Posts Tagged ‘PCI DSS



15
Nov
14

Security Or Checking A Box?

“Better to remain silent and be thought a fool than to speak out and remove all doubt.” Abraham Lincoln

What is your organization interested in?  Security or checking a box?

Not surprisingly, most people answer “security” and then go on to prove with their actions and words that they are only interested in checking a box.

For all of you out there that argue ad nausea about the meaning of PCI DSS testing requirements and the requisite documentation are interested in one thing and one thing only; checking a box.  I am not talking about the few that have honest differences of opinion on a few of the requirements and how a QSA is interpreting them and assessing them.  I am talking about those of you that fight constantly with your QSA or acquiring bank on the process as a whole.

If you were to step back and listen to your arguments, you would hear someone that is splitting hairs in a vain attempt to avoid having to do something that would improve your organization’s security posture.  In essence, you want to only be judged PCI compliant, not actually be secure.

To add insult to injury, these are also typically the people that argue the most vehemently over the fact that the PCI DSS is worthless because it does not make an organization secure.  Wow!  Want to have your cake and eat it too!  Sorry, but you cannot have it both ways.

Everyone, including the Council, has been very clear that the PCI DSS is a bare minimum for security, not the “be all to end all” for securing an organization.  Organizations must go beyond the PCI DSS to actually be secure.  This where these people and their organizations get stumped because they cannot think beyond the standard.  Without a detailed road map, they are totally and utterly lost.  And heaven forbid they should pay a consultant for help.

But I am encountering a more insidious side to all of this.  As you listen to the arguments, a lot of you arguing about PCI compliance appear to have no interest in breaking a sweat and doing the actual work that is required.  More and more I find only partially implemented security tools, only partially implemented monitoring and only partially implemented controls.  And when you dig into it as we must do with the PCI assessment process, it becomes painfully obvious that when it got hard is when the progress stopped.

“It’s supposed to be hard. If it wasn’t hard, everyone would do it.” Jimmy Duggan – A League Of Their Own

Security guru Bruce Schneier was speaking at a local ISSA meeting recently and when asked about why security is not being addressed better he stated that one of the big reasons is that it is hard and complex at times to secure our technology.  And he is right, security is hard.  It is hard because of our poor planning, lack of inclusion, pick the reason and I am sure there is some truth to it.  But he went on to say that it is not going to get any easier any time soon.  Yes, we will get better tools, but the nature of what we have built and implemented will still make security hard.  We need to admit it will be hard and not sugar coat that fact to management.

Management also needs to clearly understand as well that security is not perfect.  The analogy I like to use is banks.  I point out to people the security around banks.  They have one or more vaults with time locks.  They have video cameras.  They have dye packs in teller drawers.  Yet, banks still get robbed.  But, the banks only stock their teller drawers with a minimal amount of money so the robber can only get a few thousand dollars in one robbery.  Therefore to be successful, a robber has to rob many banks to make a living which increases the likelihood they will get caught.  We need to do the same thing with information security and recognize that breaches will still occur, but because we have controls in place that minimizes the amount or type of information they can obtain.

“There’s a sucker born every minute.” David Hannum

Finally, there is the neglected human element.  It is most often neglected because security people are not people, people.  A lot of people went into information security so that they did not have to interact a lot with people – they wanted to play with the cool tools.  Read the Verizon, Trustwave, etc. breach analysis reports and time and again, the root cause of a breach comes down to human error, not a flaw in one of our cool tools.  Yet what do we do about human error?  Little to nothing.  The reason being that supposedly security awareness training does not work.  Security awareness training does not work because we try to achieve success only doing it once per year not continuously.

To prove a point, I often ask people how long it took them to get their spouse, partner or friend to change a bad habit of say putting the toilet seat down or not using a particular word or phrase.  Never in my life have I ever gotten a response of “immediately”, “days” or “months”, it has always been measured in “years”.  And you always get comments about the arguments over the constant harping about changing the habit.  So why would any rational person think that a single annual security awareness event is going to be successful in changing any human habits?  It is the continuous discussion of security awareness that results in changes in people’s habits.

Not that you have to harp or drone on the topic, but you must keep it in the forefront of people’s mind.  The discussion must be relevant and explain why a particular issue is occurring, what the threat is trying to accomplish and then what the individual needs to do to avoid becoming a victim.  If your organization operates retail outlets, explaining a banking scam to your clerks is pointless.  However, explaining that there is now a flood of fraudulent coupons being generated and how to recognize phony coupons is a skill that all retail clerks need to know.

  • Why are fraudulent coupons flooding the marketplace? Because people need to reduce expenses and they are using creative ways to accomplish that including fraudulent ways.
  • What do the fraudulent coupons do to our company? People using fraudulent coupons are stealing from our company.  When we submit fraudulent coupons to our suppliers for reimbursement, they reject them and we are forced to absorb that as a loss.
  • What can you do to minimize our losses? Here are the ways to identify a fraudulent coupon.  [Describe the characteristics of a fraudulent coupon]  When in doubt, call the store manager for assistance.

Every organization I know has more than enough issues that make writing these sorts of messages easy to come up with a topic at least once a week.  Information security personnel need to work with their organization’s Loss Prevention personnel to identify those issues and then write them up so that all employees can act to prevent becoming victims.

Those of you closet box checkers need to give it up.  You are doing your organizations a huge disservice because you are not advancing information security; you are advancing a check in a box.

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01
Nov
14

The ASV Process Is Broken – Part 2

The next reason I believe the process is broken is with the automated scanning processes.  They do not seem to be accurately assessing the security of Web servers, firewalls, routers and other externally facing devices that form an organization’s perimeter.  In my opinion, it seems that in our drive to bring down the cost, we have created a false sense of security by having the concept of a “passing” scan and only requiring scanning on a quarterly basis.

It is hard to believe that external vulnerability scanning came into vogue more than a decade ago.  There were no automated solutions.  No popping out to a Web site, entering IP addresses and scheduling a scan.  It was all manual.  A person was required to configure the scanning solution and then launch the scanner.

There was a proven methodology used for approaching vulnerability scanning.  That methodology involved approaching the organization as an attacker would. .  The security professional would go out to domain registrars and other official sources to obtain potential IP address ranges, registered domains and other public information.  Then the professional would develop a profile of the organization’s external security posture using Nmap and similar tools as well as running non-intrusive scans to identify systems and potential entry points.  But even more insidious, the security professional would do what became to be known as “Google Hacking” to find out what, if any, information was available on the Internet that might facilitate the attack.  Log data, firewall configurations and even authentication credentials could be obtained through Google Hacking.  Even today, while Google does its best to minimize the information they collect, it is amazing the amount of information that can still be obtained with specially crafted Google searches.

Once the preliminaries were done, it was time to actually scan.  The most accepted approach used at that time was to run two scans, one fully external with security measures enabled and one with testing done inside the DMZ.  The scan done with the security measures enabled was to confirm that an organization’s firewalls, load balancers or other front ends were functioning as configured.  Essentially this scan showed what an attacker would discover in their scanning of the organization’s external presence.  There were two purposes of the second scan.  The first was to provide an inventory of vulnerabilities that were being obfuscated by the security measures so that they could be addressed or mitigated.

The second purpose of the DMZ scan was for what some would call today a form of “threat intelligence”.  The second scan provided a view of what an attacker would encounter if they were able to circumvent the organization’s external security.  It answered the question of how large the attack surface was in the DMZ should it be compromised?  What else could be subverted and used to further an attacker’s goal of getting even deeper into a network?  The point of this part of the exercise was to provide the organization with an idea of what to look for should anomalies begin to appear in log data.

Throughout this scanning process, separate scans were run for firewalls, routers, load balancers, Windows devices, Linux devices, etc.  The rationale for that was to obtain clear results based on the type of device.  No reason to toss a bunch of Windows vulnerabilities against a Cisco firewall or F5 load balancer and then have to sift through the results to remove the false positive entries generated by the Windows devices they protect.

All of this information would be collated, analyzed and an actionable report produced for management and security professionals to absorb and understand the organization’s true external security posture.  Once the draft report was delivered there would be one or more calls or meetings with the organization’s security personnel to tweak the message of the results, develop action plans to address the results and then a final meeting with management and security personnel to deliver the final report.  At the end of this process, management and security personnel knew exactly where they stood from a security perspective and what needed to be done to ensure that they remained secure going forward.

Obviously, such an approach is fairly comprehensive and that costs money to produce.  And it was the cost that drove the automation of the process so that it was less labor intensive.

In the mad dash to the lowest possible cost, the following is what typically happens today.

Organizations subscribe to an ASV vulnerability scanning service.  If the organization is lucky, they go through a scoping call with a human being at the ASV service to confirm the IP addresses that are in-scope for PCI compliance.  Having been on a number of these calls with ASVs, it is more of a questionnaire approach and there is very little done by the ASV to actually confirm the scope of the scanning.  It is more or less a conversation that explains how to enter the IP addresses into the scanning tool’s Web interface and to schedule a scan, not a diligent conversation on whether or not a device is in scope or not.  There is typically a brief discussion on how to use the Web site to dispute scanning results that caused a non-passing scan.  In total, the call takes 20 to 30 minutes at which point customers are essentially on their own.

Scans are run on a quarterly time period.  Scans may be rerun if vulnerabilities are identified that result in a non-passing scan.  Once a passing scan is obtained, a passing certificate is generated and the organization moves on to the next quarter.  Every now and then a result may be disputed, but those situations are typically rare.  The bottom line is that the ASV process is fairly automated with very little, if any, human intervention.

From a tool perspective, the vulnerability scanner is tossing every vulnerability at every IP address they are given.  Firewalls, load balancers, switches and routers are tested for Windows and Linux vulnerabilities.  False positive results can be rampant but most scanners weed out the obvious false positive results based on OS and device signatures.  But even if a few false positives remain, as long as they have a CVSS score of less than 4.0, no one cares.  And the scanner is configured to run as quickly as possible because it needs to be available for the next customer so that the ASV does not have to have an individual scanner for every customer.

All of this is driven by customers’ desire to minimize cost as much as possible.  Thus, in order to stay in business, the ASV scanning service providers have done an admirable job of driving down cost.  But at what other costs?

While I think we can all agree that the current approach is flawed, the Council would point to the fact that the quarterly ASV scanning requirement is only a minimum and that organizations should be doing their own external vulnerability scanning more often than quarterly.  And that is what is missed by a lot of organizations is that they need to do more than what the PCI DSS requires to be secure.  And no matter how loud that message is repeated, it seems to get missed over and over again.

However, a lot of organizations do not do anything more than the PCI DSS requires.  We have this “bare minimum” mentality because, if it is not mandated in the standard, then we must be secure if we do only what is required.  This results in the false sense of security that organizations have when they only do what the PCI DSS or any other security framework for that matter mandates.

In addition, I cannot tell you how many organizations totally write off vulnerabilities that have a CVSS of less than 4.0 as “trivial” representing no threat.  There is this mistaken belief that, because the CVSS score does not warrant immediate patching, it is not a threat.  However, when you have them in relative abundance and of certain types, those “trivial” vulnerabilities can be put together in a particular sequence and used to compromise a network.  To the shock and horror of a lot of organizations, their security is breached in moments during their penetration test using those “trivial” vulnerabilities.

Then we have the limitations of the tools themselves.  Their vulnerabilities are constructed for the general audience, not a specific network.  As a result, depending on security measures and configurations, a particular vulnerability for say HTTP or FTP might not register due to a load balancer or other devices in the communication path.  Yet with a minor tweak, the same vulnerability could actually work.  And that was another point of doing that second scan inside the DMZ back in the “old” days.  Taking the two scans allowed you to correlate that while HTTP or FTP was open; it was vulnerable because that vulnerability was shown on the internal DMZ scan.  As a result, you could take additional steps to ensure that the vulnerability could not be exploited from the Internet.

The bottom line in all of this is that ASV scans have become a pointless piece of the compliance assessment process.  It has not been because the ASVs are bad, it is that the process they are forced to follow is not doing what it once did at the beginning.  It does not help that merchants and service providers treat ASV scans as a “check the box” activity and that because they do something quarterly they are secure.

If the process is broken, what should be done to fix it?  That is the subject of my next post.

12
Oct
14

Lawyer Or Security Professional?

“It depends upon what the meaning of the word ‘is’ is. If ‘is’ means ‘is and never has been’ that’s one thing – if it means ‘there is none’, that was a completely true statement.” –President of The United States of America, William Clinton

It has been an interesting time as the December 31, 2014 deadline approaches and version 2 of the PCI DSS comes to its end of life.  I have started to notice that there are a lot of security professionals and others that are closet lawyers based on the discussions I have had with some of you regarding compliance with the PCI DSS.

The first thing I want to remind people of is that if you do not want to comply with one or more of the PCI DSS requirements, all you have to do is write a position paper defining for each requirement you find onerous, why it is not relevant or not applicable for your environment and get your management and acquiring bank to sign off on that paper.  But stop wasting your QSA’s or ISA’s time with your arguments.  It is not that we do not care, but without such approval from your management and acquiring bank, QSAs and ISAs cannot let you off the hook for any requirement.

With that said, the first lawyerly argument we are dealing with these days revolves around the December deadline.  We continue to get into arguments over what the deadline actually means.

It appears that the PCI SSC and card brands’ repeatedly saying that version 2 is done as of December 31, 2014 was not clear enough for some of you.  And further clarifications from them that any reports submitted after that date must be under version 3 are also apparently too much for some of you to handle.  I do not know how there could be any misinterpretation of ‘DEADLINE’, ‘DONE’ or “AFTER THAT DATE’ but apparently, there are a lot of people out in the world that do not understand such words and phrases.  Then there are the amazing contortions that some people will go to in a twisted dance to the death to get around this deadline.

Where have you been?  How could you have missed this deadline?  It has been known since the PCI SSC announced their change when standard updates would be issued back with the release of the PCI DSS v2 more than three years ago.  But even assuming you were not involved back then, the PCI SSC announced the deadline over a year ago with the release of PCI DSS v3.  Either way, it certainly should not have been a surprise as there has been plenty of warning.

But then do not take this out on your QSA.  QSAs are just the messenger in this process and had nothing to do with setting the deadline.  The PCI SSC and the card brands set that deadline.  You have a problem with the deadline, complain to them.  But if you are willing to listen, I can save you that discussion.  They will politely tell you the deadline is the deadline.  You are out of luck.  If you do not like that answer, then stop taking credit/debit cards for payment for your organization’s goods and services.

The next lawyerly argument is around the June 30, 2015 deadlines for requirements 6.5.10, 8.5.1, 9.9, 11.3 and 12.9.  Again, it is as though these dates were kept from you, which they were not.  I even wrote a post about these requirements titled ‘Coming Attractions’ back in September 2013.

For those that are calendar challenged, June 30, 2015 is practically just around the corner in business terms.  If you had years to get ready for the PCI DSS v3, what makes you think that you can just turn something on in a year and a half?  Yet we continually see people arguing that until that date, they are not going to address any of these requirements.  All as though, like a light switch, something magical will occur on July 1, 2015 that will meet those requirements.

For merchants, requirements 9.9 and 11.3 are going to be huge issues particularly for those of you with large networks and lots of retail outlets.  If you have not gotten started on these requirements now, there is no way you will be compliant with these requirements by July 1.  Both of these require thought, planning and training.  They cannot just be started overnight resulting in compliance.

For requirement 11.3, the new approach required for penetration testing is resulting in vulnerabilities being uncovered.  Organizations that did not want to get caught flat footed are finding that their network segmentation is not as segmented as they once believed.  They are also finding new “old” vulnerabilities because of these network segmentation issues.  The bottom line is that these early adopters are scrambling to address their penetration testing issues.  In some cases ACLs need to be adjusted, but I have a few that have found they need to re-architect their networks in order to get back to compliance.  Obviously the latter is not an overnight kind of fix.

Requirement 9.9 is all about ensuring the security of points of interaction (POI) as card terminals are referred.  Because of all of the POI tampering and hacks that have occurred, the Council has added the requirements in 9.9 to minimize that threat.  The biggest problems early adopters are running into is getting their retail management and cashiers trained so that they understand the threats and know how to deal with those threats.  This requires creating new procedures for daily or more often inventorying of the POIs and visually inspecting them to ensure they have not been tampered with.  Companies are rolling out serialized security tape that must be applied to the seams of POIs so that any opening of the case can be visually determined.  Locking cradles are being installed for every POI to secure them to the counter.  Let alone implementing those new procedures for doing at least daily inspections and what to do if you suspect tampering and how to inform corporate of potential issues.  Again, not something that just happens and works day one.

For service providers, besides 11.3, requirement 8.5.1 is going to be their biggest issue.  This requires the service provider to use different remote access credentials for every customer.  This is in response to the breaches that occurred at a number of restaurants in Louisiana a few years ago as well as more recent breaches.

The problem that early adopters of 8.5.1 are finding is that implementing enterprise-wide credential vaults is not as simple as it appears.  The biggest impact with these implementations is that service providers start missing their service level agreements (SLA).  Missing SLAs typically costs money.  So these service providers are not only incurring the costs related to implementing the credential vault solution, but they are suffering SLA issues that just pile on the injuries.

But the final straw is all of the people that closely parse the PCI DSS and only the DSS.  You saw this with some of the questions asked at the latest Community Meeting.  You also see it in the questions I get on this blog and the prospects and I clients I deal with daily.  These people are hunting for a way to get around complying with a particular requirement.

This occurs because people only read the DSS and not the Glossary, information supplements and other documents provided by the Council.  At least with v3 of the DSS the Council included the Guidance for each of the requirements.  Not that adding Guidance makes a whole lot of difference based on the arguments laid out by some people.  The Council could do us all a favor if they generally published the Reporting Template with all of the other documents.  Not so much that people would necessarily read it, but it would give QSAs and ISAs more ammunition to use when these discussions come up.

Successful security professionals understand the purpose of security frameworks.  These frameworks are meant to share the collective knowledge and lessons learned regarding security with everyone so that everyone can have a leg up and know ways of detecting and mitigating threats.  Successful security professionals use these frameworks to get things done, not waste their time developing scholarly legal arguments or twisting the English language as to why they do not need to meet some security requirement.  They put their heads down, review the frameworks, develop plans to implement the changes necessary to improve security, work the plan and deliver results.  Do those plans always meet requirement deadline dates?  Not always, but they are close or as close as they can get given other business issues.

The bottom line is that security professionals are not lawyers and good security professionals certainly do not sound like lawyers.  But if you constantly find yourself sounding like a lawyer digging so deep to split legal hairs, in my very humble opinion, you really need to re-examine your career or lack thereof.  I say lack thereof because, in my experience, security professionals that operate like lawyers do not have long careers.  They move around a lot because once people realize that they cannot deliver, they are forced to move on.  Eventually a reputation is developed and after that point these people end up forced to find a new career because the security community knows their modus operandi.

08
Oct
14

Do Not Jump To Conclusions

A QSA apparently posed a question to the Council regarding the scope of wireless headsets used in a client’s call centers.  In this case, the headsets rely on DECT technology.  The response from the Council was as follows:

“Although DECT is not specifically referenced in PCI DSS v3, it is a digital wireless telephone technology and given the scenario you are describing, PCI DSS requirement 4.1 and 4.1.1 would apply.”

The resulting LinkedIn discussion surrounded whether the DECT headsets are in-scope which, of course, they are in-scope.  However, the implication of the discussion was that, if in-scope, could the DECT headsets be considered as PCI compliant.  Let us walk through a discussion of this issue and develop a position on whether or not DECT headsets are a risk and can they be considered PCI compliant.

For those of us that do not have the PCI DSS memorized requirement 4.1 states:

“Use strong cryptography and security protocols (for example, SSL/TLS, IPSEC, SSH, etc.) to safeguard sensitive cardholder data during transmission over open, public networks, including the following:

– Only trusted keys and certificates are accepted.

– The protocol in use only supports secure versions or configurations.

– The encryption strength is appropriate for the encryption methodology in use.”

Requirement 4.1.1 states:

“Ensure wireless networks transmitting cardholder data or connected to the cardholder data environment, use industry best practices (for example, IEEE 802.11i) to implement strong encryption for authentication and transmission.”

For those of you not up on DECT, it does not rely on strong encryption as defined by NIST and other recognized sources.  The encryption used is 64-bit, almost as lame as DES.  But it gets worse; the protocol does not require the use of a secure authentication method to pair devices to their base station.  As a result, it is relatively easy to force authentication to a rogue base station.  To add to the threat, the theoretical transmission distance is 500m or around a third of a mile.  So it has the capability of transmitting fairly long distances.

Sounds like a PCI and general security train wreck does it not?

Now before we all go off and tell every one of our call center clients that DECT is no longer allowed, let us all take a big deep breath and look at this issue clearly.

The first question that should always be asked is what the real world likelihood of such an attack is.  In this case, would an attack on 20, 50, 100 or more DECT headsets make sense?  Probably not and here is why I believe that to be the case.

You would need as many rogue devices as actual headsets to surreptitiously pair with each individual headset in order to get the conversations.  This would require a large van with racks of notebooks in order to accomplish such an attack.  And that assumes that the transmission distance quoted in the standard can be relied upon.  However, based on the use of my own DECT phones at my home, I can tell you that my phones have issues 30’ away from my house, let alone a third of a mile away.

If that isn’t enough, the DECT cards required are no longer manufactured.  If you are lucky, you may be able to get them on eBay from Europe for about $25€ or $30USD.  I would take this as a good indication that DECT hacking was not a big thing.  But it does get worse; the cards use the PCMCIA interface (superseded in 2003) and, according to the limited number of eBay sellers, do not work reliably for hacking DECT when using the requisite adapter cables for connecting them to modern computers via USB.  As a result, the hack will also require a large number of old notebooks to execute.

The final nail in this coffin is that the known software exploit, ‘deDECTed’, appears to have languished in development (most likely because of the situation with the PCMCIA cards) and was only included in one distribution of BackTrack, now Kali Linux.  You can still download it, but without the requisite hardware, you are pretty much at a standstill.

While all of the tools exist, is this threat realistic?  Why would someone go through all of this effort when, in all likelihood, it would have been probably a thousand times easier to hack the call recording system?  Hacking the call recording system would skip all of the rigmarole of surreptitiously going after the headsets and skip straight to searching the recordings.

In my opinion, while there is a threat, the risk of that threat occurring is low.  Based on this analysis, I would feel comfortable judging these DECT headsets as being PCI compliant and would provide this analysis in my work papers so that reviewers could understand my rationale.

However, this is me talking from my willingness to accept this risk.  Other people and organizations might not be quite so willing and may decide to not allow DECT headsets or phones.  That is their decision but it should be made with information and discussion such as was provided here and not in a vacuum as a “knee jerk” response.

By the way, this technique of capturing people’s conversations is much easier to do with Bluetooth and such tools exist in Kali Linux to accomplish that attack.  However, the same issue of one rogue device to one Bluetooth device still exists.  Good news there, Kali Linux is available for smartphones, so you only need a lot of smartphones to execute the attack.  That is mitigated by the fact that the distance for Bluetooth is only 30’ or 9m.  So as long as a call center enforces a policy of no personal or foreign technology on the call center floor, then any headsets should be safe.

The take away from this post is to think through the implications of the Council’s directives before you go off advising organizations that certain technologies are not PCI compliant.  While I agree with the Council’s answer to the question, it did not immediately mean that the technology was now verboten just because the technology’s basic characteristics appeared to make it non-compliant.  QSAs and organizations need to assess the threat, the risk of the threat occurring and then make a decision as to whether or not that threat is something to be managed or avoided.

27
Sep
14

Interested In Business As Usual?

I am encountering more and more organizations that are interested in business as usual or BAU.  Organizations are finally realizing that the only way they are ever going to feel secure is to embed security controls in their everyday business processes and make sure that they periodically assess that those controls are working.  The PCI SSC used a page and a half in the PCI DSS v3 to discuss the concept of BAU.  This leads some of us to believe that BAU will become part of the requirements at some point in the future.

However, what is involved and what will it take to implement BAU?  This post will give you an idea of what you will be up against.

Going through the PCI DSS v3, I did an analysis of the requirements and testing and came up with some interesting statistics regarding BAU.

  • There are 14 requirements/tests that are required to occur at least daily.
  • There are 18 requirements/tests that are required to occur whenever changes occur.
  • There are five requirements/tests that are required to occur whenever significant changes occur.
  • There is only one requirement/test that is required to occur at least weekly.
  • There are three requirements/tests that are required to occur at least monthly.
  • There are 11 requirements/tests that are required to occur at least quarterly.
  • There are four requirements/tests that are required to occur at least semi-annually.
  • There are 118 requirements/tests that are required to occur at least annually.

For my analysis, I assigned actual values to those requirements/tests that use the words “periodic” or “periodically” in their definitions.  The values I assigned were based on other standards or security “best practices”.  That is why my analysis does not include those references.

In total, there are 227 requirements/tests that need to be done at some frequency.  There are some requirements/tests that are duplicated in this count because they are not only required to be performed for example at least quarterly or annually, but they may also be required to be performed whenever changes occur.  The best example of this is vulnerability scanning which is required to be performed at least quarterly but also whenever a significant change occurs.

The biggest problem organizations will have with BAU is getting all of this integrated into their operational.  To address that, I tied the requirements to their priorities from the Council’s Prioritized Approach spreadsheet.  This allowed me to determine which BAU to implement first, second and so on.  What I found was:

  • There are 16 requirements/tests in BAU that have a ranking of ‘1’ (highest priority).
  • There are 75 requirements/tests in BAU that have a ranking of ‘2’.
  • There are 37 requirements/tests in BAU that have a ranking of ‘3’.
  • There are 58 requirements/tests in BAU that have a ranking of ‘4’.
  • There are 30 requirements/tests in BAU that have a ranking of ‘5’.
  • There are 11 requirements/tests in BAU that have a ranking of ‘6’ (lowest priority).

Once BAU is integrated into operations, organizations will want to ensure that it continues to operate effectively.  That will likely mean including the assessment of BAU as part of their internal audit activities.  This will further mean that departments will have to maintain evidence of their BAU activities to prove that BAU is being followed.  Some of that evidence will already be maintained in centralized logging and change control solutions.  However, other evidence such as with new user setup or user termination may have to be retained in a folder in the email system or exported as a readable file and stored on a file server.  The bottom line is that evidence of some form needs to be maintained to provide proof that BAU activities are performed and performed consistently throughout the year.

But that is the ultimate point about BAU.  It is all about engraining the security concepts in the PCI DSS to better ensure security is being maintained throughout the year, not just at assessment time.  And that is where most organizations fail with PCI is keeping the controls functioning throughout the year.

I have yet to encounter any organization that can prove to me that all of the PCI requirements are functioning at 100%, 24x7x365.  All organizations have issues with controls, but with BAU, the idea is to have a mechanism that identifies those issues before they become damaging and correct them before too many controls fail and result in a breach.  If you read any of the breach analysis reports, that is why the breach occurred because the controls were not functioning and no one addressed the failure.

29
Aug
14

Is The PCI DSS Effective?

Brandon Williams has a great blog post on his site that answers this question.

The bottom line is that there is no organization that is going to execute the PCI DSS, or any security framework for that matter, 100% of the time, all day, every day.

Why? 

Security is NOT perfect. 

Why? 

Because it involves human beings and we are flawed.

However, that does not mean that you should not try and be as close to 100% flawless as possible.  Because the difference between an organization that is breached and one that is not breached, can be only a percentage point.

For all of you in the United States, have a safe holiday weekend.

24
Aug
14

P2PE Versus E2EE

I have been encountering a lot of organizations that are confused about the difference between the PCI SSC’s point-to-point encryption (P2PE) certified solutions and end-to-end encryption (E2EE).  This is understandable as even those in the PCI community are confused as well.

E2EE is the generic terminology used by the IT industry to describe any solution that encrypts communications from one endpoint to another endpoint.  Key management of the encryption can be done by any party that has an endpoint such as a merchant or a service provider.  Examples of E2EE include IPSec, SSL and TLS.

One of the most common E2EE solutions used by merchants is derived unique key per transaction (DUKPT) also known as “duck putt”.  DUKPT is commonly used in the convenience store and gas station industries to encrypt sensitive authentication data (SAD) from the gas pump to the merchant or processor.  DUKPT uses the 56-bit data encryption standard (DES) encryption or triple DES (3DES) algorithms.  While DES and 3DES 56-bit and 112-bit are no longer considered secure, because DUKPT uses a unique key for every transaction, it means that every transaction has to be individually broken to gain access to the data.  While using the cloud could be leveraged to perform this rapidly, it would be too costly an effort for the data retrieved.  As a result, DUKPT is still considered a secure method of encryption.

P2PE is a subset of E2EE.  This is because the major difference between P2PE and E2EE is that P2PE does not allow the merchant to be a manager of the encryption keys.  Under the P2PE standard, only the transaction processor or other third party is allowed to perform key management.  The merchant is never allowed to perform encryption key management under the P2PE standard.  As a result, DUKPT can be used by both P2PE and E2EE solutions.  However, under P2PE, the key management must be done by a third party, not the merchant.

While third party key management is typically acceptable for small merchants, this does not work for merchants that switch their own transactions to various processors as do mid-sized and large merchants.  That does not mean that E2EE solutions are not acceptable for reducing PCI scope.  As with PA-DSS certified applications, P2PE certified solutions can be accepted by a QSA as long as they are implemented according to the P2PE implementation guide which can reduce the amount of testing a QSA is required to perform.  In my experience, P2PE versus E2EE testing efforts are typically negligible, so any so-called savings are limited at best.

The huge downside to P2PE for merchants is that once you decide on a given P2PE solution, you are pretty much stuck with it and the processor providing it.  That is because most processors offering P2PE are only offering one P2PE solution.  As a result, if a better deal comes along for processing your transactions, you will likely have to replace your terminals and possibly other equipment to switch to the new processor.  For some merchants, that could be a costly proposition and make any switch not worth the effort.

So if your organization is looking at P2PE versus E2EE, I would not necessarily give an advantage to P2PE over E2EE.  Just because an E2EE solution is not P2PE certified does not mean it is not secure.  It only means that the vendor did not believe that the P2PE certification was worth the effort.

08
Aug
14

Requirement 10.6.2 Clarification

As a refresher, requirement 10.6.2 states:

“Review logs of all other system components periodically based on the organization’s policies and risk management strategy, as determined by the organization’s annual risk assessment.”

The argument in PCI circles is the definition of “all other systems”.  Some of us believed that it meant systems other than those in-scope.  Other people believed that it had to refer to only in-scope systems such as a user workstation.  As a result, I asked the PCI SSC to clarify this requirement and this is the response I got back.

“In PCI DSS v2.0, logs for all in-scope systems were required to be reviewed daily. However it was recognized that for larger or more complex environments, there could be lower risk systems that were in scope for PCI DSS that could warrant less frequent log reviews. As such, PCI DSS v3.0 defines a number of events and system types that require daily log reviews, and allows the organization to determine the log review frequency for all other in-scope events and systems that do not fall into those categories.

For some environments, such as those designed specifically for the purposes of PCI DSS, then it is possible that all in-scope systems fall under the system categories defined in Requirement 10.6.1, meaning that daily log reviews are required for all in-scope systems. In other environments, there may be many different types of system that are considered in-scope, but which are not critical systems and neither store, process or transmit CHD nor provide security services to the CDE. Some possible examples could be stock- control or inventory-control systems, print servers (assuming there is no printing of CHD) or certain types of workstations. For these events or systems, the entity, as part of its annual risk assessment process, is expected to define the frequency for reviews based on the risk to its specific environment.

The intent of this update is not to apply PCI DSS Requirements to out-of-scope systems. We realize that the current wording is causing confusion and will address this in the next revision.”

So there we have it.  Not the first time my interpretation was wrong.  The requirement means in-scope systems that, from an assessment of risk, are at less of a risk of compromise can reduce the frequency of log reviews.

But that means you need to have an accurate risk assessment to support your argument.  So those of you that have not explicitly assessed the risk of your category 2 systems will have to break them out to support a reduced log review frequency.

08
Aug
14

The Dilemma Of PCI Scoping – Part 3

In part 2 we discussed the criticality of a risk assessment and started on implementing the framework with fixing monitoring and alerting so that we can properly manage the risk we will be accepting.  In this part I will deal with Category 2 and 3 systems and how to manage their risk.

One of the big problems I have with the security purists is with their arguments over Category 3 systems.  Do not get me wrong, I understand their reasons for their statements.  However to me, their arguments seem to imply that Category 3 systems are somehow not secure or not as secure as other systems and therefore cannot be trusted.  This further implies that organizations are implementing some sort of multi-tier security structure which should not be the case.  Taking such an approach would create an operational and support nightmare, let alone increase the risk of compromise.

In today’s world, all devices need to have a certain basic level of security comprised of, at a minimum, hardened OS, minimized ports and services, access control, anti-virus and anti-malware (as appropriate and necessary), personal firewall (if mobile), logging and other similar security measures as necessary.  All of this is something I like to refer to as “Security 101”.  If you are not doing Security 101 across the board, then you likely have bigger issues than just PCI compliance.  But if you are following a Security 101 approach, then all of your devices under your direct control should have a solid, basic level of security and should be able to be trusted when on your network.  As a result, with the proper logical access controls in place, you should be able to trust Category 3 systems coexisting with certain Category 2 systems.

Notice I said “certain Category 2 systems” not “all” Category 2 systems.

Category 2b systems that have inbound connectivity to the CDE are the most risky because of that direct inbound connectivity.  As such, should any Category 2b system become compromised, the CDE is also compromised by default.  Most Category 2b systems are gateways to the CDE such as with out-of-band management systems or “jump boxes” for network and system administration and Citrix or other virtual desktop technologies that you can use to grant business user access to CDE applications.

These gateways need to be configured such that if they become compromised they are immediately taken out of service until they can be rebuilt and/or reconfigured as secure.  This is typically accomplished not just with anti-virus, but also through file integrity monitoring, application whitelisting and other similar measures.  But this needs to be monitored at the virtual desktop infrastructure level (aka, Citrix, VMware, Terminal Services, etc. servers), as well as the virtual desktop image level.  If a file changes in the virtual environment or virtual desktop image that should not have changed, access to the virtual desktop environment is suspended until the infrastructure or image can be recertified as secure.  But that means very tight monitoring on the critical files, however this should be relatively easy to do as long as the virtual desktop image is restricted to only a single cardholder data (CHD) application.

The other thing that needs to happen with virtual desktop is that organizations must be extremely diligent about who has access to the virtual desktop.  This means very timely user management, something a lot of organizations are very lax about.  The PCI DSS states in requirement 8.1.4 that organizations must “Remove/disable inactive user accounts at least every 90 days.”  90 days is a very long time when you look at what attackers are able to do in such a timeframe.  As a result, organizations need to step up their game in this regard and when someone’s job function changes, that needs to have a help desk ticket generated for changing that person’s access.  A 90 day review process is fine, but if you are relying on that sort of thing as a control, you are not being diligent enough in managing your users.

But what about Category 2a systems you might ask?  Category 2a systems are directory servers, authentication servers, DNS and DHCP servers, anti-virus master servers, system update servers and other network and system management/monitoring support systems.  These systems are those that only system or network administrators should ever have direct access.  These systems should be configured as “bastion” servers, security hardened so that they are not easily compromised by vulnerabilities.  Most vendors of these systems understand this and have set up their installation routines accordingly – restricting services, allowing only necessary applications, etc.  The bottom line with Category 2a systems is that, if any of them become compromised, it is game over because the attacker has the privileges of an administrator.

I am not a fan of separate directory systems.  These systems double as the access control management system and the more complicated access control becomes, the more likely that access control becomes less reliable and secure.  As such, I prefer a common access control system managed through an integrated directory system such as Microsoft’s Active Directory (AD).  Over the years, the amount of ports required to make AD work between domain controllers have gotten much better and easier to implement.  Plus there is an ability starting with Windows Server 2008 to even limit and control the dynamic ports used.  As such, I recommend using a common domain approach rather than separate domains with trust relationships as it just makes management so much easier and more reliable.  Whether or not you choose to put domain controllers inside your CDE is up to you to decide.

However, there is a larger consideration here that needs to be put on the table.  Think about what the security purists are saying with their statements about Category 3 systems.  If an attacker can jump from a Category 3 system to owning a Category 2a system such as a directory server, DNS server, DHCP server, etc. what does that say about an organization’s security posture to begin with?  If an attacker gains control of a system/network administrator’s credentials, it is game over.  That is not a device failure issue, that is a social engineering failure.  As a result, you can have whatever controls of separation all you want, but in the end if an administrator gets owed, what did all of that separation do for you?  Nothing.  The best we can do is to manage and mitigate the risks and monitor for any attempts to leverage those risks and deal with any attacks as quickly as possible.

At the end of the day, organizations need to assess the risk that their Category 2 systems provide to the CDE.  If it is higher than desired, those systems need to be put into the CDE.  Others can share networks with other Category 2 and 3 systems if necessary.

There are obviously enhancements that you can make to further improve on this strategy.  But this is just what I would consider the minimum to get by which seems to be what a lot of you desire.

01
Aug
14

The Dilemma Of PCI Scoping – Part 2

In Part 1 I discussed how isolation is an answer, but probably not a viable answer for almost all but the most security conscientious of organizations such as the military, defense contractors or those that can afford that sort of painstaking luxury.  So unless you consider everything in scope for PCI compliance, is there a viable way to reduce scope?

Before we get to that though, we need a quick discussion on risk management as the solution is all predicated on the identification and management of risk.  Because if you cannot do an appropriate risk assessment, then the only choice you really have is to consider everything in scope I know the vast majority of you do not like that approach.

Assessing Risk

In order for my proposed solution to have a chance at working properly, an organization needs to understand its risks, what risks will be accepted and managed and what it will take mitigate the residual risks.  Doing a risk assessment is the way to do that, but most organizations avoid such an assessment for a variety of reasons.  The most common reasons I have heard are:

  • The risk assessment framework is too complex,
  • We tried this once before and never got any meaningful results,
  • We were never able to agree on the risks and their scores, or my personal favorite,
  • This spreadsheet is our risk assessment (it is not, but see Tom Benhave’s blog post on the topic as he does a much better job than I could explaining this topic).

The reason why risk is such a tough topic is that everyone has their own perspective on risk; good, bad or otherwise.  There are numerous articles and presentations on this phenomena but my favorite one is from Lance Spitzner of SANS who wrapped his around security awareness training and discusses risk at the start of his presentation describing why people are such poor judges of risk.  He uses various statistics regarding events that can happen in people’s lives to illustrate this fact.  My personal favorite example of just such a statistic is that people have a greater chance of dating a supermodel than of winning the PowerBall lottery.  Granted, both have tremendous odds, but the odds of dating a supermodel are still significantly less than the odds of winning the PowerBall.

The bottom line is that, without a decent risk assessment, an organization has no way to know the amount of risk the organization is willing to accept and how they will manage that risk.  The Council has repeatedly said that PCI compliance is supposed to consider risk and take a “risk-based” approach.  However, the problem is that we each have our own opinion of risk and what risks we are willing to take on.  But at the end of the day, no matter what an organization does, there is going to be risk.  The question is, “Are these risks my organization willing to take on?”  That question can only be answered by a risk assessment and an understanding of how risks can be managed and mitigated.

How your organization chooses which risks it is will to accept and how to manage those remaining risks are up to your organization to decide.  This is why the PCI DSS and all other security frameworks require an annual risk assessment to be performed.  The risk assessment process provides a framework for an organization to document their risks, understand those risks (size, frequency of occurrence, costs, etc.), how the risks can be managed or mitigated, then agree to what risks they will take on and how they will manage and/or mitigate those risks.

From here on we will assume that the organization has a valid risk assessment and that they are willing to take on the risks presented by the example I will discuss.

Managing Risk

Today’s integrated and connected world just does not lend itself to an isolationist approach due to the volume of information involved, business efficiencies lost and/or the operational costs such an approach incurs.  As a result, organizations need to take a hybrid approach of heavily protecting some components and taking on and managing the risks inherent to such an approach.

When it comes to the IT side of risk management and mitigation, most organizations rely on some form of near real time monitoring through collected system/event log data and other sources to monitor their environment(s).  Unfortunately, where this approach comes up short is that there are too many alerts to follow up and so alerts go unaddressed.  Almost every QSA can tell you about a discussion with operations personnel where the statement, “Oh, that’s a false positive alert, so I don’t have to worry about it” has been made.

This is the first problem you must address and make sure that this attitude never creeps back into your people that monitor alerts.  Anyone in operations that “knows” an alert is a false positive needs either: (1) re-education, or (2) your organization needs to seriously re-tune your alerting mechanism(s).  All you have to do is read the Target and Neiman Marcus press reports if you need examples of how bad things can get if your personnel are blowing off alerts because they believe they are not accurate.

In my experience, a lot of these problems are the result of bad or incomplete implementations of these systems.  Unfortunately, there are a lot of people out there that think that these solutions are more like a Ronco Rotisserie Oven where, as they famously say in the ads, “you can set it and forget it.”  Yes these solutions may be “appliances”, but that is where the comparison ends.

System incident and event management (SIEM) systems require fairly constant tuning and tweaking, beyond their own software and signature updates, to minimize false positive alerts in response to the changes to an organization’s networks and systems.  Yet time and again, I encounter monitoring and alerting systems that were put in place years ago (typically to meet PCI compliance) and have not been adjusted/changed since then while all around them changes have been occurring that affect their operation.

When interviewing the people responsible for these systems I hear statements such as, “Yeah, that alert started to appear when we implemented [name of change].  We were told to just ignore it.”  When asked why they have not tuned it out of the SIEM, you get either they do not have time, they do not know how, they do not have the rights to do that or, my personal favorite, the head of security or the security committee will not let us change that.

The reason this issue does not get addressed is that it has no visibility since alerts are tucked into the various monitoring tools.  So, the best way to address this situation is to give it visibility by automatically feeding all alerts into an organization’s help desk system.  This gives all alerts immediate visibility by putting them in an automated tracking and escalation process.  It also allows for triage and investigation activities to be documented and, based on the results of those triage and investigation activities, having the alert assigned to the right people/groups to address the alerts.

“Whoa, let’s not get crazy here,” I am sure some of you are YELLING at the screen.  There is no doubt this is a very brave step to take because this will potentially uncover something you probably did not want to advertise given the state of your existing alerting.  But that is typically only be a short term problem.  Unfortunately, it may be the only way to get the underlying problem of tuning and tweaking of the alerting systems completed and constantly addressed.

But taking such a step is not entirely a bad thing, at least in the long run.  A side benefit of doing such a thing is that it will focus an organization on triage activities for classifying the urgency of the alerts.  Not all alerts need immediate action, but a lot of them can require immediate investigation and then can be put on a back burner.  It will also give visibility to the number of alerts being dealt with on a daily basis after triage.  That typically results in identifying and justify why more staff are required to deal with the onslaught of alerts that need to be researched.

Another change that organizations should make is adding a box into their change control form that indicates what the impact of a change will have on the SIEM environment.  At least these three basic questions need to be answered in regards to SIEM or other monitoring systems.

  • Do new alerts need to be added and, if so, what do they need to monitor and what are the alerting thresholds?
  • Do existing alerts need to be modified and, if so, what modifications are needed?
  • Are there alerts that are no longer needed?

If you address these areas, you should have monitoring and alerting taken care of with a built in feedback loop to keep it that way.

In Part 3, I am going to wrap up my discussion on PCI scoping with a discussion of Category 2 and 3 systems.




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February 2023
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