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Category: PKF Avant Edge (Page 10 of 18)

Alienvault: File Integrity Monitoring on Linux Part 1

October 31, 2017 / / 0 Comments

If you have been deploying or troubleshooting Alienvault long enough, you would know a few things: Alienvault is one of the most flexible SIEMs in the market. It has the most varied security features, and covers almost the entire spectrum of our PCI-DSS needs – from IDS, to SIEM, to File Integrity Monitoring, to vulnerability scaring to a partridge in a pear tree.

One of the products working under the Alienvault hood is OSSEC, which is a opensorce host based IDS. Sometimes, its interchangeable to HIDS, which is Host IDS, but really, the latter is simply the type; while the former is the actual name itself. For the sake of this article, we will interchange both terms.

OSSEC runs well with Windows, where Alienvault can do an auto deployment given the correct setup and credentials. However, it’s on Linux boxes that sometimes we get a bit concerned. Not because the product doesn’t work, but simply because the setting up of the installation. There is no auto deployment, so we need to set it up manually, and this might mean downloading the correct packages in the first place.

After this, we are going to look at a specific function of HIDS – File Integrity Monitoring or FIM for short.

Firstly, let’s get started. We have set up a simple CentOS 7 box in our lab in the same network as Alienvault, and we are going to install HIDS on this box as an AGENT. This will then talk to the Alienvault USM which is the server.

So let’s assume you have your agent system network setup (please ensure your DNS is set properly, you should be able to work this out in CentOS 7 either through the network tools or editing resolv.conf).

 yum groupinstall "Development Tools" -y

The CentOS development tools are very useful tools which is a bundle, used primarily for building and compiling software from source code. “Yum” here while making you think of going for a teh tarik is a command found in almost all red-hat based distros to run installations. It’s used for update, installations etc. In the old days before YUM, we would use RPM (which is really what YUM is using), but we would have to manually track down dependencies and it really sucks because to install an RPM package might mean to install a whole bunch of stupid libraries or updating stuff and you are basically running around the internet looking for RPMs like Where’s Wally. It looks awful now, but back in the days, RPM was heavensent. We didn’t need to do “tar”, configure, make, “make install” anymore!

Anyway, the -y argument behind simply automates the command by answering yes to the prompts. So once you run that, fingers crossed, everything runs ok and you get

Complete!

Which means everything is ok.

The next is to get the kernel-devel package.

yum install kernel-devel -y

This is a package that allows us to install a kernel driver later. It’s not the full kernel source, so it shouldn’t take too long before you see the “complete!”.

At this point you are ready to install OSSEC. If there are any issues, then troubleshooting is obviously required.

First, we need to locate the version of HIDS that can work with Alienvault. You might think heading to the latest HIDS in https://ossec.github.io/downloads.html might be the answer, but for Alienvault, we would recommend to get the 2.8.3 version. You can find it here:

https://bintray.com/ossec/ossec-hids/download_file?file_path=ossec-hids-2.8.3.tar.gz

So, go to a installation directory (optional) like /usr/src and run

curl -OL https://bintray.com/ossec/ossec-hids/download_file?file_path=ossec-hids-2.8.3.tar.gz

We used curl here because for some reason wget wasn’t installed. the -OL is supposed to handle the redirected links for that particular site and supposedly to rename it to a proper remote file name. It doesn’t do the rename though (don’t know?) and we wind up with a file called “download_file?file_path=ossec-hids-2.8.3.tar.gz”. Just rename it if you are into aesthetics to ossec-hids-2.8.3.tar.gz.

So now lets do an extraction

tar –xzvf ossec-hids-2.8.3.tar.gz

We now have a folder called ossec-hids-2.8.3. Go into this folder and then run

./install.sh

Once you run, you will be given a series of questions. Default should be fine for most, and you should just select ‘agent’ and also key in the server (Alienvault) IP address. Now if you are running a separate Alienvault setup (non-AIO), then this IP address is actually the address of your SENSOR. Not Alienvault Server. So don’t get mixed up. The Sensor is the Server. Hm.

So everything ready, fingers crossed, just go ahead and install. There will be a lot of text filling your screen but the important thing is that there is no ERROR or WARNING (well warning ain’t bad), but at the end you should have a welcome note stating

 Thanks for using the OSSEC HIDS.
 If you have any question, suggestion or if you find any bug, contact us 
at contact@ossec.net or using our public maillist at ossec-list@ossec.net 
(http://www.ossec.net/main/support/ ).

Press enter and you should be out of the installation. Congratulations!

You are not done yet. You still need to get Alienvault to talk to your box. The steps are as follows:

a) Generate an Agent Key from Alienvault

Go to your Alienvault AIO or your Server (since a standard sensor has no GUI, remember?).

Environment->Detection->Agents

Click “Add Agent”

Select the host from the list (It should be there automatically, but if it’s not just add it there through the asset list).

So now the agent has been created but you should see it as “Disconnected” from the list. Click the little Key sign that says “Extract Key”.

You should see something like

Agent key information for '2' is:

MiBIb3N0LTE5Mi0xNjgtMC01MCAxOTIuMTY4LjAuNTAgMDBmYzI0MzUyNzg4N.....etc
The garbled message is the key. So go ahead and highlight and copy it.

b) Import the key into the agent system

Go back to your agent system and head over to /var/ossec/bin and run

./manage-agents

Type in ‘I’ to import

Paste the whole key into the screen and confirm adding it.

Quit and then restart by going

/var/ossec/bin

And

./ossec-control restart

c) Restarting HIDS on the server

On the server head over to

Environment->Detection->HIDS Control

On the right side, click “Restart” the HIDS and you should be fine.

d) Check the Agent Logs

Head back to the agent system and check the logs

cd /var/ossec/logs
more ossec.log

You should (hopefully!) see

INFO: Connected to the server (192.168.0.xxx:1514).

where xxx is your server IP address.

Back in the USM server you will be able to see that now the agent is “Active”.

In the next article we will see if we can get the FIM to work.

PDPA and the Tale of the Telemarketer

October 29, 2017 / / 0 Comments

We were working very late on Saturday to roll out a PCI manual for some of our merchant clients, so I only slept at around 4.30 am. I am usually up on Sunday around 9.30 am at the latest due to my kids utilising my body as a trampoline which I can probably ignore for about 15 minutes before being entirely awoken, but 5 hours of sleep is pretty good so I will take that regardless.

At around 9 am unfortunately, my phone rang and I saw a number I didn’t recognise. Thinking this could be an emergency, I picked up the call and on the other line, this unrecognised voice chirpily said, “Hi, I am calling from <name of telco> and I would like to do a marketing survey with you!”

“Do you know it’s a Sunday?”

“Yes, it is a Sunday, I know!”

“Don’t you realise that you shouldn’t be telemarketing me on a Sunday morning?”

“We believe that you would be too busy on a weekday, sir, that’s why I am calling you on a Sunday!”

“Well, I am too busy now on a Sunday. Goodbye.”

And I hung up.

Now, I was fuming, because I just felt it was completely distasteful and disrespectful for them to be calling me up on a Sunday morning because they think I would reject them on a weekday. They think they will get me on a better mood on a Sunday morning?!

For the record, I don’t usually do this, as in, be rude or just hang up even on telemarketers. I am always reminded, that telemarketers are people. The person on the other line has a family too, and she probably wish that she was with them on a Sunday morning, taking her kids out for breakfast or hanging out with her friends or something. I mean, I doubt she is jumping up and down with excitement at the prospect of going into the office and dialing up people on Sunday so she could make her survey quota. I never experienced being a telemarketer, but in our first year, I did experience the emptiness of having zero clients and doing cold calling if anyone wanted my audit services. So, yes, I do commiserate with them. On normal calls I am usually civil to them. I usually politely tell them that they have already called me many times (Astro calls me like every week asking me to upgrade), and even thank them before hanging up, before I put their number in my ignore list. Some, I admit, when they do call, and I am in a the middle of something, I tell them that I am currently busy and then I put their number on my ignore list. It’s hard for me to ignore phone calls on any number because there could be a potential sales opportunity and not a telemarketer. But if it is a telemarketer, I don’t shut them down rudely. At least not in my memory.

But Sunday morning is a different thing. I did kind of feel bad, and was contemplating to call her back again to take that survey, but then Sunday life started (me being a trampoline) and I lost track of it.

But how does our Personal Data Protection Act fit into all of this?

Contrary to many people’s beliefs, PDPA actually allows telemarketers to call you. There is nothing in the act that says telemarketers cannot call you. The problem isn’t so much of telemarketers calling. Them calling you is already way downstream of the actual issue. The actual issue is your information being shared, leaked, sold, brokered by service companies to information brokers. Sometimes it’s our fault. We sign up for things and we don’t read the fine print. When we get a direct marketing call we get all up in a tizzy and blame the entire planet for conspiring to wake us up on a Sunday morning. But hey, we agreed to it. Yes, in that terms of services we did not read. In that privacy statement we implicitly agreed to when we gave our information to get a chance to win that free trip to Tokyo.

Privacy statements from banks, telcos, service providers all have to include the section of ‘disclosure’. Google your favourite bank or telco and put in ‘privacy statement’ and click to get their privacy statement. In most cases you will find them defining who they intend to share your personal information with, and in most cases, some broad sweeping statement such as :

Our agents and service providers with whom we have contractual agreements for some of our functions, services and activities; and/or

 

Financial service providers in relation to the products and services that you have with us (e.g. mortgage brokers, insurance companies); and/or

 

Strategic partners with whom we have a relationship with for specific products and services if consented to, by you; and/or

Now, let’s break that down. The first one is very broad. “Agents” and “Service Providers” where they have contractual agreements  – this basically means the entire ecosystem of companies providing services to this bank! The second at least defines it, but generally these are a subset of the first. Finally the ‘strategic partners’ part isn’t so much of an issue but the ‘if consented to, by you’ sounds very good and positive, only for you to realise that the implied consent is usually obtained by you agreeing to the privacy statement in the first place! You see, there is no need for explicit consent if this is not considered ‘sensitive data’, so don’t expect your signature to mean consent. By you taking up their service and agreeing to pass your data – that’s a consent enough for them to share your information. Boom.

So, technically the moment we sign up for a service, we agree that we would allow telemarketers to call us – whether in the middle of the night or on a Sunday morning is irregardless – the fact is that we gave that permission, mostly without knowing it and all just because of that carrot they usually hang in front of us. Dang, I lost that Tokyo competition! Hey, here’s another one – “provide phone number to win a Mazda 3”. OK, here’s my number! Yaay! Let me be lucky!

You get the drift.

Now, back to telemarketers calling us. They have the right. They have a bunch of phone numbers given to them by the bank, and God knows what other information so they can sell us specific services: and so they make the call.

PDPA regulates telemarketing through Section 43 of the Act: Right to prevent processing for purposes of direct marketing. 

So the proper channel to stop this: Technically you are supposed to provide in ‘writing’ to the data user (company calling you), requesting you not to be contacted anymore for telemarketing. This can be a courtesy respond during the call itself, whereby you state to them, please remove your number from their list and not call anymore (it’s not in writing, but you can try this first). If they persist in calling, write to them (their email is found in their company’s privacy notice of who to contact if you have a complaint), and if you still get called up, you can formally complain to PDPA commissioner at aduan@pdp.gov.my and follow that up with a call to 03-89115000 (please check their website to see if this has changed).

So, there you go. Malaysia was supposed to implement a Do-Not-Call (DNC) registry to block these telemarketer phone numbers back in 2014, but it has seemingly died down and implementation is still not done. We are monitoring to see if this is being looked into again, but for now, it looks like we need to fend on our own here.

Remember though – the person calling you may not wish to be calling you at all, and they might just be a phone call away from losing their jobs. While I am not advocating you to entertain them just for the sake of being nice, but on the flip side, there is no reason for some of the foul-mouthed tirade I have seen some people venting on these callers, as if they want to personally reach into their mobile phone and strangle the guy on the other line. Cool down. Ask to be removed, and block the number and move on, knowing you can rely on PDPA if your notice of removal is constantly ignored.

If anyone needs to know more on PDPA, drop us a note at avantedge@pkfmalaysia.com. We have been working with many companies to sort their PDPA concerns out and also implementing controls to address the 7 requirements.

 

IATA PCI-DSS: Is GDS Client software a browser? Part 2

September 3, 2017 / / 0 Comments

Right, now that we are past the theory in Part 1 of this article, let’s jump straight into the dissection of the traffic flow.

First of all, we will not be looking at the entire traffic stream of the GDS application. We are not interested in its security for now, but rather whether it is establishing a typical web browser traffic. We need to assume that there is going to be some working knowledge on how networking works, else we will end up giving an entire lesson on it and not get to the point of this article. So, we are not going to explain TCP, HTTP(S) protocols, TLS, handshakes etc. Let’s just assume that we are beyond that and we just need to see if the GDS traffic is similar to the traffic we see on browsers.

In order to do that, we need to look at the basic communication over the internet – handshakes. Like its namesake, a handshake is between two systems – the client and the server and it’s a way of establishing communication. It’s a universally acceptable sign of friendship, although in some countries, it would be a hug, or kiss on the cheeks, or fistbumps. It’s the same thing. A TCP handshake is when your browser fistbumps the server.

However, in this case, because this is considered a “secure” channel we will be using what we know as a TLS (Transport Layer Security) Handshake.

This typically goes like:

a) Client Hello

b) Server Hello

c) Server Key Exchange

d) Client Key Exchange

e) Handshake

f) Let’s chat!

Now, again, this article is not to break down each item and explain every single packet details, but to make a comparison between GDS traffic vs an encrypted browser traffic, to say, Yahoo.com. So what we have done is to use a normal Chrome browser and go to mail.yahoo.com which throws us into the “HTTPS” page, which is the encrypted secure page and from there, we want to establish a connection by logging into Yahoo Mail and looking at the traffic. We are using Wireshark and here is the screenshot:

So as you can see, the beginning has a “Client Hello” packet from our system to Yahoo. This means we are saying, “Hey, here’s what I want from you and here are some information: my TLS version, my cipher suites, my compression method, the server name (so we know who we are talking to) etc. It’s like I give you a name card with all my information in it.

Next, we see a Server Hello. This is great so we know we are not talking to a brick wall. While the Client Hello has information in it, the Server Hello is not just courtesy, it also has piles of instruction on how to communicate. It’s like someone responding to us and saying, “OK, we will be talking in English, we will be using a phoneline at this number, at this time etc etc”. For internet connectivity, TLS versions, cipher suites are important to sync between Client and Server. We won’t go into details here as it is not the objective of this article.

If all goes well, the next step is the Certificate (remember, we are using a secure version of communication here). This certificate does a few things: It gives non-repudiation, meaning, the client knows that it is the server that is sending the information (instead of say, another server pretending to be the actual server). The certificate also provides the important “Public Key” of the server so encryption can occur and the server can decrypt using its own private key.

After this, there might be a Server Key Exchange, which is part of the negotiation flow. At the end of this packet, there is a “Server Hello Done” which is…what it says it is. The Hello is done. Likewise, a Client Key Exchange packet is followed if there is a Server Key Exchange, which in this case, there was. The client is basically encrypting the session with the public key of the server. After these, the TLS handshake is basically done and the transmission is considered secured, and you will see New Session Ticket.

At the end, you will see that “Application Data” packet is encrypted through TLS v1.2.

So this basically constitute a typical browser packet capture for secure communications.

Let’s compare what we get from Travelport:

So here you see the start of the conversation typically begins the same, except there is no Server Key Exchange, and basically the Travelport server sends the “Server Hello Done” message in the Certificate packet itself. This is no big deal, as this is an optional message and the server certificate has the required information.

The client key exchange here is sent to travelport based on the public key algorithm…for the sake of this discussion, this is perfectly normal to either have or not have this, as is the Change Cipher Spec. Finally a “Session Ticket” is also optional (it is missing here) , it’s based on RFC 5077, which basically is session caching on the client side which removes the tracking of each client session on the server side. It’s kind of like those special pass stamps you receive on your hand when you enter into a concert, when you need to take a leak and go outside, the bouncer recognises you on re-entry by the stamp on your hand and you don’t need to do a re-registration again. I really can’t think of another analogy here, so do forgive me if this flies over your head.

So from here, you can see Travelport Galileo Client is actually establishing the same sort of traffic that our Chrome established with Yahoo Mail on the browser. The only thing here we are not comfortable with is the fact that the protocol negotiated is TLS v1, which is not secure and broken. PCI-DSS would have some choice words to say to Travelport on this, as there is a requirement to migrate TLS v1 to v1.1 or v1.2 by June next year 2018.

So let’s look at Sabre:

Again, more or less the same as Travelport except here we have a “Encrypted Handshake Message” which usually occurs after “Change Cipher Spec” since now the messages are no longer unencrypted like the Client Hello, Server Hello etc. Again, it’s part of the normal handshake flow.

With the breakdown as such, we can see that the Travelport client and Sabre client are establishing the same sort of network flow as a browser authenticating to a website, and not doing any local authentication or getting local application data within the client application itself. This generally means, these are specialised “browsers” that are made for only one purpose: connecting to the GDS server. No Facebook access permitted here.

Again, we went through this because we needed some assurance that these GDS clients are functioning similar to browsers, as opposed to standalone payment systems, and from these packet capture, we can surmise (unless stated otherwise by the GDS, IATA or acquiring banks) that these clients are indeed “Internet Based Virtual Terminals”. This gives our travel agencies a measurable confidence to approach this channel with SAQ C-VT (as long as all the other eligibility requirements are met).

Thanks for reading this post, and as always, let us know if you have any queries regarding your PCI-DSS program, at pcidss@pkfmalaysia.com.

IATA PCI-DSS: Is GDS Client software a browser? Part 1

September 1, 2017 / / 0 Comments

We are writing a fair bit on PCI-DSS for travel agencies simply because there is a deadline looming for them in March 2018 to become PCI compliant. While one might surmise there is still plenty of time, on the contrary, even merchant PCI programs will take a few months, and since the end of the year is pretty busy time for traveling, it’s best to get everything in order before the January – March months roll in next year.

So far, we know that the travel agencies are uniquely dealing with their PCI program whereby they have PCI obligations to their acquirer where most of them have card terminals merchant accounts with, and also IATA where they accept card through the “BSP channel”. They are both separate channels, because the BSP channel is actually acceptance of card IN BEHALF of airlines, not part of the agency’s own merchant flow.

So because of this, agencies have options to either fill in a full SAQ D-Mer and submit to acquiring banks and IATA, or to submit an SAQ B (or B-IP) to bank and SAQ C-VT (or C) to IATA. We are now looking into more details to the latter discussion – whether C or C-VT self assessment questionnaire should be filled.

Now before we start, we believe the answer to this is obvious. Ask IATA. We have. But we haven’t got any reasonable response. Next, they can ask the acquirer bank, which is what PCI-SSC suggests. Unfortunately for this channel, the merchant acquirer bank has no visibility over, so they don’t respond. Next, you could probably ask the GDS vendors. Which we also have. Only Amadeus have responded, when we queried whether we were correct in filing out SAQ C-VT: “Basically, if the payment is done via Amadeus and entered manually from a personal computer directly into the GDS – you have (the) right form for Amadeus agents and tick it off with confidence.”

Now it doesn’t really go out of the way to say it, because for this channel, technically, as long as no card data is stored electronically, we need to look at the eligibility of SAQ C vs SAQ C-VT. First of all, SAQ C has 162 questions. SAQ C-VT has 81 questions. More notably, SAQ C-VT does not have obligations for ASV scans whereas SAQ C has. Also, as an introduction for SAQ C, this is mainly designed for restaurants, fast food, franchisees with integrated Point of Sales. You know, the one we see at Oldtown Kopitiam whereby the point of sales system is like a desktop computer that has a LAN connectivity. The SAQ C-VT is designed for very small businesses who needs to enter manually the credit card number to a Virtual Terminal that connects to the acquirer through a ‘web-browser based connectivity’. Now these terms are very important to note, as we go into more details.

The question we have on the table is: Does your GDS channel qualify for SAQ C-VT?

First of all, if you store card data electronically, you can stop reading. You need to do SAQ D-Mer. Go. You have 332 questions to go through and we suggest you start! If not, then the idea here is whether SAQ C or SAQ C-VT is correct for your GDS channel. Now, these are obviously our own opinions, and some other consultants/QSAs might have a different idea or take on it. We do not represent the industry or IATA or PCI SSC in defining this…as and until someone from these parties decides to make a definitive statement of which SAQ needs to be done, this is our suggestion on why SAQ C-VT could be the correct SAQ for the GDS channel.

Now for SAQ C-VT there are a bunch of criteria. You can download the SAQ itself directly at

https://www.pcisecuritystandards.org/documents/PCI-DSS-v3_2-SAQ-C_VT.pdf

To save time, we are going to focus on the first three main eligibility points that define this SAQ conditions:

a) Your company’s only payment processing is via a virtual payment terminal accessed by an Internet connected web browser;

b) Your company’s virtual payment terminal solution is provided and hosted by a PCI DSS validated third-party service provider;

c) Your company accesses the PCI DSS-compliant virtual payment terminal solution via a computer that is isolated in a single location, and is not connected to other locations or systems within your environment (this can be achieved via a firewall or network segmentation to isolate the computer from other systems);

Now for A), the key here is “Internet Connected Web Browser”. The other part about ‘Your company’s ONLY payment processing is via a virtual payment terminal’ might mean that if you have any other channels such as internet of EDC (card terminals), you disqualify for this SAQ…but actually no, PCI-SSC states in their Article 1082 that as long as the channels are isolated from each other, you can go ahead and complete different sets of SAQ for different channels.

Now to understand the GDS connectivity, a majority of agencies are using either Sabre, Travelport or Amadeus. Each one of these are supposedly PCI compliant (so item Bcan be checked), and each of these provide a client solution that installs in your desktop and connects back to their main server for information and input. Sabre has their Sabre Red Workspace, Amadeus have their Selling Platform and Travelport have their Galileo Desktop. Some GDS now also offers direct web browser connectivity so that there is no need to install additional client, but for this article, we will be looking at the client application residing in the agent’s desktop. This is key, because if this is considered a stand alone payment application, then SAQ C-VT cannot be fulfilled.

It is this installation of additional client that some consultants have ventured to say that this is not a ‘web browser’, with web browser being what we know as Internet Explorer, Chrome, Safari, Firefox etc to name the popular ones. Without going into the history of web browser itself, the basic definition for the web browser is “a software that retrieves, present and traverse information resources on the internet”. These can also be used to access private web servers or private files in private servers. It is important to note that there must be a call to a web server, usually through encrypted transmissions and there is a dependency on information being posted/sent to this server and receiving a response. Basically, without internet connectivity (except if you have offline data), your web browser is basically non-functional.

So where does this leave us? Unfortunately PCI SSC is cryptic about this ‘Internet Connected Web Browser’ bit in SAQ C-VT. However, it does offer a bit more information about what constitutes a ‘Virtual Payment Terminal’ which is basically:

“Web-browser-based access to an acquirer, processor or third-party service provider website to authorize payment card transactions. Unlike physical terminals, virtual payment terminals do not read data directly from a payment card. The merchant manually enters payment card data via the securely connected web browser. Because payment card transactions are entered manually, virtual payment terminals are typically used instead of physical terminals in merchant environments with low transaction volumes.”

Now we are getting somewhere. So instead of saying Internet connected web browser, here it states a ‘web browser based access’ which might sound like the same thing, but it isn’t. It’s basically stating as long as the software accesses similarly like how a web browser access a resource, then it can be considered as SAQ C-VT qualified. Again in PCI SSC article 1063 in their FAQ:

” SAQ C-VT is for merchants who manually enter a single transaction at a time into an Internet-based virtual terminal solution provided by a PCI DSS validated service provider. “

In this case, it does away with the term ‘web browser’ completely and just states Internet based Virtual terminal.

So let’s establish a few assumptions here to approach this:

a) Software must be dependent on the internet. If there is no connectivity, there is no usage.

b) Like a browser, the software must send and receive information to and from a server

c) Like a web browser, the line should be encrypted if private information is being sent (this is technically more for security than functionality)

If the software can meet these requirements, then it can be considered an internet based virtual terminal. In order for us to really dig into this, we need to go down into the details: doing a packet capture.

We will look into this in more detail in Part 2 immediately after this, which is a separate article, since this one is already way past its word limit already!

IATA PCI-DSS: Approaching the BSP Channels

August 26, 2017 / / 0 Comments

First of all, Selamat Hari Merdeka (Independence Day), and congratulations Malaysia for hauling in a record number of SEA Games Gold Medals. So much so that our government has declared next Monday (4th September) as a holiday for….celebrating? I am all great with achievements, but at the risk of sounding like a spoil sport – aren’t we having a wee bit too many holidays? It’s great for morale I suppose, but it’s not so great for business due to the start-stop nature of things and worse, when we are chasing down a compliance deadline for our clients. In fact, approaching the end of the year, the amount of compliance work we are faced with is absolutely daunting.

Which is why it has taken so long for an update on this blog – not because it is low priority, but because we were just chasing so many deadlines in August, and now in September all the way to Christmas. It’s going to be a fun ride to the end of this year for sure.

Now as we approach our March 2018 deadline, we are getting more and more travel agencies calling us up on the IATA PCI-DSS requirements. While these are generally smaller agencies, we have come up with a standard package that addresses specific agencies with specific requirements.

a) No storage of PAN electronically

b) Only for Level 4 merchant levels (less than 1 million traditional transactions and less than 20K Ecommerce transactions)

c) Self signed SAQ by Merchant

d) GDS (Global Distribution System) Provider must be PCI Compliant

These are reasonable conditions for us to consistently approach each agency. See the problem is not so much that travel agencies are complicated – it’s because we have a whole lot of agencies with a very short deadline. We advocate that the whole industry and QSAs, Consultants or PCI experts all work together to get these agencies up to speed.

The first hurdle of cost prohibition is passed. Previously we all thought (based on the wordings) that IATA requires all agencies to have the QSA sign off on section 3c of the SAQ/AoC document, effectively rendering all Level 4 merchants to be Level 2. Obviously that would cost more as Mastercard requires Level 2 assessments from QSAs to be carried out onsite as opposed to remotely. That won’t be feasible due to the amount of agencies. Once it becomes more of a consultancy and advisory as opposed to an audit, it makes more sense. We are not saying QSAs should not get involved – we are saying now agencies have more options on their table – if QSA is affordable then by all means.

Secondly – storage of PAN. This is a real pain. Especially for travel agencies. You may think that you don’t store the PAN, the infamous Primary Account Number, that 16 digit on your credit card (remember, truncated PAN, or what we know as “First Six Last Four” or “Last Four” where the other numbers are X’ed out – this is NOT PAN)- even if you don’t formally store PAN as your process, the fact that you receive PAN in email, or Whatsapp or Skype or Wechat or QQ – anything at all – this translates to PAN being brought into your environment. Unless you are interested to secure your handheld devices and laptops and desktops and email servers – we suggest that you have only formal channels of card acceptance. Via Phone is one way. Through a secure portal is another way.

The problem is compounded due to Credit Card Approval Forms (CAF) or Credit Card Charge Forms (CCCF). These are formal forms either from the agency or from IATA to collect details of transactions, inclusive of credit card. IATA, however, has taken pains to ensure their channel is PCI certifiable and has since removed the requirement for CCCF to contain credit card information in full, as well as providing electronic alternative to CCCF submission via GDS. They are, in essence, securing their channels.

What about travel agencies own CAFs? This is not in any regulated form and even sometimes we see CVV information being required in these forms. This obviously is not allowed, to the genuine surprise of some agencies. Like the CCCF, either these forms need to be secured, or the channels in which information is provided needs to be secured. This is one of the challenges being faced.

Thirdly, the fact that IATA allows for self signed SAQ eases up the pressure of getting an audit in. However, in theory, the agency still needs to go through the same amount of due diligence to ensure they are fully compliant. Audit or no audit, there is no excuse of marking down “Compliant” in the SAQ for a question that you have no clue about. One client actually marked down compliant for “IDS” thinking this meant Internal Distribution System, which he thought was another name for GDS. Seriously. We don’t blame them. We blame the entire technology community for coming up with these acronyms that can sometimes be frustratingly flabbergasting for the general public to understand.

Lastly – the GDS. The ones we have experience with are Sabre, Travelport-Galileo and Amadeus. We come across some older ones but in general, these are the three main ones utilised by travel agencies. All of them as far as we know are PCI-compliant. We only have ever seen the AoC from Travelport. Sabre and Amadeus in turn provides our clients with some weird certificates by QSA or other documentation that is not AoC. Again, it’s just completely irritating when providers give these so called ‘certificates’ and argue with us that this is acceptable to PCI and we have no idea what we are talking about. It’s mind numbingly, teeth-gnashingly frustrating.

The GDS channel is general is secured. As long as credit card information is sent to the GDS mainframe you are more or less done. The problem is whether the desktop client is an actual application or just serves as a web gateway to the mainframe. This is where we are juggling between SAQ C or SAQ C-VT for this channel. We have gone through the Sabre Red Workspace and Galileo Desktop, and either of these cannot function without internet connectivity, and all information traverses through a TLS link to the mainframe of the GDS. We have done packet capture on these applications and while not traditionally considered as ‘web browsers’ in what we are used to, the functionality of it is similiar to a web based client. Even Travelport AoC states that the ‘travelport application client’ is covered under its compliance. In essence, these are virtual terminals in every understanding of the term.

While rare, the internet channel is probably the most straightforward, whereby an SAQ A should sufficiently cover most agencies, since they are utilising a payment gateway and not processing, transmitting or storing credit card information in their own environment.

In summary, the challenges faced mainly by agencies is not so much on the security of BSP or GDS channels, but their own. The credit card forms remain a pain, not so much of the forms itself but the channels in which the forms are sent or received. This forms a very real challenge in securing based on PCI-DSS requirements.

Of course, we have also recently encountered another massive hole in the travel agency PCI program – if you are doing “enhanced data services” with any of the card brands and exporting through a system like Sabre Powersuite, you have another headache in your hands: Clear PAN. We will go into this in a later post. Suffice to say, we have a lot to do, with little time to do so, so it’s time to get cracking.

Drop us an email at pcidss@pkfmalaysia.com and we will see how to get you started with your PCI-DSS program.

 

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