IBM Security Services PCI Blog
Andi Baritchi 27000216AA firstname.lastname@example.org Tags:  service vendors sharing providers pci 1,370 Visits
PCI DSS Requirement 12.8 seems to be a source of confusion for lots of folks in the industry.
"What's a service provider?"
"What counts as sharing credit card data?"
This example, from a totally different industry, really helps illustrate the intent behind requirement 12.8. That intent being, make sure the people who help you store, transmit, or process cardholder data don't mess up. That includes people helping you manage your systems, host your systems, or monitor your IDS...
Andi Baritchi 27000216AA email@example.com Tags:  pci dss malware appliance anti-virus point-of-sale usb 759 Visits
If they see cardholder data - YES. Check out The TJX Effect and Keeping Point-of-Sale Equipment Secure for the rationale behind this.
Any merchant should protect their point-of-sale environment to the same level as the rest of their cardholder data environment. Maybe even a higher level since the POS's are more vulnerable to physical threats.
Cute commercial from the PCI Security Standards Council explaining the virtues and requirements of the DSS...
Hat tip to Martin.
Andi Baritchi 27000216AA firstname.lastname@example.org Tags:  virus trojan lawsuit pdf malware compliance heartland merrick qsa virtualization 2009 recession security computing pci savvis year cloud review new 1,845 Visits
Wow . Another one's gone by. 2009 felt like a flying lap around the Nürburgring. The ups. The downs. The slip angles. And ah yes, the opposite lock.
So... Let's take a look at look at the top events and trends that helped shape the year from a PCI perspective:
Best of luck to everybody in the new year and have a happy, successful 2010!
¡Felíz año nuevo! La mulţi ani!
David Mundhenk 2700022KT6 email@example.com Tags:  pci compliance hardening system wmq middleware 1,885 Visits
PCI Compliance Blind Spot: Middleware
One of the great things about industry standards is that there are usually more than one to salute at any given time. The true acid test for any security compliance standard is how applicable the standard remains given changes in technology, business and governmental requirements and ever evolving threats.
The PCI Data Security Standard is one that, despite grumbling by some detractors in the market space, is written well enough to do exactly that. When one thinks of PCI compliance as it relates to various IT architectures one usually thinks of traditional Point of Sale systems, e-commerce web implementations, and payment processing gateways. To date most of these architectures have involved classical client-server types of infrastructure, and in some instances even with some integrated components that are mainframe based.
A not-so-new, albeit rapidly evolving web-facing IT architecture implemented over recent years is currently testing just how well written the PCI DSS is. It is known as a Service Bus Architecture (SBA) and also sometimes referred to as a Service Oriented Architecture (SOA). It is from these types of implementations that highly sophisticated, large-scale web portals are often comprised. Essentially well-designed, and they often employ non-trivial web application front ends which provide large scale, highly available access to multiple and duplicitous web service offerings and highly diverse database storage capabilities. Due to their scalability and stringent service level fulfillment capabilities they often comprise the core of industrial scale e-commerce, banking and finance web applications and services.
Certainly one can view this type of architecture as essentially being built from a myriad of various client server based modular components. Often they require the addition of additional auxiliary software systems to help ‘sew together’ the components into a cohesive, highly dynamic web and data services framework. These components are often referred to as ‘middleware’. A very specific type of middleware that helps to translate complex messaging across this type of architecture is called, quite simply, message-oriented middleware or "MOM".
From Wikipedia we derive the following definition of MOM:
“Message-oriented middleware (MOM) is infrastructure focused on sending and receiving messages that increases the interoperability, portability, and flexibility of an application by allowing the application to be distributed over heterogeneous platforms. It reduces the complexity of developing applications that span multiple operating systems and network protocols by insulating the application developer from the details of the various operating system and network interfaces.”
Traditionally PCI DSS compliance assessments of web-facing applications have focused on assessing the security of the overall web-facing server and applications components, DMZ-based logical separation components such as firewalls and routers, relevant database storage elements deployed in the interior network, and the communications services between them all. Assessing the PCI data flows associated with such traditional client-server based web application infrastructures is a fairly straightforward endeavor.
Assessing the PCI compliance of highly sophisticated SOA or SBA implementations, however, is a bit more challenging. This is due to the multiple cardholder data flow combinations possible throughout the various SOA application interfaces, numerous database components and possible interconnections with customers, and also between various business partners. This is not a bad thing – it’s exactly why SOA/SBA architectures have been conceived of, and implemented wide scale in the first place. If well designed and correctly implemented, they are remarkably suited and scaled to accommodate industrial scale web application based business services provision.
In large part, a good percentage of communications between such non-trivial architecture components is facilitated by middleware messaging software and systems. And as one might suspect is the case when dealing with the storage, processing, and transmission of cardholder data, it is often precisely the scheme used to help transmit various aspects of the payment card transaction authorization and settlement processes. These can include actual transaction requests and responses, back-end settlement capabilities, and various types of reporting.
When considering middleware systems compliance with the PCI DSS, the very same requirements that are applied to client-server or mainframe systems applies. At a very high level they can be summarized as follows:
1) Develop and maintain system build standards that reflect industry recommendations for securing such systems. These are often referred to as “hardened” build standards.
There are obviously more subtle aspects to the PCI DSS that also apply, however, the fact remains that middleware is by no means allowed any differing or diminished security considerations than any other systems handling cardholder information.
As with many operating systems, web software, payment applications, network components, etc., it is often the case that default installations of associated software are not auto-magically configured to be compliant with PCI DSS or any other security standard. It is incumbent upon those architecting and implementing such systems to sufficiently harden their configurations such that standards compliance, and indeed optimal critical data protection is achieved. A good example of this is with respect to message-oriented middleware software is IBM’s WebSphere MQ (WMQ). A default installation of the product right out of the box will most assuredly not be PCI DSS compliant.
The good news is that IBM has its own core WMQ subject matter expertise, and indeed an evangelizing subject matter expert on the proper assessment and securing of WMQ implementations. His name is T.Rob Wyatt.
T.Rob has many years of experience with WMQ and has provided guidance to quite literally hundreds of IBM customers, as well as the IBM ISS Global PCI Practice in assessing and supporting PCI compliant WMQ implementations.
T.Rob’s diligence, passion for “getting the message out” and un-yielding efforts to accurately convey WMQ best practices and techniques are commendable. He is a tremendous asset and is ready, willing and able to help. His thinking and efforts are entirely consistent with the philosophy of the Information Security industry whereby “security through obscurity” never works out. Even if attempted, more damage will probably occur over the long run than not. He also believes that the best defense is a good offense when it comes to securely configuring WMQ and other systems. As was said in Ghostbusters the movie, “…we have the tools and we have the technology.” Now let's go forth and make it a better, no check that, “let’s make it a smarter WMQ world”.
You can find more about T.Rob and his efforts at the following website and twitter:
In the next blog installments, we will review T.Rob's WebSphere WMQ best practices recommendations, and how not addressing them can adversely affect your overall PCI compliance if using WMQ in PCI environments.
Andi Baritchi 27000216AA firstname.lastname@example.org Tags:  security website ibm compliance solutions pci iss 1,270 Visits
Andi Baritchi 27000216AA email@example.com Tags:  pci security business compliance roi 1,033 Visits
IBM whitepaper hot off the presses: The Return on Investment of PCI DSS Compliance (PDF).
David Mundhenk 2700022KT6 firstname.lastname@example.org Tags:  pci nrf qsa compliance dss retail 1,932 Visits
It has been no secret that retail merchants and their industry representation have been extremely unhappy with having to comply with Payment Card Industry Data Security Standard (PCI DSS) requirements. Their industry representative presentations at the recent Congressional hearings on the effectiveness of PCI DSS showed that their spokespeople could barely contain their vitriol during testimony. In addition, the National Retail Federation has also recently published an ‘open letter’ to the PCI Security Standards Council regarding their collective discomfort over PCI requirements. A copy of this letter can be found at their own website via the following link:
This blog entry is not intended to make light of the concerns of the retail industry regarding PCI DSS, nor to dismiss their assertion that having to comply with the requirements isn’t pain or duty free. The challenges of complying with PCI DSS are measurable, and for some businesses difficult to address. This is especially true for small-to-medium sized businesses which may lack the expertise, bandwidth or resources to formulate an effective response to meet the requirements. The NRF collective attempts to make overall industry improvements for the better should be applauded, however, after reviewing the highlights of their recommendations it appears that they may have been drafted in haste.
What they have proposed is interesting and deserves some analysis and an objective response. The following is a representative sampling of NRF recommended improvements with respect to the current PCI compliance requirements, and also an interpretive viewpoint on the items noted:
National Retail Federation (NRF): Incorporate a formal review and comment phase on revisions to the PCI DSS by participating membership before they are issued.
Objective Response (OR): This is already taking place. The PCI SSC solicits feedback from certified QSAC’s and their respective QSA’s prior to finalizing version changes. In addition they sponsor “town hall” meetings where merchants and service providers who attend can ask questions, make recommendations, and vent their frustrations.
NRF: Ensure the amount of time from issuance of a revision to the
PCI DSS and the effective date is appropriate for all merchants, including
Level-1 merchants making enterprise-wide changes, based on the revisions that
are being implemented,
OR: This is purely subjective, no matter how much time is allotted there will be a contingent of merchants and others who feel like they need more time. The PCI SSC has to draw a line in the sand somewhere. In addition the PCI SSC has recently provided additional assistance for level 2, 3, and 4 merchants with their new, improved Self Assessment Questionnaires and their recommendations for a “prioritized” approach to achieving compliance.
NRF: Follow, and adopt, the ASC X9 announcement of its plan to develop a new standard to protect cardholder data that may include end to end data encryption.
OR: This is very interesting, and apparently their lone
recommendation toward relieving all the perceived pain and suffering associated
with having to comply with the PCI standard. They actually seriously propose
adopting yet another compliance standard? Especially one that is not even
mature yet? Yessir, and
They also propose adopting the supposed “holy grail” of cardholder data protection which is sometimes called “end-to-end” encryption. Sounds like a great idea in principle, but implementing end-to-end encryption will be a serious challenge for all parties currently involved in payment processing and settlement across the globe. It may actually be a viable prospect for the future and possibly successful over the long term. Initially, however, it will be incredibly expensive to deploy, administer, and maintain on a global scale. One also wonders what it will be like for everyone involved to re-initialize and then maintain all those crypto keys in a secure, PCI compliant fashion.
NRF: Utilize the concepts of key controls and controls rationalization to restructure the more than two hundred detailed requirements of the PCI DSS.
OR: This one too is fairly entertaining since the PCI DSS is already
constructed to accommodate what is known
SOX and SAS70 requirements permit unencumbered business operations to continue even if total compliance with their requirements has not been achieved. Also in some instances the auditor and the entity audited sit down prior to the exercise and “agree” upon the audit criteria to be measured against. "What? You don't want to rotate your encryption keys because you 'feel' like it is too much work? OK then! You don’t have to do it." This approach is not going work for PCI, which is one of the few required security frameworks that actually incorporates some level of enforcement for those who refuse to comply.
NRF: Require credit card companies and their banks to provide merchants with the option of keeping nothing more than the authorization code provided at the time of sale and a truncated receipt, rather than requiring merchants to store credit card information for dispute resolution, putting customers at unnecessary risk.
OR: Where PCI compliance is concerned this is a non-issue. Nothing within the PCI DSS nor the PCI PA-DSS requires the merchant to retain anything post authorization. Even section 3.1 & 3.2 of the PCI DSS clearly states the following:
3.1 Keep cardholder data storage to a minimum. Develop a
data retention and disposal policy. Limit storage amount and retention time to
that which is required for business, legal, and/or regulatory purposes,
3.2 Do not store sensitive authentication data after authorization (even if encrypted).
The PCI DSS doesn’t require having the merchants store any CHI post authorization. Some “issuer-processors” may actually be doing so on behalf of their customers (i.e. – banks, financial institutions, credit unions, etc.) who already own the data they are asking to be collected. In addition any sensitive authentication data being captured by them is usually collected during the pre-authorization process. Since the banking industry already "owns" this data, why shouldn't they be allowed to collect it? The additional audit compliance requirements imposed by the card brands on their issuer-processors accommodate a trusted relationship that allows for this to take place only under extremely special circumstances.
If a merchant does not want to collect CHI information for any reason what-so-ever post authorization they currently can choose not to do so. In reality it is usually the case that merchants have been collecting this type of information for years for their own business intelligence and data mining purposes. They are often unwilling to commit the resources required to re-tool their IT applications and infrastructure to support not storing CHI.
It has been reported in some Internet postings that the PCI DSS offers "minimum general recommendations for security" for systems storing or processing CHI. This is a myth. The PCI DSS is indeed a standard and a framework, not detailed process or procedural recommendations on how to secure PCI systems. This is somewhat akin to the OSI model defining the seven protocol and architecture layers for computing systems and networks, but not detailing “how” they should be configured down the system level. The corresponding PCI DSS Requirements and Security Assessment procedures, however, are exacting in spelling out how to measure PCI DSS compliance within a given environment.
The effects of changing or re-engineering an operational business enterprise to become PCI compliant are usually measurable and often significant. Sometimes dealing with any change to normal business operations especially in tough economic times is very uncomfortable, however, managing change and potential risk to business assets is a simply a major component of doing business safely and securely. Reducing or eliminating the emotional aspects of having to do so helps provide focus and reduces anxieties associated with doing so. It also helps to aid in complex decision making. The PCI DSS and related compliance processes are not perfect, but their adoption has resulted in a significant industry improvement over doing nothing, or adding additional security standards to the mix.
Andi Baritchi 27000216AA email@example.com Tags:  cardholder risk compliance security lawsuit breach pci 1,868 Visits
Co-written by Andi Baritchi and David Mundhenk
The recent news that Merrick Bank is suing Savvis for negligence regarding the CardSystems compromise back in 2004 is creating quite a buzz on security blogs and other sites across the web. Merrick Bank is alleging that Savvis was negligent when conducting a CISP audit (a contributing predecessor to PCI DSS assessment) for CardSystems, that this negligence led to a serious breach of credit card information, and ultimately to related large scale liabilities and costs that Merrick Bank incurred. They are seeking compensation for these costs, to the tune of $16 million.
This news is polarizing the security blogosphere. The popular “buzz” over the announcement is that this is supposedly a wake-up call for the industry, especially if Merrick ultimately proves that Savvis was indeed negligent. The mounting anxiety over this is creating a scenario whereby all those who have complained about the pitfalls and complexities and costs of compliance, in a figurative sense, are now lining up with a big stick in hand ready to flail away at the PCI compliance piñata. They are ready to vent their collective pent-up frustrations by disparaging and dismissing the PCI compliance process, and especially the QSAs who perform these assessments. (Note they are now called assessments by the PCI SSC, not audits). They do so hoping the figurative “spoils” that might spill from the busted PCI piñata will include relaxed compliance requirements and reduced fines and penalties for non-compliance.
The PCI SSC has gone to great lengths to write a unified security standard to help protect the cardholder information (CHI) for the founding member card brand customers. It has developed a fairly rigorous training and certification program for those who perform PCI DSS compliance assessments. Only certified companies with certified Qualified Security Assessor (QSA) personnel can perform such work. In addition, there are Quality Assurance steps in place to help identify and restrict those QSAs that do not, or cannot perform to minimum levels of professional competency. There are also stipulations that companies who perform this work must not only recommend their own products for solutions. That having been said, no standard is perfect, nor are companies or people. There can be instances where mistakes are made. It is also quite possible that there are some bad apples involved in this business who have somehow circumvented the checks and balances designed to establish and maintain a minimum level of professional competency. But this is why the Council has its QA process.
The PCI DSS at a rudimentary level can be compared to Information Security 101, but it goes much deeper than that. Much like the more mature audit frameworks in the financial sector, the goal of PCI is to protect sensitive private information – and in doing so install a level of transparency into enterprise information security, reduce fraud, reduce risk, and increase confidence. PCI isn’t perfect, and its biggest weakness is its reliance on the integrity of the business being assessed. It is, however, the strongest driver for information security in the business world we’ve seen to date. Thus far PCI and its predecessors have identified and helped mitigate a staggering amount of risk to CHI due to insecure systems and business processes.
While there has been an impressive improvement in the overall protections afforded by all of these Infosec standards both individually in a collectively, there is still no guarantee that systems assessed for compliance are completely secured against compromise or misuse. There are no guarantees with this, just as there are no guarantees in business. A significant component of managing businesses and organizations involves managing all risk to corporate assets. And even if all reasonable and cost effective protections are in place, stuff can still happen. In addition it is important to understand that all IT environments, including those that process credit card payments are highly dynamic environments. An audit or an assessment of such an environment takes place over a finite time period. It represents a “snapshot” in time at the time of the assessment. The assessor attests to the overall compliance of a given environment during that time period, and then provides a reference date for making that assertion. If a compliant business or organization induces any change to that environment after the fact, there are no guarantees that the environment is still compliant.
What does this all mean when it comes to the Merrick Bank lawsuit against Savvis? Merrick has a large burden of proof ahead. They have to prove that (a) Savvis was negligent and that the alleged noncompliance was there at the time of the CISP audit, meaning their Report On Compliance (ROC) was false, (b) the breach would not have occurred had they been compliant, and (c) this is their biggest hurdle: they have to prove that Savvis is somehow liable for Merrick’s damages even though Savvis had no business relationship with Merrick Bank (Savvis was hired by CardSystems, not Merrick). Whichever way the lawsuit goes (with today’s legal system I’d rather go to Vegas than call that one), the real lesson here is to be damn sure all requirements are met before professionally attesting to security related organizational compliance.
There is one key to
understanding PCI compliance (or any compliance program for that
matter) – there is no ‘silver bullet’ solution. There are vendors that
will try to sell you solutions that will guarantee 100% hackproof
security with full compliance, however the truth is that such a thing
doesn’t exist. It’s a panacea to think otherwise. Security is all
about risk management, and the bad guys tend to be pretty skilled and
resourceful. Not only that, they only have to be “right” just one time.
As a merchant or service provider pursuing PCI compliance, the goal
shouldn’t be to achieve it and then put a “safe from hackers!” sticker
on your website. Doing so or anything like it will only increases
possible risk. The end goal is to determine your business’ risk tolerance, and bring your risk tolerance profile to acceptable levels.
Similar decisions are made when determining “should I become compliant
with PCI or just pay the costs of noncompliance?” Same risk management
model as the one you use every day deciding whether to speed on the
freeway, except PCI compliance actually makes sense.
Look for our new IBM ISS white paper on the ROI from PCI Compliance, coming to this blog soon.