Tag: PCI-DSS (Page 8 of 10)

PCI-DSS v3.2 for ePetrol Services Sdn Bhd

Congratulations to ePetrol Services Sdn Bhd for being certified PCI-DSS v3.2 Level 1!

ePetrol is a secure and reliable payment switch and service provider that offers a variety of payment solutions to a broad spectrum of industries encompassing oil and gas, finance, healthcare, retail, e-Government and telecommunications.

Founded in 2007, ePetrol – a subsidiary of Dialog Group Berhad – is a MSC status company which conceptualised and pioneered an innovative payment system which uses the Malaysian National ID Card (MyKad) as the payment instrument for purchases of goods and services. Their MyKad solution is also designed for welfare distribution and subsidy management.

Besides payment, ePetrol offers variety of IT solutions such as Loyalty Solution, Scheme and Entitlement Solution and Enterprise Management Solution to meet the client’s needs.

PKF and ePetrol actually had started the PCI journey together earlier, however due to the move from their old office to the current Dialog Tower, we then rebooted the process. We are happy to be part of the journey of PCI and the highs and lows we have had with the team. It has truly been a fulfilling experience in the project and we are looking forward to serving ePetrol for years to come.

Congratulations!

PCI-DSS – So Why Aren’t We QSA?

We have faced this question many times before over the course of 7 years working on PCI-DSS in this region. Many customers have asked us, why haven’t we become QSA (Qualified Security Assessor), considering the amount of PCI work we have been involved in, as well as the PCI-DSS knowledge that we are having?

The answer is simply – we choose not to.

Don’t get me wrong. QSAs certainly have their place in our world, and the fact that we work closely with one, as well as representing them in our country states the importance of having a solid auditing foundation in every project that we go in.

But here are the main reasons why we have decided that being a QSA would hinder us, rather than assist us:

a) Conflict of Interest

This is a huge reason why we maintain our consulting and implementation practice, while choosing not to become an auditor. Our business is not just PCI-DSS. We have a huge chunk of consulting practices in ISMS (ISO27001), training as well as upcoming compliances like SOC1,2, Personal Data Protection Act etc. QSAs and the question conflict of interest has been around for a long time. It is also addressed in Provision 2.2.2 in the PCI-DSS validation requirements for QSA

The QSA must describe the company’s practices to maintain and assure auditor independence, including, but not limited to, practices, organizational structure/separation, and employee education in place to prevent conflicts of
interest in a variety of scenarios, such as the following:

The QSA customer uses products or applications developed or manufactured by the QSA company.
The QSA customer uses products or applications managed or configured by the QSA company.
The description must include details with respect to compliance with the Specified Independence Requirements called out in Section 2.1 above.

The thing is, we do a fair bit of work for our clients – including development of policies, reviewing their security, implementing policies and logging products etc – because we are good at it. Before PCI, we were operational guys, guiding SOCs and NOCs, troubleshooting routers and switches, deploying firewalls and SIEMs etc. We weren’t bred as auditors from the start, so most of us have an inherent instinct to just go in and get the job done for our clients. Now, the problem is once we do wear the auditor’s hat, there are a lot of grey areas. We make this demarcation very distinct in our IT general Controls audit – the moment we implement something for our client, we cannot audit or assess it. We can’t audit our own work. This is not just for PCI, this goes across the board for anything we do.

PCI gets around this by ensuring that the QSA has proper internal segregation – meaning it is generally accepted that policies be put into place that mandate a separation of duties between QSA Auditors and QSAs, or other individuals within a QSA certified company who provide remediation support. So generally, any QSA company should have its consulting group separated from its audit group. Now, PCI-SSC doesn’t specifically state that QSA Companies cannot provide remediative services – after all, if the QSAs know what it takes to pass PCI-DSS wouldn’t they be the best source of knowledge to clients after all (and they often are) – but QSAs need to be very aware that they cannot push their products or services as the only option for compliance. Customers must have the options on the table, the knowledge that there are other options in order for them to make informed decisions.

It’s made trickier due to our DNA as a CPA company. PKF wasn’t born an IT company or a security firm – our roots are in accounting and auditing, and most of our partners hail from Big 4 (PWC, KPMG, EY, Deloitte) and even ex-AA. In fact, I am the only non-audit guy in the partner table and my jokes are often not understood. Due to this background, inherently we have this default position whereby if there are any grey areas, it’s safer to err on the side of caution and not do it unless proper conditions are clear. So while in PCI the arrangement of QSACs providing remediation works are allowed with certain conditions, the very memory of how an 89 year old accounting firm had to surrender its CPA license due to the largest auditing scandal in history still lives on in our industry.

b) We Hate Auditing

Well not really. We are auditors after all! We do have a fair bit of audit and assessments as part of our work. But boy, have you ever been in an audit as an auditor? Everyone just hates you. I remember auditing for a very large BPO company for their IT general controls and software development. The head of software looked like he was going to put live electric eels down our pants halfway through our interview. And we weren’t even antagonistic. Asking for documentation of his software practices was like asking for the what Edward Snowden had. Another company had their head of operations sit with us in the room for 1 hour and throughout the entire session, he refused to answer anything without legal in the same room. It was like we were interrogating him for murder instead of just asking if he had a change management procedure. It’s not all like this of course, we do have excellent clients who are on the same page as us mostly and we do feel the whole auditing process is enriching to our professional lives. Really. Even with that, the follow up audits, the report writing and quality assurance process etc, the evidence gathering and formatting into the proper report, the cycle of obtaining management comments etc. It’s just very taxing on the guys. Report writing takes up a chunk. And guess what – in PCI, a normal Report on Compliance (ROC) for level 1 onsite assessments can stretch up to a thousand pages. Yes. A. Thousand. Or more. It’s like asking us to become Leo Tolstoy and start writing War and Peace every single assignment.

c) Cost vs Benefit

Being a QSA is a great achievement. But there is a huge outlay for the company as well. Not only there are fees you need to pay to become QSA, there are fees you need to pay to operate in particular regions as well. Then you have training fees for your QSAs, yearly maintenance etc. It’s a lot of money to run a QSA company and because of that, you need to get your bacon from all over. For instance, if you have license in Asia-Pacific, then you probably want to tackle the China market. Or else, focus on the SEA region and get your QSAs to fly between countries. Focusing on a single country isn’t going to make up for the cost of maintaining your QSA company, at least from our point of view and our brief calculations. Now because of this, we need to fan out. To fan out, we need to expand the company. To expand, we need to hire and get jobs. I’m all for it, but its a matter of being a big fish in a small pond or a small fish in a big pond. As of this moment, our strategy is not to overstretch ourselves too much and to establish ourselves with the clients we have. It’s not as if PKF is in a hurry to IPO or go anywhere. We’re here for the long run, and in Standard Chartered slogan: We are here for good.

d) Stretching is not fun

We tried it before.

As in not physically, but in terms of a company. We grew our tiny little professional services firm to 16 people once upon a time, with dedicated R&D and Project Management group only to get kicked in the butt by a guy called “No Jobs”. We grew so fast, we didn’t get the sales in to keep up and after the initial projects were done, we were left with a lot of people on the bench playing Pokemon-go. We stretched. But we over did it. It’s not to say we are now not being ambitious. We still are, but we need to be realistic with our goals. If we target to get 10 – 15 tier one customers to keep our benefit more than our cost – how many QSAs do we need to do that? After that, how many consultants to do the remediation work?

Additionally, even if we had 10 QSAs for instance, these guys will be scrambling all over the region doing audits. They won’t have time for operational work. They won’t have time for consulting or providing technical services. They will either be auditing a customer, or they will be on a plane somewhere, or they will be writing or reviewing one of those 1000 pages tomes called the ROC.

e) We Want to Stick with our Customers

The bottom line is this. If we hadn’t found a trusted QSA whom we can work with and who are mostly on the same page as us, we would have gone and gotten our QSA ourselves and went another direction. I think we have enough legs and enough entrenchment in the region and global to do that. But we found a great partner. We found a QSA that we could work with and didn’t do any BS work. We found a QSA that had similar philosophies (although we are still working in synching our concept of deadlines, but hey, that’s like marriage, ain’t it) – and for 7 years, we have been working great together. They like what we do, that they can hands off a lot of the remediation advisory to us and don’t have to get on conference calls all the time or have to fly in and out of our client’s offices for weekly meetings. We like that we can work with our customer, look after our client’s interest and not worry to much about whether we are overstepping our limits as advisors or consultants versus auditors. We can stick with our customers and give them all we have. We can spend a whole day in our customer’s premise working with them without worrying that we need to head off for an audit for 2 weeks in Timbaktu. We don’t have to fly in and out of countries or tell our clients we can only meet 2 weeks later. If you want us within 24 hours, we will have someone there. Best of all, it’s very clear that once auditing starts, we are sitting on the side of our client, and ensuring that our client have what it takes to pass PCI-DSS.

Of course, this is simply our view at this current time. We are well aware of the flowing and ebbing of different forces in our industry and it might come a time whereby this model doesn’t work anymore. But for now, honestly, we just want to get cracking at troubleshooting your Cisco ASA as opposed to writing a War and Peace Novel. Drop us a note at pcidss@pkfmalaysia.com for more information!

PCI-DSS and how we messed up the scope

pci-compliance

Reflecting on challenges of a recent PCI-DSS project for a client and the key learning points for an effective implementation

People team challenges – having a team to champion the project

When we started the PCI project, we were faced with multiple changes in the client’s project manager and so the project was like a car unable to start on a cold morning (for those old enough to remember there were such cars back in the 80s!).

Eventually, by working with the client, the musical chairs stopped and we had a stable project team to champion the PCI-DSS project.

The importance of the scope

By then, so many changes had been made in the systems and people that we were asked to rescope the work.  Now, scope in any PCI-DSS project is absolute key. If you start wrongly, you will definitely go down the rabbit hole and never come out.

(Mis)Understanding the process flows

The client described how the credit card data was fed into their system through the credit card terminals connected to their POS systems in their nationwide store network.

Initially, we were quite surprised that credit card data would be flowing back into the retailer’s system so they could do their reconciliation.  Our experience suggested that retailers would simply transit credit card information through the credit card terminals to the acquiring bank and then receive back a transaction ID or approval code.

Further enquiries got the same answer and we were assured that the information would be ‘encrypted’ and stored in ‘encrypted’ form.

On the basis of their answers, the client expected to undergo an onerous Self-Assessment Questionnaire, consisting of over 320++ questions!

Managing information

Our team took their word for it, and began the project by asking them to draw out their process flows so we could assist them in scoping their systems and completing an asset inventory (a key part of the PCI-DSS programme) together.

And this was where things got a little messy.

Because they insisted the credit card terminals that were interacting with the cards belonged to the acquiring bank and they had no influence over it, they did not have an asset list.

Also, with a significant number of branches it was difficult to provide an asset list to cover all relevant hardware and software across the portfolio.

The pushback caused the project to once again grind to a halt. Without a scope confirmation, we could not start any PCI implementation for them, in case we over-committed or under-committed on the plan.

Benefits of documenting process flows

The project was being worked out at management level for a long time before it was brought up to the director level, but once it did, things began to move.

We decided to go on the ground to a few of the store locations to really see what was going on.

What we found out surprised everyone:

Credit card information indeed never flowed back into the client’s system!

Getting the terminology right

The so-called ‘encrypted’ credit card information from the bank that was supposedly sent back to the client after the authorization, was in fact, ‘truncated’, not ‘encrypted’.

Apparently, the client had thought these were the same thing.

In PCI speak, encrypt means to protect credit card details by making the information unreadable with a key. The main reason is that there is a need to ‘de-crypt’ the information back again.

Truncation, on the other hand, meant that the card number itself, when sent has already its numbers ‘X’ed out. This is different in a sense that truncated card information is NOT card information because the critical numbers have already been X’ed out, leaving (usually) just first six and last four numbers of the credit card number visible.

Immediately, it was like a light being flipped on.

The team worked hard to optimize the scope by confirming the other flows and observing live transactions take place.

At the end of a 2 day onsite scoping assessment, we concluded that this client was eligible for a much reduced – only around 80 questions – assessment and then by filtering further, we pared down their compliance questions to only 40 reducing the scale of this compliance project by more than 85%.

Key messages

The takeaway here, from our experience would be:

  1. All PCI-DSS assignments require a stable and strong project team – get the right people, in the right place, with the right focus
  2. Understand the client’s terminology and descriptions and then check and check again. Ensure that you start from the best position, and not chasing the wrong end of the stick.
  3. For PCI-DSS merchant compliance it is essential to explore if the client is eligible for any reduction in the scope and don’t just go with the default. The time and cost elements of getting this wrong could be very substantial.
  4. Nothing beats being onsite and to undertake live walkthroughs of the actual processes. In this case, the earlier the better, so the assignment can be properly scoped.  A different set of eyes might be able to unlock the project obstacle – and in our case, it was essential to have the onsite scoping exercise.

Finally, because of these findings, the compliance is now ongoing and finally we are seeing the light at the end of the tunnel.

If you have any queries on your scope or compliance on PCI-DSS, drop us an email at pcidss@pkfmalaysia.com and we will get back to you ASAP.

Tonight, I Wanna Cry

There is a country song that goes:

I’ve never been the kind to ever let my feelings show,
And I thought that being strong meant never losin’ your self control
But I’m just drunk enough, to let go of my pain,
To hell with my pride, let it fall like rain, from my eyes,
Tonight I wanna cry.

And cry they did. Almost 75,000 and counting, over 99 countries hit by one of the largest ransomware attacks of all time, “WannaCry” and the other Wanna* variants.

Wannacry was released on the 12th of May 2017. The irony of it all was that we were invited as one of the speakers in a Ransomware event in Putrajaya under Panda Security the day before and we were just warning those in attendance that the next wave of ransomware is due to hit and within 24 hours, bam, we have Wannacry. In Malaysia, there seems to be already infection, thanks to the guys at

https://intel.malwaretech.com/botnet/wcrypt/?t=24h&bid=all

There have been reports of large telecommunication companies, banks and telcos are being affected. Tens of thousands of networks worldwide have been hit and the attacks do not appear to be targeted to any specific region or industry. Once infected, victims are asked to pay approximately $300 by Bitcoin. For the curious, you can check

https://bitref.com/13AM4VW2dhxYgXeQepoHkHSQuy6NgaEb94

This means there is around 5.8348 bitcoins paid already to this. Which translates to around RM46,000 paid so far – which isn’t so much if you think the average of ransom payment is around RM10,000 – RM11,000 for other ransoms.

So what is this?

Wannacry is using the file extension .wncry, and it also deletes the Shadow Copies (which is normal for ransomwares, like Locky) which is a technology introduced into the Microsoft platforms as far back as Windows XP and Windows Vista as the Volume Shadow Copy service. This means that even backup copies produced by this service, such as Windows Backup and System Restore will be screwed. That’s mean. Here is the command executed.

cmd.exe /c vssadmin delete shadows /all /quiet & wmic shadowcopy delete & bcdedit /set {default} bootstatuspolicy ignoreallfailures & bcdedit /set {default} recoveryenabled no & wbadmin delete catalog -quiet (PID: 2292)

The following file is also created in the affected systems: @Please_Read_Me@.txt

How it gets in is just like any other ransomware: email either phishing or spear phshing. Basically, don’t click on any email attachments that are suspicious! It’s easier said than done, especially if you see one coming in stating that you are behind in your payments for your credit card. Resist the urge. One of the things to check on email:

The return email – most phishing doesn’t even attempt to spoof their email, and you will get emails coming from strange domains like maaybank or clmbclicks. Bad language is also a hallmark of a phishing email. “All your base are belong to us” type of english. Anyone asking for passwords, or click on a link etc is nonsense. Don’t click on email links. Don’t click on the attachments, above all.

Back to Wannacry. It exploits a known Microsoft Windows vulnerability to spread. This vulnerability was released as part of the Shadow Brokers leaks back in April. It hits the SMB (Server Message Block) – some people pronounce it as SAMBA, which technically is not so correct, as SAMBA is the SMB implementation on Linux. It basically allows the sharing of files and printers in networked environment. Which means, if one gets infected, the infection spreads through network shares even to systems without connectivity to the internet.

Microsoft released a patch for MS17-010 on March 14th 2017. Obviously, a lot of systems – especially those in healthcare still runs on Windows XP. The case has been deemed so serious that Microsoft has taken the step to release patches for systems already dead like XP! This shows how unusually dangerous this ransomware is.

OK, so if you have been hit, what do you do?

Well, you can pay. Around 41 transactions have been made so you could make the number, but don’t expect too much out of it. In fact, we probably do not recommend this course of action. You need to remove Wannacry and there are plenty of sites that gives details on that. The problem with ransomware is not so much of removing it, its a matter of recovering your files. Here’s a site you can check if there is a decryptor available:

https://www.nomoreransom.org/crypto-sheriff.php

Please be careful – some so called ‘decryptors’ are disguised as further malware and gets you a double whammy of sorts, so you need to ensure these are proper tools and not something you download from torrent.

As an advisory to all our clients, especially PCI-DSS here’s what you can do to protect yourself:

a) PATCH

https://technet.microsoft.com/en-us/library/security/ms17-010.aspx

Now we see how important it is to patch your systems. Most PCI clients struggle on this and the examples can come from: Our servers are not connected to the internet, or If I patch, my application breaks. Well, if your application breaks then you need to get a warranty from your developers or get them to upgrade and improve.

b) Backup

While PCI doesn’t really focus much on backup or BCP (after all PCI’s interest is in the confidentiality of credit card and not the availability of your business) – it’s still good practice to backup your system. And not just online as ransomware hits shadow copies firstly – but offline backup and ensure your restoration has been tested. Remember those grandfather-father-son backup scheme you learnt in college and university? Yup, it can be applied.

c) Antivirus and Antimalware Updates

While it’s known Antivirus is missing a chunk of malware out there, it’s still for many systems the last line of defence and most vendors have released protection signatures for the ransomware so get it updated. It’s like having the final militia protecting against an invasion. It will probably not hold out forever, but at least it buys your administrators some time.

d) Remove SMB v1 support

https://support.microsoft.com/en-us/help/2696547/how-to-enable-and-disable-smbv1,-smbv2,-and-smbv3-in-windows-vista,-windows-server-2008,-windows-7,-windows-server-2008-r2,-windows-8,-and-windows-server-2012

Simply, for Windows 8 for instance, you need to run Powershell in administrator mode and then just issue

Set-SmbServerConfiguration -EnableSMB1Protocol $false

to disable SMBv1

e) Network segmentation

While this is helpful, it still doesn’t save everyone. Segmentation helps because it isolates computers. Vector of attacks usually comes into the access network (where end users access) and if you segment this from the critical systems, you will need the malware to traverse through your firewall or a filtering device in between which leads us to:

f) IDS, SIEM, IPS or any protection systems you have!

If you don’t have any IDS, IPS or SIEM deployed in your environment, it’s time you get one and this is a good argument for your business budget. IDS/IPS are usually available features in most firewalls these days, so if you segregate your networks, you can then enable these features and it should detect or prevent malware coming into your critical environment.

SIEM is critical. Security Information and Event Management systems have been around since the dawn of time but most companies avoid these due to costs, ever relying on the good old free syslog services. No, not allowed anymore, as far as PCI is concerned. We need more visibility over these logs, malicious traffic and even outgoing traffic to check if there is any communications with a command and control (C&C) server, which is the normal operations of these ransomware. SIEM these days are also no longer that expensive, with a Gartner SIEM like Alienvault starting off at a little over RM25K to get it up and running. We recently deployed a very large SIEM deployment over AWS cloud and on-premise on a major airlines with a fraction of the cost compared to traditional SIEM deployments.

There you have it. WannaCry is a very serious outbreak and we will be monitoring this system and also making our visits to our clients to give a short talk and description over it. If you have any questions over this, or on PCI-DSS or SIEM, drop us a note at avantedge@pkfmalaysia.com.

Stay safe!

PCI and Multi Processing Environments

PCI

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

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

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

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

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

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

The short answer is yes, you can.

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

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

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

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

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

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

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

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

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