Category: PCI-DSS (Page 15 of 20)

Passing PCI-DSS: Evidence Checklist – Brief History

January 29, 2017 / pkfavantedge / 0 Comments

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We have been working on PCI-DSS since 2010. We started out as project managers for an offshore bank in Brunei that approached us asking for PCI-DSS compliance. At that point, we had invested a lot on training and getting our guys ISO27001 lead auditor certified because we saw a stable demand for compliance. We just banked on ISO and ISMS to kick off because of the directive of our government that all Critical National Information Infrastructure (CNII) needs to be ISMS certified. The reality though was slightly different. We pitched for jobs and saw precious few coming to us. Mostly, it went to agencies already incumbent, or agencies that knew how to get projects from government. We didn’t. We were new boys on the block and I remembered we were so desperate for business we drove all the way to Penang for a half hour meeting with a potential company only for them to say, Sorry we have already given the project away. Well, we did market that we had an office in Penang, so they probably thought we came to meet them from down the street. And not down the country.

In any case, in the middle of this desperate look for ISMS business, our customer in Brunei asked us for PCI-DSS. We didn’t really know anything about it, but we said, sure, let’s do it.

We called up some big QSA-Companies – Trustwave, Verizon being some of them. Verizon didn’t even bother responding to emails and calls. Trustwave did respond to my email – 5 months later. The only one that responded was a company called Control Case International. They called around 4 hours after I sent an email, and I was contacted not by their sales, but their founder, Kishor. He called me directly from the US and told me, let’s do this.

PCI is already a tough journey to begin with. We hear some QSA-C touting that it’s as simple as ABC. It’s not. And it’s not fair to say that it is because if it’s easy, everyone will be doing it. That’s not to say it’s impossible. With proper scoping, proper guidance, all companies can get certified with hopefully minimum fuss, stress and cost. Having local support and a responsive QSA is key. Local support doesn’t have to be a QSA. In fact, if possible, it might be even better to have non-QSAs and project specialists handling the local support. In our experience, QSAs are a busy lot and are often flying around on audits and working out other projects. Having a QSA handle your PCI initiative and remediation might not be the most efficient way as most meetings will be conducted either on a call or webex. PCI consultants are more than able to handle the remediation support because they are less caught up with ROC (Report on Compliance) writing and QA processes – which eat a significant amount of time for QSAs.

We successfully managed the Brunei project to certification and from there on, Control Case wanted to work with PKF for more Malaysian business. We started from zero clients to more than 30 plus clients today. Our goal is to push 50 by the end of this year. While we do work with Control Case, we remain independent as PKF does not have any influence over any report or opinion that Control Case has, and in almost all our projects, we work as project managers and technical advisors for our clients, not for Control Case. In that way, we are not part of Control Case, or in any way represent or partner with them and even in some cases, we work with other QSAs to achieve the same results.

One of the key areas we work with the QSA and customer on is the evidence collection. Evidence is a key ingredient to your PCI success. We call it audit artefacts – proof that controls are in place. It might be a simple sample of change management tickets, or a more complex sample of 12 month logging of your database – in any case, these are the bedrock of your PCI journey. Without solid evidences that key controls are in place, passing the QSA’s Quality Assurance is going to be very difficult.

In the next few articles on PCI, we will share our evidence collection methodology, our 95 checklist of evidence and sampling on how to get these evidences sorted out for you to succeed in your PCI certification journey.

PCI-DSS and the Retailer Conundrum

October 18, 2016 / pkfavantedge / 0 Comments

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Over the past six years, we have had our share of PCI-DSS experiences across different verticals. Unlike other standards, companies each have their own unique PCI journey to compliance, due to the type of business they have in regards to storing, processing and transmitting credit card information.

Payment gateways usually have a challenge in securing stored credit card information. Here we identify the areas and types of storage and the option for securing this data – usually with encryption. The good news is that most payment gateways do not have many physical locations in scope, so we are generally looking at maybe one main site and one DR site, or two at most. This helps significantly.

BPOs or outsourced companies are another animal altogether. These are generally multi site projects, with various types of interactions with credit card information – usually phone, or MOTO (mail order, telephone order).

Banks are probably the top of the food chain in terms of complexity. Not only do they have hundreds of sites which are in scope, they also have storage of card data all over, as well as ATMs in scope in different branches.

Somewhere in between, we have the retailers. Not the e-commerce only retailers but traditional retailers. And here, in this layer of retailers, choke full of credit card and personal information, the hackers ply their trade.

Target (ironically the target of one of the largest information heist in history), Neiman Marcus, Home Depot, PF Chang’s, even Wendy’s – these were all hit with credit card breaches, resulting in millions upon millions of credit card information siphoned off into the jungles of the Dark Web. Why?

In general, hackers view Retailers (and hospitals) as easy targets. One example is where hackers ship a box full of new POS (point of sales) devices to the retailer outlets with a note from the Chief Operating Officer that these are devices to be installed and used from here on due to security or upgrade concerns – and once installed, these POS devices start hijacking credit card information in behalf of the hackers. A similar vector of attack is to infect the POS updates with malware and once the malware (like BlackPOS) is installed, it’s open season.

For the Target case, 40 million credit/debit cards were lost through POS. The reality was that the hackers breached Target’s main network first and accessed the database. Thanks to PCI, their database were encrypted and instead of hacking the keys, the hackers decided to go to the source (the POS devices). If the data in the databases was not encrypted, the damage would have been much, much more (we are looking at 70+ million).

PCI has stringent considerations for the security of POS, including software and hardware checks, as well as physical location checks. This is why retailers going through PCI is facing such a hard time. Some of the main issues are:

a) Retailers are underfitted for security. I am not sure if there is such a word underfitted – but in most cases, budgetary concerns are usually the reason why there is so little investments in security systems for retailers. The focus is on efficient transactions, and often efficiency and security are strange bedfellows. While millions are spent on customer relationship management tools, and systems to predict customer buying habits and big data solution, the backend hardware are outdated – we have seen XP and its variants still going strong in some retailers.

b) Inventory is haphazard. Some retailers grow, and in growing they do not keep stock of their internal inventory of systems. Some customers we go into have a very rudimentary excel sheet dated back to 2009 for their systems inventory, that is inherited several times by different IT administrators who seem to be going in and out of the company.

c) Like b, IT admin staff in retailers generally do not stay long. While some of the have good intentions in implementing certain structures and projects, these get lost along the way as new staff replaces them.

d) Location, location, location. In security, more locations, more problems. We see main branches carrying out good security practices but replicating along 85 branches in the country is a different story. In most attacks, hackers might infiltrate through a smaller branch with less focus on security and less education on preventing breaches.

e) Technical considerations. Most retailers we see have rudimentary effort in securing the network. Perimeter wise, we have seen a conglomerate of firewalls from yesteryears that no longer have any updates – and a plethora of free security software that does not have any auto-updates on signatures and in some cases, are spyware themselves. The network itself is usually flat (because of efficiency) and this brings in a huge amount of scope when your database is next to your ERP and accounting system that is being connected by a 100 of junior staffs with their desktops running XP.

There are many reasons why retailers are now prime target for PCI breaches. How do we avoid these breaches?

Well, you can’t. You can deter, but you cannot fully remove the risk of breaches. PCI helps a lot but as of now, there is no silver bullet to resolve security completely, except to unplug everything and set up a pen and paper store like back in the Wild West. But where PCI comes in – physical location security, POS security, network and database security – these are all critical areas where retailers can start with. Some first steps for retailers:

– Set up a proper inventory of systems: In my University in Western Australia, there is a huge engraving on one of the main halls: KNOW THYSELF. We generally use that advice a fair bit especially when we have had a fair bit of alcohol in the Beer Parties, while stumbling back to our dorms. But in order to know what we are up against, we need a proper inventory of what we have and set about securing these systems.

– Secure the perimeter: Firewalls and IDS/IPS are important here to ensure that attacks are sorted out and abnormal traffic behaviour is properly caught.

– Segment the network: While Segmenting is not for everyone, the security benefit here is considerable. Databases which are critical systems should not reside on the same network as your junior associate’s desktop, especially one who spends half his/her time downloading music or watching youtube. An analogy here is simple: when you put a healthy person in a room with a sick person, the sick person doesn’t get well, the healthy person gets sick.

– Eyes on everything: We can’t iterate enough how important monitoring is in retailers. A good security information and event monitoring (SIEM) system is KEY to their security. Because of the lack of security personnel, the SIEM takes away a lot of these manual responsibility in tracking down strange and abnormal events. If a SIEM was set up properly in the Target case, they would have realised that one of their printer spooler device was sending out FTP packets out from the network into another system in the internet.

– Test, test and retest: Test your systems for vulnerabilities. You don’t need to spend truckloads on penetration testing if you don’t want to. Scanning using a Nessus scanner or even OpenVas will be useful as a first step. If a system is not patched, patch it. If you are still using Windows XP, seriously consider upgrading it.

– Finally, educate the users: While this has become a mantra for consultants and trainers, it’s still true. The weakest link in the security killchain is between the keyboard and chair. That’s the person. Security awareness training is key. While firewalls, email filters and Intrusion detection systems can go a long way, the security infrastructure is compromised by one executive clicking on an email attachment with the word: “Watch this Cat play the piano!”. Boom. Welcome malware, welcome ransomware, welcome sleepless nights for IT.

In summary, PCI-DSS establishes good and practical security practices for retailers. It might not be cheap, but once you have been hit by a ransomware or have your data pilfered, the fallout costs would be even more significant. For retailers looking to start off your PCI journey, or who need assistance on your ongoing one, please email us at pcidss@pkfmalaysia.com and we will get back to you immediately.

The Long Road of PCI Recertification

September 10, 2016 / pkfavantedge / 0 Comments

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We have been in PCI-DSS for six years.

When we began back in 2010, we were tasked by one of our offshore customers in Brunei to get them “PCI” certified. Honestly, back then, early 2010, we were mainly doing IT audits under COBIT, a lot of penetration testing, some IT forensics and bogged down with piles of ISO27001 ISMS opportunities.Back then PCI was more known as Peripheral Card Interconnect, which are those add-on cards that you slot into your motherboard back in the days when you wanted to extend your network interfaces, graphics accelerators etc. I used to build computers in those dodgy computer shops back in the days, so I kind know that very well.

Fast forward six years, and now we are getting more and more queries for PCI-DSS. So much so that we have dedicated an entire team from our company to work only on PCI-DSS projects.

In earlier years, we brought our PCI clients through their first year certification, and many of them are now going through their 2nd, 3rd year recertification etc.You would think that most companies will find re-certification easy compared to the first time certification.

Don’t be fooled.

The thing about PCI is, during the re-certification, there is a lot more expectations on your organisation for compliance. An example – PCI requires logs to be retained 3 months online, 12 months offline. It also requires daily log reviews, as well as quarterly internal and external vulnerability scans.

Now for the first time certification, some of these requirements get a free pass: meaning, if our client had just installed a SIEM and only has 2 – 3 months logging set up, we verify those controls and based on those controls, we can pass their PCI. We don’t need to wait for 12 months to get the offline requirement passed. Likewise, if our client provides us with one internal and external scan, we can pass them for first time, we do not need a 4 quarterly scan before we sign off on the initial AoC.

However – once the re-certification arrives, these become MUSTs. Some of our clients want to undertake internal scans themselves and missed one quarter and expects us to still pass them. Or they have a SIEM, but no action done on daily reviews, or their SIEM was not set up properly and no logs were sent there. They get upset when we say we can’t pass them on those basis because their response was “We did this last year!”

Also, evidences.

Whenever we conduct our audits, we conduct it onsite. Onsite, the QSA will verify these controls if they are in place or not. On top of that, we require audit evidences. This is normal even out of PCI – in our governance audit or ITGC we often rely on audit artefacts (we call it), to supplement our opinion on whether certain controls are in place. In PCI, these evidences might come in forms of documents, policies, screenshots, configs etc – anything that can prove controls are in place, and effective, and accordingly used as per PCI requirements.

The onsite audit confirms these controls. The evidences supplement the QA process. Each QSA needs to go through a stringent QA (quality assurance) process internally, whereby, the QA requires supplementary evidences to prove why the QSA arrives to such and such an opinion. Therefore, there is always that post-audit work of compiling audit evidences.

Some clients are of the opinion that the onsite audit should end the process and the auditor passes PCI then and there. Unfortunately it’s not so simple as there is a check and balance involved. An example is this: one of our clients recently added in a few out of scope devices into the CDE. During the onsite audit, we referred these and requested these systems removed or resettled in another segment. They said, OK, we will put it in another VLAN. So, if they do that, is that ok? We said OK.

Fast forward to the post-audit work, we asked “Hey, have you done your VLAN yet?”

“Yes, we have. Can you pass us?”

“OK, can you give a screenshot of the new configuration in your firewall or switch to prove that you have done this action?”

“WHAT??! Why??!”

You see – as auditors, we simply cannot trust you for your word. It’s not personal. It’s not that because we find you are a shifty trader looking to spin some yarn and fleece us of our money. It’s simply because it’s part of our job. Evidences provide us with some measure of assurance that these controls are done correctly and in place. It’s not that we question your integrity. It’s strange that even at this stage, many people find this difficult to accept, and we have gone through many, many strange situations whereby I have faced a red-faced, yelling executive thinking that I am personally insulting him and his family name by not trusting what he is saying.

Audit evidences. It’s part of PCI.

There are of course some exceptions, such as certain private and confidential documents or config that cannot be shared – even in that case, we generally ask these information to be anonymized, but evidences to be submitted all the same: for instance, evidence of VLAN config, you can screenshot the config, and remove elements deemed sensitive (IP Address, versions, other information etc).

In summary – the second year onwards, this is where the real PCI battles begin. Your recertification efforts will be a whole lot more than the first time, so get started early. We will be posting more articles on tips and actions that will make your PCI certification successful.

In the meantime, drop us a note at pcidss@pkfmalaysia.com and we will attend to any queries you have.

The Obfuscation of PCI Standards

August 14, 2016 / pkfavantedge / 0 Comments

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When you go through the PCI-DSS standard, while in most part, the sections are clear, there are some that just annoys the heck out of me, for good reasons.

Stateful inspection and Anti-spoofing in firewalls – I know these are useful features, but it is extremely rare these days to encounter clients going for PCI-DSS that own firewalls without these capabilities inbuilt. Even the humble ScreenOS running on your tiny SGs (Juniper) are enabled by default. While this isn’t an issue, we’ve faced vexing times when our clients are sometimes asked by their QSA, to show the firewall rules that prove that Stateful inspection and anti-spoofing is turned on. We have to come in and explain to them that its already enabled by default, and they insist on us testing and showing them traffic captures. Sometimes, I just show them the manual and entitle my email “RTFM: Stateful Inspection was first introduced in 1994.” You would think that PCI would do something better than to ask this question.

AntiVirus and AntiMalware – the researchers at Imperva, a couple of years back, did a study of effectiveness of antiviruses.They collected 82 new computer viruses and ran the malware against antiviruses from some of the largest companies like Symantec, Kaspersky, McAfee. The results: initial threat detection rate was 5 percent. That’s detection. This means 95% of malware is undetected. I don’t know how strong this hypothesis is, but frankly, we have known for years antiviruses, while there are limited uses, presents to us a false sense of security. Just because the antivirus says, “ALL IS SECURED” doesn’t really mean anything. The annoyance here is not that PCI has antivirus as part of their controls, they dedicated an entire requirement to it. It’s not effective – move on!

Confusion of application testing – Requirement 6.6 states:

For public-facing web applications, address new threats and vulnerabilities on an ongoing basis and ensure these applications are protected against known attacks by either of the following methods:

a) Reviewing public-facing web applications via manual or automated application vulnerability security assessment tools or methods, at least annually and after any changes

b) Installing an automated technical solution that detects and prevents web-based attacks (for example, a web-application firewall) in front of public-facing web applications, to continually check all traffic.

Note: This assessment is not the same as the vulnerability scans performed for Requirement 11.2.

Now, we need to clarify this because this is obfuscation. Note the nice caveat they put into 11.2. Now, if you go to 11.2, you get a whole bunch of requirements for vulnerability scans, quarterly ASV etc.This is understood, right

So the above, you would surmise this: if I have a WAF (web application firewall), I do not need to do any web applications review, correct? What IS a web application review anyway? In a lot of instance, QSA will interpret it as web application testing, covering OWASP top 10. In pentest world this is called WEB APP PENTEST. This tests issues like cross site scripting, validation etc. You can find more here

https://www.owasp.org/index.php/Category:OWASP_Top_Ten_Project

A web app PT can set you back around RM10 – 25K depending on your web app and the provider. I’ve seen web applications go into the RM50 – 80K regions before for massive applications, but in general for a web application payment system, you would get that range (unless the provider is looking to rip you off, in which case I suggest you give us a buzz).

So if you have 10 – 20 Web App, that would set you back a mile, so the suggestion is to “Let’s invest in WAF”, where you pay a license and every year you don’t have that WEB APPLICATION testing headache siting on your books. In the long run, it makes more sense if you have a lot of web applications to test.

Now, here is the PCI problem.

Requirement 11.3 – Implement a methodology for penetration testing that includes the following:

blah blah blah

– Defines application-layer penetration tests to include, at a minimum, the vulnerabilities listed in Requirement 6.5

Unfortunately the presence of 11.3 renders the earlier requirement choice useless, because now QSA interprets at despite having invested in WAF, they are still insisting on getting 11.3 passed, which requires this application layer PT!

My question to the PCI-SSC, why don’t you include this 11.3 caveat in the earlier 6.6 requirement instead of the useless 11.2 caveat which anyone knows how to read? And if my interpretation is wrong, I am going to war against some of these QSAs because they basically said, it’s nice to have WAF, but you still need to do App PT. In fact, one of them actually said: “Well, the advantage is that you are more secure.” Yes – but our client’s goal was to pass PCI. If they wanted financial modelling and investment advise from you, they would ask it, if not, just do our job and interpret the standards properly! Will someone from PCI-SSC actually clarify this because I’ve talked to some QSAs on either side of this opinion – some say WAF OR APP PT, some say, APP PT regardless of WAF.

To be safe – get your QSA to interpret this before making a decision to invest in WAF, because this is a major roadblock in a lot of cases we are in.

PCI-DSS and the SAQs that suck

June 21, 2016 / pkfavantedge / 0 Comments

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While a good part of our PCI business is providing level 1 certification to service providers, we also have provided the same to Level 1 merchants. Where we are seeing a big need for advisory is in the Level 2 Service Providers, or the Level 2,3,4 Merchants. This is because they generally fall under the SAQ category. SAQ = Self Assessment Questionnaire.

Now, I am not going document what these SAQs are, or their individual applicability and requirements – there are 2,345,565 sites so far that do this, so go ahead and google it – these sites do a great job in presenting the SAQs in a far more structured manner.

What we are going attempt to do here is jump right into it with the assumption you have some familiarity with these SAQs and you are as frustrated as most of our clients with it and want to find out why these SAQs suck so bad.

Well, mainly, there are a lot of ’em. PCI-DSS isn’t a guideline or framework like ISMS/COBIT. It’s a bunch of standards (some excellent in terms of making sense, some not so) that range from ‘oh that’s easy’ to ‘That is going to cost me a bomb’ sort of thing. So, different SAQs apply to different business. Each type of business have somewhat a different journey in PCI – the online mall with e-commerce vs the restaurant chain that has 100 branches nationwide etc.

We are going to focus where most the confusion happens: The SAQ A vs SAQ A-EP. Note that these SAQs apply to mainly e-commerce customers. So if you are doing mainly e-commerce business (we can go into POS issues later) – then it’s either SAQ A, SAQ A-EP or SAQ D-MER.

Now there’s a bit of history here – previously e-commerce companies that do online transaction with credit cards have two choices: SAQ A – which has a breezy 14 or so questions (now updated to around 20) or SAQ D – which jumps to the full monty, i.e 300++ questions covering the full 12 requirements of PCI. There is no middle ground. It’s like you are doing a weekend hike up your neighbourhood hill with your 5 year old son and suddenly someone tells you you are climbing up Mount Everest next. You can imagine merchants doing two things: they tear their hair out doing the SAQ D, or they just work on SAQ A, whether they qualify or not. More on the qualifying later.

So now, recently in the newer versions, PCI says, “Aha, let’s give these guys a break by introducing SAQ A-EP”. The ‘EP’ here stands for Ecommerce Payment, we assume. The problem here is that PCI Council, while trying their best to clarify who can or cannot be SAQ A, A-EP or D, only serves to make things even more confusing.

Your goal – if you are an e-commerce merchant – is to do your best to end up with SAQ A. Because it is the easiest. More importantly, it’s the cheapest. You don’t need to do any ASV scans, or pentest or all the kebabs that come with doing SAQ A-EP or SAQ D. The list of questions in the recent version increases from 20 to around 190 to 340+, when you go from A -> A-EP -> D-MER. That’s a difference between a days work to probably one to two months to a full five to six months.

PCI generally have a lot of documentation on SAQ A and A-EP and when to use it etc.We have provided a few good links below the article.

PCI generally slice the e-commerce implementations into 4 broad categories and in a layman description below: (for more technical explanation, google the words below with PCI appended to it and there should be some good sites coming up that explain in more detail):

a) Redirect – SAQ A

When you (customer) click on checkout with credit card after selecting your favourite golf clubs to buy (or high heels, whichever your fancy), you suddenly get a message saying, exiting www.ecommercemerchant.com, redirecting to PaymentProcessorName. This usually is a popup, or if not, another tab, or just a pure redirect. Now you see another page stating its the payment processor, and here is where you enter your card details (name, PAN, CVV etc). After entering, and being authorised, you are dropped back into the merchant page. The merchant has no idea of anything you have typed into the payment page.

b) IFRAME – SAQ A

Not as common, at least in our experience. This is when we click checkout with credit card, the page is still with the ecommerce merchant, but an iframe is loaded. An iframe is basically a page within a page, a child page that belongs to another site. It’s like a dream within a dream concept from Inception. So the merchant page now loads the payment processor page WITHIN its own page. The entire code for iframe is controlled by the payment processor. Even the code to Call the iframe is given by the processor. As far as the merchant is concerned, it’s like a redirect, a sleight of hand, it’s prestidigitation! (In the words of OZ). This is advantageous from a customer experience perspective as the customer feels that they are still with the merchant instead of being sent to another shop to make payment. The problem is, like everything, IFRAME is hackable. Here is a good rundown recently of an IFRAME hacking incident.

c) Direct Post – SAQ A-EP

OK – this is the one we see most (aside from the first). A lot of customers think they are doing a), when in fact they are doing c). Basically the form where we type in our Payment information is sitting with the merchant, and once we click submit, then it connects to the payment gateway and sends all the information. The payment detail collection page sits with the merchant.

d) Javascript – SAQ A-EP

We hardlysee this around, but even if we do, and if we are not firing up our developer tools, we probably won’t know. Basically, when we load the payment page on the merchant website, the processor page talks directly to us, the customer. The processor sends Javascript to our browser and our browser magically creates the payment form, which we happily fill in and send it back to the processor. Generating via Javascript has its advantages – dynamically it can fill in some parts of the form depending on where the client is, or basically improve the user experience overall. But again, a malicious code can be executed instead and instead of sending over to the payment processor, you might end up sending over to your friendly neighbourhood hacker.

The other scenarios falls into the bottom catch-all of SAQ D.

The confusion is added when in the SAQ A-EP document, it states: “Your e-commerce website does not receive cardholder data but controls how consumers, or their cardholder data, are redirected to a PCI DSS validated third-party payment processor”

So my question is, wouldn’t the fact that the merchant site is controlling the iFrame code or the actual redirection make it fall under “Controls how consumers are redirected” caveat there? It does. So much so that PCI Council issued a statement here at their FAQ site: https://www.pcisecuritystandards.org/faqs. Just type in “1292” and you should see the article reproduced.

Basically they go a long about way saying that yes, they understand that iFrame and Redirect falls under that SAQ A-EP caveat but they are willing to allow SAQ A to be used in this circumstances because “in the payment brands’ experience these are detected before significant volumes of cardholder data are lost. The Council is working with Payment Service Providers to encourage tamper-resistance and tamper-detection which will also reduce the viability of a MITM-type attack.”

As we can see from the IFRAME hack, it’s not really that trivial to pull off as you do require some knowledge of the transaction ID and getting it from the payment processor. Like all man in the middle attack, it does take some skills to pull off and massive removal of credit card details is harder as each transaction ID is unique. It’s a lot easier getting a malware into a POS device and siphoning the credit card information there a’la Target breach a few years ago.

So you see, it really depends on how you code or implement your e-commerce site. We have seen many companies underscope themselves by doing SAQ A when actually they had to do SAQ A-EP. Worse, we have also seen some ecommerce merchants forced to go trough SAQ A-EP or even D when they can qualify for A. These are usually directed by their acquirers – either banks or gateways with little knowledge of SAQ and who somehow just randomly decide that all merchants must suffer through SAQ D. It’s like being jailed for 50 years for stealing an acorn from a squirrel. Maybe in Norway it’s a law, but it sure as heck not here!

And now we are seeing some really strange permutations coming from acquirers – some of our clients are told to do SAQ A, but must to ASV scans. What? If it’s SAQ A, it’s SAQ A. Done. Why ASV scans are needed? Oh – because the acquirer says so. Well, the PCI Council doesn’t say that, so what we are doing isn’t PCI requirement. And even one case whereby the company said, yes, the merchants need to do ASV – but hey, because their risk management approves it, only need to do twice a year, not four times a year. Wait – PCI still requires at least per quarter though.

And the best one we have heard in an RFQ so far – the requirement is to “ensure that company must get Level 1 certified and become member of PCI Council.”

Become a member of the PCI Council? How?

I don’t really blame the companies for misinterpreting actually. I mean, if you look at the amount of documents PCI forces us to go through, it’s like asking people to read War and Peace six times. In Russian. When you are not Russian.

So, it’s really our job, whether QSA, ASV, PCI-P or consultant, to generally stop, take a breath and try to get this PCI education going.

This is a long post. I haven’t even gone to live demo of actual sites doing the 4 things listed above (Redirect, Direct Post, IFRAME, Javascript). I usually do that during our PCI-DSS training but I will try to give some examples in the next few articles.

If you are interested in PCI-DSS training (HRDF claimable), a free PCI scoping or any PCI services like certification, ASV scans, penetration testing or generally dissecting the PCI-DSS novels you don’t want to read yourself – drop us an email at pcidss@pkfmalaysia.com and I guarantee we’ll pick it up.

No customer is too small (or big) for us to handle!

Here are some useful links on this topic:

a) Good PDF from VISA

b) Official document from PCI

c) PCIPortal

Good luck on your PCI journey!