Tag: malaysia (Page 2 of 4)

IATA PCI-DSS: What Exactly is Required?

May 30, 2017 / pkfavantedge / 2 Comments

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Continuing our series on Merchant program for PCI-DSS. Why this is (or will be) so important is that in around 12 – 15 months, if you are a merchant, very likely you will be getting a call from your acquirer.

About 2 months back, Mastercard announced that all acquirers must have in place a risk assessment program for Level 4 merchants by March 31, 2019. This basically means that there is a great concern that 99% of Level 4 merchants out there are blissfully unaware of this PCI-DSS nonsense they need to comply. It is the acquirer’s duty, but the pain starts all the way at the merchants.

One industry feeling the pinch here is the travel industry. But don’t worry, travel agents, soon, the other industries like your cousins at the hotels and hospitality will be going through the same process as you are going through now. It’s just who is going through first. And the faster you get through the better.

Travel agents across the world has been mandated by IATA to be PCI compliant. Please read our previous post here.

We have gone through the requirements in that post, but we’ve been hearing a lot of things coming to us from the travel agencies recently, namely:

a) All Travel Agents need to engage a QSA to formally sign off their SAQ.

IATA should be able to give a formal statement on this. QSAs or consultants or PCI experts cannot dictate or mandate the validation requirements. Mostly this is by the processor (IATA) or the acquiring bank. If they can’t make a statement, then it would fall back into the card brand validation requirements. Which it has so far, unless IATA comes forward to clear this up. We can’t seem to find anywhere that IATA has had special requirements other than listed in the card brands requirements.

There might be further explanation needed based on their PDF at http://www.iata.org/services/finance/Documents/pci-dss-compliance-procedure.pdf

The procedure first states

Travel Agents are encouraged to contact their merchant bank (acquirer) or the applicable payment brand(s) to identify the appropriate procedures based on their eligibility.

But then at the bottom it implies that for assessment, it needs to have a QSA perform ‘on-site’ PCI assessment – which is not exactly accurate as it depends on their level. Further on right at the bottom, it states:

Depending on the number of card transactions handled those can be:
– PCI DSS Attestation of Compliance (AOC) which must be completed by a Qualified Security Assessor (QSA).
– Self-assessment questionnaire signed by an authorized officer.
– The results of quarterly vulnerability scans if applicable.

The problem here is that if the AoC is required to be signed by the QSA, so does its corresponding SAQ. These documents have the same signoff (3c for QSA) section. If you read the above you might be tempted to also argue that IATA is saying, depending on the number of card transactions (meaning your level), the requirements can be either:

– PCI DSS Attestation of Compliance (AOC) and ROC or SAQ which must be completed by a Qualified Security Assessor (QSA) – this applies to Level 1 Merchant (they can also use ISA but lets put that aside for now), and also Level 2 if you deal with mastercard.
– Self-assessment questionnaire (SAQ) and AoC signed by an authorized officer. – This applies to level 3 and 4
– The results of quarterly vulnerability scans if applicable.

Now we don’t know if this is what IATA is saying – it’s just the many ways this section can be interpreted so we do hope IATA will have a clarification on this matter. They CAN decide on a more stringent requirement for their agencies (such as ALL levels engaging a QSA to be onsite like a level 1 merchant), but this needs to be clear, so agencies can forge ahead with the proper budget and expectation.

Most travel agents fall under the Level 4 category of merchants, which based on the current requirements of PCI-DSS only requires a merchant officer to sign off the document.

Mastercard’s SDP services recently responded back to us on this with a confirmation as below:

Level 4 merchants are required to ensure they are PCI-DSS compliant by filling in the correct SAQ based on their processing environment and have the evidences prepared , and also to do this each year. There is no requirement from Mastercard to engage a QSA/ISA to signoff their SAQ on part 3c or part 3d of their SAQ/AoC and their executive signoff on part 3b is sufficient. This must be signed by the merchant. Engaging a QSA will be above and beyond their requirement and only done if they require assistance in filling their SAQ. Therefore, using a QSA is entirely optional and based on the discretion of the merchant.

This goes a long way in saying the same thing that has always been said. The logic I would argue here is, if your industry is made up thousands of merchants, how do we build a meaningful program to get all these merchants compliant? If QSAs are supposed to validate all the evidences, how much bottleneck will there be?

This is also inline with the famous PCI-DSS myth document at https://www.pcisecuritystandards.org/pdfs/pciscc_ten_common_myths.pdf. In Myth 6:

Myth 6 – PCI requires us to hire a Qualified Security Assessor
Because most large merchants have complex IT environments, many hire a QSA to glean their specialized value for on-site security assessments required by PCI DSS. The QSA also makes it easier to develop and get approval for a compensating control. However, PCI DSS provides the option of doing an internal assessment with an officer sign-off if your acquirer and/or merchant bank agrees. Mid-sized and smaller merchants may use the Self-Assessment Questionnaire found on the PCI SSC Web site to assess themselves.

Now, I know, there are so-called ‘merchant programs’ out there run by a few QSAs. I’ve spoken to many merchants who deem themselves compliant just because an ASV ran a scan on their external IP address and gave them a ‘certificate’ of compliance (which is not even a recognised document by PCI-SSC!). If anything, it just makes the merchant falsely complacent and gives PCI a bad name and a bad rep as an on-paper compliance but practically as useful as ice is to eskimoes.

The crux of the matter isn’t whether QSAs need to be involved or not. It would be super if they can get involved, but the matter is cost and time. QSAs programs are not cheap, and also, how much work do they actually do for the client? The counter argument is, if QSAs are not involved, what then? You get a bunch of executives just signing off they have a firewall when in their mind they are thinking, “Man, Which wall am I going to have to set on fire to comply to this stupid request?”. It’s not a knock on their intelligence, but really, a lot of merchants are really good in doing whatever they are doing and they don’t exactly have a CIO to standby to interpret all the requirements of PCI-DSS for them. And PCI, despite its oftentimes banal requirements, is a compliance requiring a lot of technical understanding.

How do we solve this? Awareness.

The SAQs reason for existence serves simply as a baseline document and puts the onus on the merchant to ensure they have the proper security in place. A lot of merchants are not aware of this obligation. The moment they sign off that document, they are saying, I am taking responsibility over this document. I verify and validate this as true. If it’s not…well. If it comes to any breaches or anything, then the merchant takes responsibility.

If they are fully aware of their responsibility, then getting help is likely required. But now, there is no need for a formal QSA to get involved. If you can, then do so as QSAs do theoretically should have more experience in PCI – but consultants, or advisors can take this role. And there are many reasons why it might turn out better this way which I will explore in my next few articles.

b) All Travel Agents need to engage ASV to do their security scans

Man. This is probably the most misunderstood requirement of all time. All time. 100s of merchants have come to us proudly saying their ASV scan proves their PCI compliance. No, it doesn’t. The ASV scan is just one of many requirements you need to go through. It’s like you dressing for work and wearing only your shoes and nothing else and go to work and say, “Hey, I am all dressed!”. Um. No.

And while ASV is important, we have seen our fair share of trigger happy ASVs being done for travel agencies. Oh, you have a website? ASV! Oh, you have an internet facing IP and router? ASV!

Come on. We recently adviced one client who was having trouble remediating an issue on their website. I asked them, wow, for a small company doing internet transactions, its a big deal. And they went like, “What in the good name of **** are you talking about?” And they explained they just had a corporate website and were asked to do a scan. I went and look, and aside from the site looking like it had been designed by a 15 year old drinking too much mountain dew, it serviced no credit card transactions at all. They don’t even have any systems doing that. They just do EDC terminals that connect directly to the bank and completely isolated. So why the scan?

Because we were told, they said.

And so I drafted an email for them and told them to send it over to their QSA (they are level 4 by the way) and the response came back, “Oh thanks man, they told us there is no need to scan anymore! Yay!”.

The problem remains. How many merchants are scanning their completely static websites and receiving a certificate of compliance and pronouncing they are PCI ‘certified’? Is it the ASV or QSA’s problem? No. PCI clearly states that it is the merchant (or scan customers) who ‘defines the scope of the scan’, so merchants are taking a fair bit of the burden if the ASV is done incorrectly. ASV scans are needed if your site does credit card acceptance (SAQ A-EP). It’s also needed on any external IPs you might have if these are transmitting card information (SAQ B-IP, SAQ C). SAQ A, B and C-VT has no scan requirements listed. A lot of clients could possibly fall under the SAQ B and possibly SAQ C-VT, so ASV scans can be further avoided.

c) All Travel Agents will be fined XYZ amount for non-compliance

Now, this might be true but IATA hasn’t really come out to say anything. Frankly I will be very surprised if there is such a requirement. Basically, IATA is just saying, if you don’t become compliant, don’t connect to us. If you don’t connect to us, then you can’t issue tickets. This is a worse threat than being fined. So they don’t have to be overbearing to impose such a condition AND impose a fine for clients who are non compliant. Because technically, if you are non compliant, you are not connected to IATA. If you are not connected to IATA, what are they fining you for?

smartmurphy

d) PCI-DSS is applicable to all Travel Agents even those without credit card acceptance and transactions

OK. I am not sure whether there will be such agencies or not, meaning there is ZERO card acceptance or processing or storage or transmission in your merchant environment. Now do note, even e-commerce when you outsource your ENTIRE payment processing, the fact that you have the credit card payment option on your website puts you in need of compliance. For merchants that do not have any facility whatsoever (either card present or card-non-present), then technically, PCI-DSS should not apply. I say technically. Because if you are connecting to IATA’s processor (BSP) then even if you make zero or a million transactions, the risk is still there. So yes again IATA as the big boss of BSP has the right to ask for compliance from agencies with zero credit card transactions. In this case, my suggestion is to write to IATA and see what is the next step. I can’t imagine any merchant business now not catering to credit/debit card payment but, wait. OK, my neighbourhood barber actually told me they only accept cash only, or barter trade my iphone for 2 years supply of haircut. So yeah, why not. But really, if no credit/debit card payment is an option and you regularly settle through agency credit or carrying a pile of cash, you technically can ask IATA what’s the next step.

In summary, we are not saying that there is some sort of conspiracy theory going on where QSAs are trying to pull a fast one on customers and creating F.U.D in the industry. After all, we ourselves have been certifying clients for 7 plus years already. But what we need to understand is that wrong information could be worse than no information. We need to get the right information out there so that merchants can make informed decisions. If they want QSAs, then ok all the better. If they prefer in house or specialised consultants, then OK. If they decide to do the hokey pokey instead of PCI compliance, then hey, that’s an informed decision on their side.

So, let’s get this awareness out. Travel agencies have about 10 months to get compliant. It’s not crunch time yet. This is like the start of the 3rd quarter in basketball. Important, but not Michael Jordan clutch time.

If you need more information on PCI-DSS applicability in your merchant business, drop us an email at pcidss@pkfmalaysia.com. We’ll get in touch with you ASAP.

Deploy HIDS agent in a Checkpoint Environment

April 6, 2017 / pkfavantedge / 0 Comments

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In our years of deploying and implementing SIEM, if we get 10 ringgit everytime a customer says: “Nothing wrong on our side, your SIEM is the problem” and then after hours of troubleshooting, the customer responds: “Ooops sorry, seems like our problem, we blocked your traffic” – we would all be as rich as Jack Ma by now.

The issue here is not so much that SIEMs are notoriously difficult to deploy – they are not, but its more that other devices need to talk to it. Deploying SIEM is easy, the finetuning is the problem. Because products need to get logs to the SIEM – either through the good old Syslog via UDP/TCP 514 or through agents installed on the systems, or through third party applications like Snare and NXLog – both for the naughty Windows machine where no syslog facility is found for some strange, Bill Gatesy reason.

It’s also because most Administrators guard their systems like pitbulls and any request for them to send logs over is generally greeted by a dumbfounded “Why are you so stupid” look, or “Over my dead body” look, or simply you get ignored completely. Oh, and also the “I want to go home at 5 pm today, so don’t mess with my jam” look. Whatever. The war between Administrators and Implementers has been going on longer than the blood feud between Lycans and Vampires.

We have been through deployments where countless of hours were spent just trying to convince our customer: “We are NOT getting anything on the interface. No packets. It’s being blocked.” And customer: “No, there are no firewalls between.” Five hours later, customer: “Oh yeah, there is a small firewall between and it’s blocking. Cheers”. On our SIEM, it’s easy. If our interface doesn’t see it, it ain’t there. That’s it. Do a tcpdump and grep the IP or port and boom, we know it’s not our problem.

The issue here is that “Not our problem” generally gets translated to “It’s now your problem” and we end up troubleshooting for our clients how to fix THEIR systems and devices. I’ve called my pals at Fortigate, Bluecoat, Cisco, Juniper etc so many times, asking them about issues that my client should be doing it themselves.

So anyway – we had this issue whereby we deployed a fair bit of HIDS (Host IDS, aka OSSEC) agents in a fairly large environment. It basically traverses through a firewall (Checkpoint). That Checkpoint firewall dropped UDP 1514 connection between agent and our AlienVault server. Port 1514 is the port that our HIDS uses to communicate between agent and server.

Firstly, establish whether we are getting those traffic or not in the interface. If we are not, then the problem could be on their end. When we do a tcpdump for udp 1514 on that specific host, we are able to observe some traffic from the server and vice versa. In our case even with that, the connection cannot be established. Bascially, our agent is able to reach the server but the server tries to respond but the traffic disappears. Therefore, the agent is orphaned.

For this case, after troubleshoot and checking, we found out that Checkpoint is dropping the UDP 1514 traffic responses from the alienvault server. So the communication between the HIDS agent and the server is never established. The log shows that UDP traffic is dropped with the following message:

Message_Info: Violated unidirectional connection

Great. UDP traffic is a stateless protocol. According to Checkpoint, by default, a reply to a UDP packet is not allowed. The Security Gateway can mark a connection in the Connections Table to allow traffic to pass only in one direction (hence the term ‘unidirectional’). If a UDP connection uses a bi-directional communication method, this would create a violation.

Therefore, the workaround to this is to allow Checkpoint to respond to this bi-directional communication. It’s pretty straightforward for Checkpoint actually.

You will need to add or edit a service object in Checkpoint. Again, we are Alienvault implementers but we end up mucking through Checkpoint firewalls just to get our job done!

So on a checkpoint edge box, it’s basically

Main Menu->Network->Network Services tab

You can now edit or add.

Go ahead and add a new UDP service, fill in the requirements, and then you will have an option for advanced, click OK.

In the Advanced UDP service property, ensure “Accept Replies” is clicked.

Now go ahead and use this service under the new or existing policy rule that has been set up for Agent->Server communication for HIDS.

Ta-da, done!

If you have any questions on Alienvault USM deployment, drop us a note at alienvault@pkfmalaysia.com.

Alienvault Troubleshooting: The Missing Sensor

March 15, 2017 / pkfavantedge / 0 Comments

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USM Sensor not displayed properly at “AlienVault Center” of the USM Server

We have recently been involved in a few deployments of Alienvault. Aside from the All In Ones, we have had a few projects where separate sensor, loggers and servers were deployed, as well as even deploying USM Anywhere, Alienvault’s new flagship cloud centric product that literally makes Alienvault USM works – well – anywhere.

While the USM Anywhere deserves its own piece of article, in this short article we will explore the often seen problem we call: The Case of the Missing Sensor.

So, you have setup the standard server and sensor properly and as per the deployment guide that you find here. The configuration was well configured and the sensor peacefully connects to the USM Server. So you break open the celebratory glasses and start relaxing. You let your customer go through the whole features, absolutely confident that they will be impressed with everything you have done so far and they will be signing off the implementation sheet, and you will be paid and you will ….

“Hold on. Where is the sensor?”

Startled, you look at the screen and even though you have configured the server IP address in the sensor, you do not see any sensor under the Server’s Alienvault Center section. This makes it look like the sensor wasn’t deployed but in fact all has been configured and accepted. If it didn’t show under AlienVault Center, you won’t be able to manage and update the sensor properly. Plus, it makes it look like you sold them a sensor but then ran away without actually installing one. Which makes you a charlatan. Which isn’t good.

So, you try the well tested “alienvault-reconfig” and cross your fingers. Do it on both server and sensor. No luck.

If you hit a brick wall on this, one method around it is to add the sensor manually into the server. The below is the command used to fix it:

To add sensor into Server

#alienvault-api add_system --system-ip=[sensor's ip] --password=[sensor's root password]

Once you run the command, that doggone sensor should show up properly under the AlienVault Center and you look like a king in front of your customer. However, like all CLI commands, you need to make sure that if this is done on production, proper backup and proper due diligence has been done.

There is not much detail found but there is similar issue found at the Alienvault forum and the thread is a couple years old.

AlienVault Forum: https://www.alienvault.com/forums/discussion/1322/adding-sensors-to-the-alienvault-centre-display

PCI-DSS Evidences: Your Type of Compliance

February 25, 2017 / pkfavantedge / 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.

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!