they disallow it. Here is an article we wrote a while back that talks about this.

So what happened was, one of our clients insisted they can use it because they have seen it in AWS website. We took a snapshot of it and here it is

PCIAWS

You can see they have proudly displayed the Level 1 Service Provider logo of PCI-DSS ‘Compliant’ along with the nice and thoroughly aggrandizing ‘tick’ and an altogether unnecessary picture of a lock at the bottom. The only problem is that this logo is not endorsed by PCI-SSC and was probably created by their summer intern.

So we asked politely to PCI-SSC, why are you allowing AWS to use it and not our client? Is it because a certain Jeff Bezos is the most powerful man in the internet?

Their response was classic:

They are not allowed to use that logo. Unfortunately, we cannot police the entire internet, so we contact these firms as we learn of the logo use.

You are correct in your understanding of the article. We encourage you to refer your clients to this article when they question you.  And let them know we will be contacting this firm to have this logo removed.

We appreciate you bringing this to our attention.

Wow. That’s nice. The largest cloud provider in the entire known universe uses that logo and you cannot police it. This generally means, they don’t do any policing. At All.

I like the fact that they refer Amazon as ‘this firm’ as if AWS is some useless junk company in the outer fringes of Elbonia. I like that. It’s powerful.

So what happened? PCI-SSC like a chihuahua took on a T-rex and guess what? The T-Rex changed.

PCIAWS2

You can see now that the ugly ticked lock, illegal, summer intern designed logo is gone, replaced by another PCI logo. This time, this is a logo they can actually use because they are registered as a ‘participating organisation’. But nowhere in the logo does it state they are Level 1 certified Service provider.

We like to think, in our small and narrow mind, that we, an unknown security firm in the fringes of Malaysia AKA Elbonia to most of the world – made the mighty AWS change something on their website.

Such feeling of worthiness.

PCI-DSS Evidences: Your Type of Compliance

February 25, 2017 / / 0 Comments

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Since our last post, we have received some queries on how do we get PCI-DSS started. A majority of our clients are doing Level 1 Certification – this is where we come in and do a gap assessment, determine scope and then remediate and certify. However, lately we have been seeing more and more clients looking to do PCI-DSS on their own.

The question is: Can they?

Well – as with many questions for PCI-DSS, the answer is: it depends.

You see, the journey to PCI-DSS is different for different companies. Some need to go through the whole road. Some goes through just a little. Some need a third party to audit, some can do their own assessment…so while the standard is ONE, the ways to achieve it is MANY.

Now, enough of the philosophical babbling. Simply put: if you are doing PCI-DSS, you simply have 3 available options:

a) Third Party Certification

b) Validated Self Assessment Questionnaire (SAQ)

c) Self Signed Self Assessment Questionnaire (SAQ)

That’s it. You will fall into one of these buckets. If you fall under b) or c), you will then further have to wade through the types of SAQs: A, A-EP, B, B-IP, C, C-VT, D-SP, D-Mer, P2PE. Yes. They have a lot. But in general, your consultant or QSA should be able to tell you which one is right for your business.

Now back to the buckets. What’s a third party? No, it’s not literally a third party that you go to after your graduation and you are getting smashed. In audit terms, there are 3 kinds of audit – first party which is where internal auditors of the company audit themselves. Second Party which is where an external company with ties to the auditee company audits the auditee company – for whatever reason. It could be a supplier audit, it could be a due diligence audit before takeover, it could be a regulator auditing its regulatee etc. Finally a third party is a completely independent organisation auditing the company.

So the first bucket is a third party certification. This is where an external company called a Qualified Security Assessor (QSA) assesses your company and provide a Report on Compliance. This is where they will ask you to do a gap assessment, assist you through the ‘remediation’ period, and do the certification. What a lot of people don’t know is that actually, Merchant Level 1 also has an option to do a first party audit. This means they need an ISA (Internal Security Assessor) in their organisation who is able to sign off on the ROC. Of course, getting an ISA certified is another story, and in most cases, many just take the QSA route.

The second bucket is a Validated SAQ. This will not apply to Level 1 Merchants or Level 1 Service providers, and this is available for Service Providers Level 2 or Merchants Level 2 and below. Basically this means that theoretically, you can complete the SAQ that is applicable to your company and sign off and you are ‘compliant’. This also means any Tom, Dick and Harry who thinks that a firewall constitute setting an actual office wall on fire, can sign off on 1.1.4 (a) which asks if a firewall is implemented in your company. Seriously though. That’s why Mastercard has this caveat:

“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.”

Many, including myself, find this caveat extremely frustrating. To cut the long story short, Mastercard is simply saying for all Level 2 merchants you have 2 routes:

a) Do the Level 1 route. Get a QSA

b) Do your SAQ, but get the staff ‘engaged in the self assessment’ to be ISA certified. Now the first confusion is staff engaged in self assessment does not mean everyone involved in the audit. It basically means the one doing the assessment in behalf of the organisation and signing off at the AoC (Attestation of Compliance) of the SAQ. Whew! But still, now you need to get an ISA. It’s not cheap! And it’s also, to me, a really silly certification, but one that makes total Sen$e to the PCI-SSC.

In theory, option b) above is correctly still called ‘Self Assessment’ as it is still a first party audit in that sense.

Now the last bucket therefore is the truest first party audit. This usually applies to only Level 3 or Level 4 merchant, but sometimes we still find this existing in Level 2 Service Provider. Where the management say, “Screw it, let me sign it off and I don’t need any other signature on this” and the bank, customer or card scheme accepts it.

So this is the first step of your compliance – find out your type. Because you could be overdoing it (Level 3 Merchant doing a ROC Certification) or you could be underdoing it (Level 1 Service Provider doing an SAQ D). If you overdo it, it’s fine from PCI-SSC perspective, but your boss/stakeholders/board/customers might not be too happy when you have spent half the company’s budget and 8 months on the PCI program doing a full Level 1 RoC on all the 340++ subrequirements – and the vacation trainee points out that you only have to do a self signed SAQ A which takes about 1 day to complete. If you under-do it, likewise, you might be in an awkward position to explain to someone that your SAQ D-SP is not enough to convince your acquirer to start connecting to them, as they need a QSA signed ROC.

So how do we know?

Well – the easiest is to really, ask the ones who are pushing you for PCI? If you get the answer : “Ah, just get compliant!”, then you have more leeway to understand your business, and you might be tempted to just go for the easy way out. Don’t! Assess your business – if you are a merchant, then follow the number of transactions to determine which level you are at. Easy remembering:= 6 million and above for level 1, 1 – 6 million for level 2 and the rest level 3 and 4. I don’t differentiate 3 and 4 because there doesn’t seem to be a squat a difference to what you are supposed to do. It’s the same, they just classify it differently where level 3 is focused on e-commerce and level 4 is more on traditional transactions.

For service provider, it’s simpler. Level 1 is above 300,000 volume of card transactions and level 2 is below. There is no other levels for Service Providers. There is also only SAQ D available for Service Providers so you don’t need to think so much.

The next round, we will explore deeper into how do we get our scoping questions sorted out.

 

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