PKF AvantEdge

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Why QSAs Matter in your PCI-DSS

April 3, 2024 / / 0 Comments

The questions we usually get asked, aside from why we prefer not to be a QSA (which, although it is fairly dated and need to be revised, have been answered), despite us doing PCI-DSS since 2012 in Malaysia, is why we hardly work with different QSAs in our PCI-DSS projects. Aren’t all QSAs the same? Aren’t all created equal?

Like everything in life, there are basis of variation. We are not here to say which is better, which is worse. It’s not in our culture to constantly provide a barrage of negative statements in regards to other companies and organizations, even with basis — because that’s not how we are wired.

That being said, we do have an internal list of companies (and QSAs) that we would perhaps have some less inclination to. This is due to either working firsthand with them, or mainly seeing some of the results of their work. Quite shocking some of the things we see. Additionally, we have also had clients who had suffered under their so called advisory and have asked us to step in for help.

So to the query on which QSA should you spend the next six months (or more) months with for your PCI Project? Let’s put a few options forward in a more quantifiable manner.

a) Experience

A question we get asked is why we generally don’t just work with local providers or assessors who are closer to home. It’s not because they are worse or better. It’s like comparing cars. They all have their pros and cons – we do not slag organizations off even if we would rather avoid some of them. But one way I would tell customers is, let’s look at experience first.

As of writing, we have 3065 PCI-DSS listed projects based on the Visa Provier List at https://www.visa.com/splisting/searchGrsp.do. The top 10 assessors on this list is as follows:

AssessorProjects
VikingCloud208
Foregenix142
ControlCase 113
SECTEC103
Compliance Control96
Coalfire Systems86
SISA 83
A-LIGN80
CIPHER 71
atsec 71
Total1053

The top 10 assessors make up almost 35% of the projects listed. Those are heavy hitters. Suffice to say a lot of projects remain unlisted – level 2 Service providers, SAQ projects, Merchant projects etc. So actual projects (included non listed) for each assessor is probably a lot higher. To put in context, there are the following numbers of projects for assessors:

ProjectsNumber of Assessors
154
235
325
422
518
613
713
87
910
103

There are 200 Assessors out there with 10 or less projects listed. In defence, some of these are actually the same company under another name, so it’s not like 100% accurate in terms of this overview. So out of 262 assessors in that list that does PCI, 77% of them have 10 or less projects, showing that it’s not that easy to get that number to a 100 or more. Again I will reiterate, quantity doesn’t automatically means it’s better. Some may argue, the more projects you have, the more quality is suffered. That is a good point. And I have experience with some of the overseas QSAs in that smaller project number group that I would gladly give a project and have a beer with. They are really good and extremely passionate about PCI-DSS and I’ve learnt truckloads from them. We are just saying this is one starting indicator you may want to jump from because most service providers start off with this off the bat when they are presenting their services: how many customers ‘trust’ them.

b) Location

This is slightly misleading in a sense that the query we ask is: do we need a QSA who is local? Local here would mean they have an office in the country they are serving the customer in. This argument, while it seems to initial hold some credence, is actually self defeating. And a bit strange, when most organisations now prefer to be known as regional or global, instead of touting themselves as just local players. If they use this as a plus point, then by going to their overseas customers, they are technically disputing the same argument point they are advocating. Most QSAs won’t use this track because they know that a QSA company needs to at the very least operate regionally, or if you want to be focused on a country – then, fine, take USA. The reason why the service provider list does not have a breakdown of all 195 countries (or if you are a Malaysian Minister, then that would be 500 countries) of Earth is that being a QSA is tough work. The breakdown is in regions and the only countries listed there are US and Canada because US makes up almost 35% of the listed projects there.

Think about the last time you dealt with a QSA. Did you have access to that QSA through messages or call? Did you call for a meeting and that QSA came as required? Did that QSA respond quicker? Was that QSA able to reply your queries, technical or otherwise related to your compliance in clear and consistent manner? Did they insist on you paying them more for advisory or delayed your project? Did they upsell more services to you that was unplanned and unknown? Think about the positives and negative experience you had.

Those are more pertinent queries than deciding someone to be ‘local’. That point is actually really moot. Because in almost all projects, the bulk of the work will be handled by a consultant. QSAs by definition should be global or regional anyway. In the economics of being a QSA (explored in another article), being a QSA operating in a single country would probably not be cost sustainable. Especially in a country where the currency is slightly more than the value of a turnip. So the assessor will still have to be flying to other places anyway. Therefore, it doesn’t really matter whether its local, regional or global when it comes to being an assessor, the question is how accessible and communicable they are.

In that sense, we strike a balance – we are local to Malaysia, or any other country that we operate in (we have presence in 150 countries as a global network), and we provide the independent, technical advisory needed to be consultants. We are not QSAs so we don’t need to be pulled all over the place in other PCI projects all over helter-skelter. We are all certified in various certifications and more product certs that I can throw a stone at. We are operational people all with more than a decade of experience so you won’t have a wide-eyed associate with a checklist coming to you. We also have non-IT services as we are also tax advisors, corporate financiers, risk managers, compliance directors – we aren’t just an IT company aiming to push IT services or cybersecurity solutions for you – our DNA is in advisory and consulting.

Enough of blowing our own horn then. Which leads me to item 3:

c) Reference

It’s important to not just look at a list of customers. I have a client who gets annoyed with seeing a presentation with a list of logos without any context of the work. Some may list down large companies or merchants under their so called ‘Customer’ but without any context. You know what? Fine. I can list down all telcos, up to twenty PLCs, more than half a dozen of oil and gas and more banks than I can swing a bat at just because I have given them ‘training’. Come on.

Look past that veneer and look at actual references in the industry. Is there a positive experience? Is there someone out there willing to endorse good will? Are there any bad experiences? Another area I got asked is, if the assessor has been involved in a breach before. This almost needs a new article to explore. Look, we all know PCI doesn’t guarantee non-breach. It’s not a panacea to world hunger. Its more important to note that what is the outcome of the investigation or forensics before we go witch hunting. It’s meaningless to state for instance, the top QSAs would never experience any breaches in their existence. For sure, some of them would need to deal with this one way or another and to see if indeed there was an oversight. If there’s none, then the breach could be down to myriad of reasons outside of PCI-DSS control. Remember – assessors are not operational. They enter an audit in good faith. Witchunting a QSA just because of a breach involvement without context or having the final conclusion is a narrow minded, irresponsible approach to assessing capability (or culpability). If the QSA is truly to blame, wouldn’t they be put in remediation by the Council? There you go.

One thing you will never catch us doing is giving an opinion about certain things that we don’t have the full context on. It’s simply not something we are comfortable at. If we see some issue with a report from other QSAs, even if it looks strange, the reply is always: what is the context of this, and there must be a reason why it was interpreted as such. So that gives us a more balanced view and not just mouth off without understanding. As the proverbs say: “The more talk, the less truth; the wise measure their words. “

d) Cost and Resources

Most PCI projects have the conflicting pull of cost and resources. A QSA with a lot of resources and consultants will be very useful. The last thing you want to see is a QSA not responding and after 3 months rushes you for evidences. Cost still plays a huge role in PCI-DSS and it’s not as if things are getting cheaper. With version 4.0, there is more work for QSAs to do and they likely will pass down some of these costs to the customers. This still remains a very subjective item in this filtering exercise — a QSA charging your liver and kidney for PCI isn’t ideal, but if a QSA comes in with a price that resembles a popsicle in a flea market, I would likely stay away as well. We all know how much effort PCI is. We don’t want a situation where halfway through, the bulk of invisible costs comes pouring in like the army of Mordor, or else things will not be done. If you want to build your house, have most of the materials cost sorted out. If there is a VO, don’t let it cross a threshold of percentage of your initial cost. Having a QSA who understands this and is willing to negotiate is important. Even if the cost is not lowered (because to be fair, QSA work is not trivial), then negotiate for future services, or better payment terms – anything else to meet in the middle.

e) Stamp of Trust

Are there any stamps of trust for QSAs?

No, there isn’t. At least not officially. However, I would like to highlight there is this thing called Global Executive Assessor Roundtable (GEAR) found here: https://www.pcisecuritystandards.org/about_us/press_releases/pci-security-standards-council-announces-2022-2024-global-executive-assessor-roundtable/

There are 28 QSAs in the GEAR currently, with the purpose below:

The Roundtable is an Executive Committee level advisory board comprised of senior executives from PCI SSC assessor companies. The 2022-2024 GEAR consists of 28 organizations, with the Roundtable term running 1 September 2022 – 31 August 2024.

“The Council depends on the input of a wide range of stakeholders to provide PCI SSC with valuable insights,” said PCI SSC Executive Director Lance J. Johnson.” With the release of version 4.0 of our PCI Data Security Standard this year, it is even more important to have active representation from every corner of the globe from an assessor perspective. Assessors are critical in assisting the Council with our effort to improve and evolve payment data security.”

PCI COUNCIL

The QSA we often work with, Controlcase is one of them, and have been reappointed, pointing out that in terms of reference, the Council considers their input as ‘valuable insights’. This is one of the list we look at, especially when requested about QSAs. Are they involved in GEAR?

IN SUMMARY

Like choosing a car, there is really no guarantees actually that your experience will be immaculate when it comes to PCI-DSS considerations. The above are just possible filters you can decide on when it comes to choosing your next QSA partner to embark your journey on. Or you can roll a dice or consult with the gods. Disclaimer of course is that we have not worked with ALL QSAs yet, so this still remains a rudimentary filter when you are thinking of a QSA. Find a QSA that can actually do the hard yards and have proven themselves with Project references and quality, Global Reach and experience, Positive Customer feedback and respect from the industry and finally, seen as an invaluable assistant to the almighty PCI Council themselves. In our personal opinion, it’s a start to look at these metrics and springboard from there. Because anyone can give a nice presentation or dress in a suit or talk negatively about other companies — but what are their numbers, references and contribution to the PCI council?

Drop us an email at pcidss@pkfmalaysia.com to learn more about PCI and other compliances like ISMS or ITSM or SOC!

The Question of QSA Conflict

March 19, 2024 / / 0 Comments

An interesting conversation over coffee with a client today gave me something to mull over a little. The question brought to the table was how some assessors, while engaged in audit, brought up other services they offer like ASV, penetration testing and vulnerability scan and how this may look like a conflict of interest issue.

I will start first by proclaiming that we aren’t QSAs. We do have a myriad of certifications such as ISO and other personal certs in information security, but this article isn’t about our resume. It’s the ever important question of the role of the QSA and whether they should be providing advisory services.

Why we choose not to go the route of QSAs is for another article, but suffice to say, in the same regard we work with CBs for ISO projects, we employ the same business model for PCI or any other certification projects. We rabidly believe in the clear demarcation of those doing the audit and those doing the implementation and advisory. After all, we are in the DNAs of statutory auditors and every single customers or potential customers we have require a specific conflict check, in order to ensure independence and not provide consulting work that may jeopardize our opinions when it comes to audit. Does anyone recall Enron? Worldcom? Waste Management? Goodbye, 90 year old accounting firm.

We have worked with many QSAs in almost 14 years of doing PCI-DSS – and here, QSAs I mean by individuals as well as QSA-Cs (QSA Companies). Our group here is collectively made up of senior practitioners in information security and compliance, so we don’t have fresh graduates or juniors going about advising 20 years plus C level veterans on how to run their networks or business.

A QSA (Qualified Security Assessor) company in a nutshell is a company that is qualified by the PCI Security Standards Council (PCI SSC) to perform assessments of organization against the PCI standards. Take note of the word: QUALIFIED. This becomes important because there is a very strict re-qualification program from the PCI-SSC to ensure that the quality of QSAs are maintained. Essentially, QSAs are vouched by the PCI SSC to carry out assessment tasks. Are all QSAs created equal? Probaby not as based on our experience some are probably better than others in specific aspects of PCI-DSS. Even the PCI SSC has a special group of QSAs under their Global Executive Assessor Roundtable (GEAR), which we will touch on later.

The primary function of a QSA company is to evaluate and verify an organisation’s adherence to the PCI DSS requirements. This involves a thorough examination of the organisation’s cardholder data environment (CDE) — including its security systems, network architecture, access controls, and policies — to ensure that they meet the PCI requirements.

Following the assessment, the QSA company will then prepare a Report on Compliance (RoC) and an Attestation of Compliance (AoC), which are formal documents that certify the organization’s compliance status. Please don’t get me started on the dang certificate because I will lose another year of my life with high blood pressure. These OFFICIAL documents are critical for the organization to demonstrate the company’s commitment to security to partners, customers, and regulatory bodies. The certificate, however, can be framed to be hanged on the wall of your toilet, where it rightfully belongs. Right next to the toilet paper, which has probably a slightly higher value.

Anyway, QSAs have very specific roles defined by the SSC:

– Validating and confirming Cardholder Data Environment (CDE) scope as defined by the assessed entity.
– Selecting employees, facilities, systems, and system components accurately representing the assessed environment if sampling is employed.
– Being present onsite at the assessed entity for the duration of each PCI DSS Assessment or perform remote assessment activities in accordance with applicable PCI SSC assessment guidance.
– Evaluating compensating controls, as applicable.
– Identifying and documenting items noted for improvement, as applicable.
– Evaluating customized controls and deriving testing procedures to test those controls, as applicable.
– Providing an opinion about whether the assessed entity meets PCI DSS Requirements.
– Effectively using the PCI DSS ROC Template to produce Reports on Compliance.
– Validating and attesting as to an entity’s PCI DSS compliance status.
– Maintaining documents, workpapers, and interview notes that were collected during the PCI DSS Assessment and used to validate the findings.
– Applying and maintaining independent judgement in all PCI DSS Assessment decisions.
– Conducting follow-up assessments, as needed

QSA PROGRAM GUIDE 2023

You can see above, there is no advisory, recommendation, consultation, implementation work listed. It’s purely assessment and audit. What we do see are more often than not, QSAs do offer other services under separate entities. This isn’t disallowed specifically, but the SSC does recommend a healthy dose of independence:

The QSA Company must have separation of duties controls in place to ensure Assessor Employees conducting or assisting with PCI SSC Assessments are independent and not subject to any conflict of interest.

QSA Qualification requirements 2023

Its hard to adjudge this point, but the one providing the audit shouldn’t be the one providing the consultation and advisory services. Some companies get around this by having a separate arm providing special consultation. Which is where we step in, as without doing any gymnastics in organizational reference, we make a clear demarcation of who does the audit and who does the consultation and advisory role.

The next time you receive any proposal, be sure to ask the pertinent question: are they also providing support and advisory? Because a good part of the project is in that, not so much of the audit. We have actually seen cases where the engaged assessor flat out refused to provide any consultative or advisory or templates or anything to assist the customer due to conflict of interest, leaving the client hanging high and dry unless they engage another consultative project with them separately. Is that the assessor’s fault? In theory, the assessor is simply abiding with the requirements for independence. On the other hand, these things should have been mentioned before the engagement, that a bulk of the PCI project would be in the remediation part and definitely guidance and consultation would be needed! It might reek of being a little disingenuous. It’s frustrating for us when we get pulled in halfway through a project and we ask, well why haven’t you query your engaged QSA on this question? Well, because they want another sum of money for their consultative works, or they keep upselling us services that we are not sure we need unless we get their advisory in. What do you think their advisory is going to say? You can see whereas on paper, it might be easy to state that independence has been established, in reality, it’s often difficult to distinguish where the audit, recommendations, advisory and services all start or end as sometimes it’s all mashed. Like potatoes.

Here’s the another official reference to this issue in FAQ #1562 (shortened)

If a QSA Employee(s) recommends, designs, develops, provides, or implements controls for an entity, it is a conflict of interest for the same QSA Employee(s) to assess that control(s) or the requirement(s) impacted by the control(s).

Another QSA Employee of the same QSA Company (or subcontracted QSA) – not involved in designing, developing, or implementing the controls – may assess the effectiveness of the control(s) and/or the requirement(s) impacted by the control(s). The QSA Company must ensure adequate, documented, and defendable separation of duties is in place within its organization to prevent independence conflicts.

FAQ #1562

Again, this is fairly clear that QSAs providing both assessment and advisory/implementation services are not incorrect in doing so, but need to ensure that proper safeguards are in place, presumably to be checked thoroughly by their requalification requirements, under section 2.2 “Independence” of the QSA requalification document. To save you time on reading, there isn’t much prescriptive way to ensure this independence, so we’re left to how the company decides on their conflict of interest policies. Our service is to ensure with confidence that the advice you receive is indeed independent and as much as we know, to benefit the customer, not the assessor. We don’t have skin in their services.

In summary, QSAs can theoretically provide services but it should come separately from the audit, so ensure you get the right understanding before starting off your PCI journey. Furthermore and more concerningly, we’ve seen QSAs refused to validate the scope provided to them, citing that this constitute ‘consulting and advisory’ and needs additional payment. This is literally the first task a QSA does in their list of responsibility, so call them out on it or call us in and let us deal with them. These charlatans shouldn’t even be QSAs in the first place if this is what they are saying.

And finally, speaking on QSAs that are worth their salt – the primary one we often work with Controlcase has been included in the PCI SSC Global Executive Assessor Roundtable 2024 (GEAR 2024).

https://www.pcisecuritystandards.org/about_us/global_executive_assessor_roundtable/

These are nominated as an Executive Committee level advisory board comprising senior executives from PCI SSC assessor companies, that serves as a direct channel for communication between the senior leadership of payment security assessors and PCI SSC senior leadership.

In other words, if you want to know who the SSC looks to for PCI input, these are the guys. Personally, especially for complex level 1 certification, this would be the first group of QSAs I would start considering before approaching others, as these are nominated based on reputation, endeavor and commitment to the security standards — not companies that cough out money to sponsor events or conferences, or look prominent in their dazzling booths, give free gifts but is ultimately unable to deliver their projects properly to their clients.

Let us know via email to pcidss@pkfmalaysia.com if you have any queries on PCI-DSS, especially the new version 4.0 or any other compliances such as ISO27001, NIST, RMIT etc!

An Ode to the Invalid Certificate

April 19, 2023 / / 0 Comments

Once upon a time, in a not-so-faraway land of PeaCeEye, merchants, credit card transactions, online payments, payment gateways, POS terminals all lived in harmony. In this land, all citizens carry a trust symbol, held together by validation documents, called the Citizen Badge. However, PeaCeEye is now facing an existential threat. A threat shrouded in the cloak of validation, a false symbol of security and trust – called the Certificate. But, dear reader, beware! For this tale of caution and deception, and the Certificate, much like the elusive unicorn, while tangible, carries a false value – nothing more than a fabrication. A figment of imagination, conjured up by the minds of its idle creators, the Qessays.

You see, in the kingdom of PeaCeEye, there exists a council – a council of wise men and women who determine the rules and regulations that govern this realm. This council, known as the Secret Sorceror Council (SSC), has decreed that only three sacred documents hold the key to validation for the Citizen Badge – the Attestation of Compliance (AoC), the Report on Compliance (RoC), and the Self-Assessment Questionnaires (SAQs). Yet, despite the council’s resolute stance on this matter, a mysterious fourth document continues to emerge from the shadows – the Certificate.

Ah, the Certificate, a work of art crafted by the Qessays. You see, these Qessays were charged by the council to uphold what is truthful and right, and to ensure that all Citizens of PeaCeEye are identifiable by their Citizen Badges – The AoC, Roc and/or the SAQs. However, over the years, some of these noble Qessays have turned to the darkside and the sinister art of producing corrupted documentation, called the 4th deception, or the Certificate as it is now known. These dark Qessays have mastered the art of illusion, conjuring certificates out of thin air to dazzle their customers. They’ve become modern-day alchemists, turning mere paper and ink into a symbol of validation, which, in reality, is as weightless as a feather and as useful as a chocolate teapot. Or a fork and spoon when eating Chapati. It’s a thing of beauty, destined to hang on the walls of businesses, gracing them with its shimmering falsehoods.

But why do these Qessays continue to spin their webs of deception, offering their customers a document that has no merit in the eyes of the SSC? Something that even invalid citizens to PeaCeEye can procure? To unravel this mystery, we must dive into the murky depths of human nature. For, you see, people are drawn to shiny, pretty things, much like moths to a flame. A certificate, with its elegant calligraphy and embossed seal, is a testament to the allure of appearance over substance. It is a tangible representation of validation, regardless of its actual worth.

Moreover, the Certificate serves as a placebo, a sugar pill of sorts, which instills in businesses a false sense of security. It is a talisman that they cling to, convincing themselves that they are protected from the malicious forces of the World beyond PeaCeEye – the World called Cyberattacks. And, in the process, they become blind to the fact that the true power of validation lies in the sacred trio of documents – the AoC, RoC, and SAQs.

Now, one might argue that those who peddle these invalid certificates are merely fulfilling a demand. After all, the customer is always right, and if they desire a shiny piece of paper to adorn their walls, who are we to deny them? But, as the saying goes, “With great power comes great responsibility.” And these Qessays, as the gatekeepers of the citizenship of PeaCeEye, must hold themselves to a higher standard.

By offering these overvalued and useless certificates-that even the SSC had themselves admonished and had announced to the citizens to not place any value to them- these certificates not only betray the trust of customers but also undermine the very foundation of Citizen Badge. They turn the realm of PeaCeEye into a farce, a stage where pretenders masquerade as protectors, and businesses are lulled into a false sense of security. There are even Qessays who are not even involved in the process of validating an SAQ being answered; luring their customers to portals with questionnaires answered by the citizen themselves and then conjuring these certificates that look as if it has been validated by the Qessays, but instead are just self aggrandizing papers that has been only self validated by the person answering their own questions! In other words, the person becomes their own judge and jury and are able to produce a Certificate that looks as if they have been properly validated by a third-party Qessays. Amazing art! An ostentatious object of grandeur and magnificence, yet with all the actual value of a discarded banana peel withering in the Sahara sun.

But, dear reader, do not despair, for there is hope. You see, the truth has a funny way of revealing itself, much like the sun breaking through the clouds after a storm. And, as the truth about the invalidity of these Certificates spreads, businesses will begin to see through the veil of deception, and the demand for these counterfeit documents will wane. Qessays who persist in peddling these worthless certificates will find themselves exposed, their credibility crumbling like a house of cards.

In the meantime, we must not sit idly by, complacent in the face of falsehoods. Instead, we must raise our voices and spread the word, educating businesses on the true path to Citizen validation. We must sing the praises of the AoC, RoC, and SAQs, enlightening those who have been led astray by the allure of the invalid certificate. For it is only through knowledge that we can pierce the veil of deception and lay the mythical beast of the Certificate to rest.

So, let us embark on this crusade together, wielding the sword of truth and the shield of knowledge. As we march forward on this noble journey, let us remember the wise words of the SSC: “Trust, but verify.” Let us tear down the great wall of this Certificate, brick by brick, and replace it with a fortress built on the solid foundation of the council’s sacred trio of documents. And as we watch the last remnants of the Certificate crumble to dust, we will know that we have triumphed over the forces of deception.

We bid farewell to this Certificate, and to welcome a new era of transparency, security, and trust. An era where the mythical beast of the Certificate is relegated to the annals of history, and where the true power of validation is embraced, in all its glorious, council-approved forms. May the sacred trio of documents – the AoC, RoC, and SAQs – guide us on our path to a brighter, more secure future, and may the Certificate forever remain a cautionary tale of the perils of deception and the triumph of truth.*

** The above is written obviously in satire and tongue-in-cheek with absolute no journalistic value nor based on any real world reimagination and solely based on our absolute frustration at the continuous dependence and insistence from acquirers or banks to have our customers produce them ‘certificates’. In addition, some clients even go through self-service portals provided by QSAs and answer SAQ questions on their own, at the end of this process of self answering, a certificate is produced. Granted, the certificates do come with disclaimers in small prints stating that the certificate is actually based on self assessment and even admits that it isn’t recognised by the council.

But in reality, who actually reads the fine print?

In the end, anyone having gone through these ‘compliance’ portals, answering affirmative to everything would be able to procure these certificates and remarkably, some acquirers even accept them as proof of third party audit (which they are clearly NOT). Again, we are not stating that QSAs providing this service is doing anything wrong. There is nothing essentially wrong with certificates on its own, or QSAs providing these certificates as a simple means to show a company has undergone PCI-DSS compliance. But where it becomes a gray area is when there is too much dependence placed on these certificates to the point where even the AoC is rejected and acquirers insist on every company showing them these certificates. In this case, QSAs who are willing to provide so called certificates to companies without having undergone any assessment and only answering questions from the SAQ based on their own knowledge or whim – unless the QSA is willing to go through each question of each customer and validate these through evidence submission and review (the process called audit); then these creation of self signed certificates should be stopped. It’s akin to a banking website issuing a self-signed SSL cert on their own website and tell everyone to trust it. Does this happen in the world of e-commerce? No, it’s absurd. Then why is it different in the world of compliance? Why is this practice still allowed to prosper? How do we stop this practice?

We have been advocating removing certificates for years now from the PCI-DSS landscape and to have a more consistent and acceptable way to show PCI validation. Unfortunately, unlike the satirical tale above, this still eludes us. Drop us an email at pcidss@pkfmalaysia.com if you have any ideas and comments to this!

Do or Do Not – ASV for SAQ A

July 24, 2021 / / 0 Comments
pci-compliance

I would have thought this debate died out with the extinction of dinosaurs, but apparently, we are still at this subject in 2021. Still. Going. On.

So in the past weeks, there were some debate between us and some consultants as to whether the SAQ A requires an ASV scan or not. Our position was No. Their position was yes. So let’s look at it.

Now, keep in mind, we aren’t talking about best practice. We are talking about PCI-DSS v3.2.1 and what it says about ASV scans being mandatory for SAQ A. That’s it. That’s the statement. Now, debate.

There is actually no debate. This isn’t some sort of grey area, hard to explain, obscure rule in Sanskrit and written on the Sankara stones. This is just: Look at SAQ A, search for ASV, don’t find it. Thank you.

The ASV requirement is present in item 11.2.2 of PCI-DSS.

SAQ A does not have it.

So why do consultants still insist people do ASV scans for SAQ A?

There could be a lot of reasons, ranging from ‘guideline’, ‘best practice’ and so on. No doubt, having a scan (which isn’t expensive in any case) would be the least effort of security done by the merchant if they are hosting an e-commerce website that is redirecting customers to their payment processor once the “Click here to pay” is clicked. I mean, even if it has nothing to do with PCI, it may seem like common sense to have at least a scan done on your site to ensure it passes the very minimal requirement of security. So do we advocate an ASV scan to be done on any e-commerce site that deals with payment options (not necessarily payment data)? Yes, we do. There are many ways a site may get compromise. A coding error may allow data to be siphoned off, or passwords may be compromised. A re-direct may be vulnerable to man in the middle attacks; or even a total redirect to another page altogether where payment data is inadvertently entered. While the e-commerce site may be outsourcing the payment part to a processor, it still has the job of redirecting traffic to it.

Think of it as an usher (not the singer, but the job); where you enter into a dark auditorium, let’s say Royal Albert Hall to watch Ed Sheeran – and the usher takes you through this row of lights to what is supposedly your seat which you paid RM10,000 for.

When the lights come on, you find yourself in nice cosy room and in front of you someone who seemed to resemble Ed Sheeran but slightly off. His hair isn’t ginger and he isn’t as chubby as you see that guy on TV and he speaks with a slight Indian accent. And isn’t the Royal Albert Hall a HALL? Why are you in this room that resembles a glorified grandmother’s living room? You find out later that the usher had led you through the wrong Hall into a neighboring pub attached to the side of the hall and you are listening to the wonky music of Eddy Shiran.

The point is, the usher is pretty important in leading people to their seats. So as a redirect, even though you aren’t the main draw, you could end up leading your customers to Eddy Shiran instead.

But back to the main debate, whether it is required for SAQ A customers to go through ASV? No, it’s not.

However, there is always a but in everything. There are exceptions.

Some acquirers make it a point to state that they still require an ASV report even if merchants are going through SAQ A. That’s completely fine because the guidelines from Visa/Mastercard are just guidelines. At the end, the acquirer or payment brands may make individual decisions based on merchants, so it’s not written in stone. However, if there are no such requirement, we’re left to interpret the SAQ as it is, and it doesn’t state anything there.

Some may point out within the SAQ A under part 3a, there is a statement

ASV scans are being completed by the PCI SSC Approved Scanning Vendor (ASV Name)

Triumphantly being pointed out as proof of ASv requirement

Take note however, that above, under Part 3a, the instructions do state:

Signatory(s) confirms:
(Check all that apply)

the realisation that asv is still not needed for Saq A (or B)

Even under the title “PCI DSS Self-Assessment Completion Steps” of the SAQ:

Submit the SAQ and Attestation of Compliance (AOC), along with any other requested documentation—such as ASV scan reports—to your acquirer, payment brand, or other requester.

It does seem to be grappling at straws if this sentence was used to justify the requirement for PCI-DSS. “Such as” generally denotes an example, which may or may not exist or is required.

In previous requirements of merchants from Visa, there used to be statements describing merchant levels such as 

 * Merchant levels are based on Visa USA definitions
** The PCI DSS requires that all merchants perform external network scanning to achieve compliance. Acquirers may require submission of scan reports and/or questionnaires by level 4 merchants

And perhaps there is where the myth was perpetuated from. In recent times Visa has updated its site (https://www.visa.com.my/support/small-business/security-compliance.html) to reflect a better understanding, stating:

“Conduct a quarterly network scan by an Approved Scan Vendor (“ASV”) (if applicable)”

In conclusion, SAQ A and B do not require ASV scans. If it’s required by the acquirer then so be it. If it’s supposed to be done out of best practice requirements, so be it. But you don’t want to hear an ASV/QSA telling you that you need to do something that is above and beyond your PCI requirement without them pointing to something in the standards that states so.

Finally – for SAQ B, which usually applies to POS terminals dialing up to the bank for authorisation; we’ve even seen some consultants requiring the merchant’s website to undergo ASV, which has nothing to do with their POS Terminals. Why ASV the website? Don’t know. So the merchants go about scanning their website that hasn’t been updated since 2012 and wonder, what sort of nonsensical requirement is this from PCI-DSS that needs them to pay just to scan something that is built by an 18 year old intern who had left the company 10 years ago? You don’t need to. So don’t do it.

Anyway, that’s it for now. Let us know your thoughts or questions and send to us at pcidss@pkfmalaysia.com and we will get back to you ASAP. Now, back to listening to our Spotify for Eddy Shiran!

Clarifying ASV Scans

April 3, 2020 / / 0 Comments

It has been a while since our last post but as we are getting back up to speed to restart our work, our email engines are churning again with a lot of queries and questions from clients and the public on PCI-DSS, ISMS, ITSM, GDPR matters. We even have an odd question or two popping up regarding COVID-19 and how to secure against that virus. I don’t know. It’s a multi-billion dollar question which nobody can answer.

So while all these things are going, the one relentless constant we are still facing is: PCI-DSS deadlines. Despite the worldwide pandemic, we still get clients telling us they need to get their certificate renewed, their ASV scans done, their penetration testing sorted within x number of days. The reality of course is a bit more difficult. For example, once you have tested or scan, how does one remediate the issue when we cannot even get onsite to do proper testing? What about the development team, or the patching process, or the testing procedures and change management that needs to be done? The reality is simply, due to the pandemic, DELAYS will occur.

One of the main concerns are ASV scans, because ASV scans need to be done quarterly, there may be actual issues in remediation delays that may cause the company to miss the quarter.

How do we overcome this?

The main step is to always check with your QSA on this. I cannot repeat this ENOUGH. An organisation undergoing PCI-DSS, no matter what your size, especially if you are undergoing QSA certified program (Level 1 or Level 2 SAQ signoff from QSA) – ENGAGE your QSA to assist you. The QSA isn’t just supposed to come in at the end of your certification cycle, start poking holes into all your problems and tell you – you can’t pass because you missed our your internal VA back in Quarter 1. Or state your segmentation testing is insufficient at the end of your certification cycle. Or tell you that your hardening procedures are inadequate, with 1 month left to your certification cycle. The QSA needs to be in engagement at all times – or at the very least on a quarterly basis. Get them to do a healthcheck for you – all QSAs worth their salt should be able to do this. The mistake here is to treat your QSA as just an auditor and not onboard them throughout your certification cycle. An example is in the supplementary document from the council “Penetration-Testing-Guidance-v1_1” shows the possible involvement of the QSA:

In order to effectively validate the segmentation methodologies, it is expected that the penetration tester has worked with the organization (or the organization’s QSA) to clearly understand all methodologies in use in order to provide complete coverage when testing.

Pg 10 PCI Data Security Standard (PCI DSS) v1.1

It’s essentially critical to understand the relationship the QSA must have and the involvement they have, especially in the scoping part of PCI-DSS. The problem we often see is there is a disconnect between the company and their QSAs in terms of scope, or expectation, or evidences, which generally leads to A. LOT. OF. PAIN.

For ASV scans, a QSA may also provide ASV services provided these are properly controlled that there is proper segregation of duties and independence within the QSA/ASV company itself.

However, we have also done many companies whereby we provide the ASV scan and another QSA does the audit. Or the other way where we provide the QSA audit, and ASV is done by another company.

There is one example whereby we were auditing a company, and the ASV scans were done by another firm. We have been engaged from the start on a quarter basis and we highlighted to them that their Q1 ASV scan isn’t clean. We got on a call with the ASV company and worked together to ensure that the next quarter, these non compliant items would be remediated. So even with Q1 ASV not passed, at the end as QSA we still accepted the PCI recertification. PCI Council addressed this in FAQ 1152 – “Can an entity be PCI DSS compliant if they have performed quarterly scans, but do not have four “passing” scans?”

Without early engagement of the QSA and ASV, there would be a lot of problems once the recert audit comes around. In this case we could set the proper expectation early in the cycle for the customer to address.

Another possible instance is whereby the ASV themselves can pass a quarter scan with non compliant findings with compensating controls. This procedure is detailed out in section 7.8 of the ASV program guide, whereby within the quarter scan itself, before the expiry of that quarter, compensating controls are provided and validated and the ASV is able to issue an acceptable report for that quarter. This is important, because QSAs like to see 4 quarterly clean reports, and they throw a tantrum if they don”t get what they want. So in short, for ASV scans, do the following in this order:

a) Remediate all and get a clean report for the quarter; or

b) If you have non compliant for the quarter, engage your ASV, provide acceptable compensating controls, and attempt (not influence) with the ASV to accept/validate these controls and provide a clean report for the quarter but documented under Appendix B of the scan report summary; or

c) If for whatever reason, a clean report cannot be provided for the quarter, work closely with the ASV and the QSA to ensure that at least the next quarter or quarter after next remediation is correctly done. This is tricky because once the quarter report is out, it’s out of the ASV’s hands and into the QSA – on whether they can accept these reports or not. You can hang on to FAQ 1152 – but remember, FAQs are NOT the standard, so you are essentially in the hands of the QSA.

Those are your options for ASV, if there are any delays. DO NOT, in ANY CIRCUMSTANCE, MISS Your quarterly scan. Missing your scan is NOT THE SAME as getting a non compliant report. Missing your scan means there is no recourse but to delay your certification until you can get your 4 quarters in.

Finally before we sign off – let’s clarify here what a ‘quarter’ means. Some clients consider ‘quarterly’ scans to be their actual calendar year quarter. No. It’s not. Essentially a quarter is 3 months of a cycle of 12 months compliance year. A compliance year is not your calendar year (it could be, but it doesn’t have to be). So let’s divide this into two scenarios:

a) Where the ASV scans are required for the compliance year

In the case – the compliance year first needs to be defined, and this is usually done by identifying the signoff date of your AoC. For example if the QSA signed off your certification on April 1st, then that is where your quarter 1 begins. April – June; July – September; October – December; January – March. 4 quarters. You need to perform your ASV scan within the quarter, resolve the issues, and get the clean report out. This is CRITICAL to understand. Because many organisation fail this portion where they do not even perform any scans for the first few quarters and only pick up their PCI-DSS again mid way through and everyone is like: “Oops.” So while drinks and celebration are in the works once you signoff the AoC – your quarter 1 has also begun, so don’t drink too much yet.

So know your quarters. Start your scan early in the quarter, rescans must be done after remediation, and in case you need compensating controls, you need to get ALL THESE DONE within the quarter. If you perform your rescans in the next quarter, you are doomed. You MAY perform the rescan in this quarter and the clean report comes out next quarter for the current quarter – but all scans must be done within the quarter itself.

a) Where we have NO clue when the quarters are

As funny as this may sound (in a tragic way), there are many instances where we (wearing the ASV hat) gets plopped into situations where the client HAS NO CLUE when their compliance quarters are. I don’t know why this occurs. When I request them to check their AoC, or their QSAs for guidance, some can’t provide it. This is as great a mystery as the Sphinx itself. We call these internally, ‘Orphaned ASV scans’. These are projects where we are given the IPs and just told to shut up and scan the IPs. In this case because we onboard all ASV scans with quarters to define when we need to remind our customers, or escalate issues if the quarter runs out – we generally just use the date of the scan as a reference for quarters. So for instance, we provide a clean scan on April 31st. Since they are orphaned scans, without a compliance year/cycle for reference, we use the date of the scan report itself – meaning this scan expires 31st July.

By and large, we are seeing less and less of these orphaned ASV scans issues. Because QSAs these days are more engaged with customers and their customer service has also improved, it’s rare we find a client who isn’t aware of these cyclical requirements. Most clients, not just the large ones, are serviced by QSAs who themselves are reinventing themselves not just as auditors coming in once a year to observe and audit, but provide separate, independent units/consultants to assist healthchecks and support as well to enquiries pertaining to clients.

And a final note on this article – when we refer to ‘QSA’ or ‘ASV’ – we mean ControlCase International (QSA and ASV), whom PKF have been working with for close to a decade. We are not their representatives nor partners, but as our vendor, we’re keenly aware of how they do their certification and we try to manage our projects according to their expectations. As to why we do not want to become QSAs ourselves, we take independence and segregation of audit and operations seriously, as accounting and audit is our DNA. An article has been written at lenght on this:
http://www.pkfavantedge.com/it-audit/pci-dss-so-why-arent-we-qsa/

So – drop us a note at pcidss@pkfmalaysia.com for any queries on ASV scans, PCI-DSS or compliance in general. And no, we don’t know how to solve the resolve the Coronavirus yet, but I hope we get there soon. Stay safe and stay well!

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