QSAs: SecurityMetrics in Remediation

Noone at SecurityMetrics had any comment on why the company was sent into remediation. As you'll notice, Chris Konrad from Fortrex kindly stepped up and posted the yesterday about the plan to remediate, and the company's committment to resolve the  internal issues that caused the status change. Anyone from SecurityMetrics? PSC?

How to Choose a PCI Assessor

Choosing an assessor is a lot like choosing a car. Some of them get you there quickly, some of them are reliable, and your mileage may vary. There are a number of factors to consider, including:

Ask to See Your QSA’s Resume

There are A LOT of people in the information security space, and their backgrounds vary pretty wildly. Make sure that you are comfortable with the skillset of your assessor, his or her work experience, and their knowledge of PCI. Also, make sure that the person who shows up is in fact the person who’s resume you reviewed. You may want to interview them as well to insure that they have a knowledge level that you're comfortable with.

Talk to other Merchants

There are people out there who have gone through this multiple times, and have probably used more than one assessor. Ask them what they thought about the assessor meeting their expectations in terms of technical abilities, and delivery timeframes.

Timeframe to Completion / QSA Availability

What is sales willing to commit to on paper in terms of having an assessor at your facility? How long will the assessment take? The answer may surprise you. If you’re a level 1 service provider, and they’re only going to spend 3 days reviewing your security controls, you may want to keep shopping. On the other hand, if its going to take 6 months to complete the assessment, that's probably less than optimal as well.

Your assessor should be able to start within 30 days, and given that there are 200+ requirements that need to be answered for with interviews, observation, and direct evidence gathering, the process will take some time. For an average level 1 merchant , 60-90 days is a reasonable expectation if you've been through the process before and are prepared.

Perform a “Pre-Assessment” Yourself

Understand what the scope of your environment is, and try to anticipate the results of your assessment. This will allow you to speak to the issues with confidence. In the event that you disagree with your assessor on a particular technology or architecture, you’ll be able to defend your position on its deployment without having to use your bank as an intermediary.

(Shameless Plug: We help a lot of people with this.)

Talk to your bank

Do they have a solid reputation with your acquiring bank and/or the card brands that you work with? Banks have to review a lot of scan reports, ROCs, and self assessment questionnaires. They see the cumulative results of many different assessors, and can provide you with valuable input as to who has delivered consistent, quality assessments. On the other hand, some assessors have a practice of "partnering" with banks, and those banks use that assessor as their "preferred assessor," making the recommendation somewhat worthless, because the answer is always the same, irrespective of the situation.

QSAs: PSC and Fortrex First to Go Down in New SSC Quality Assurance Program

Neither the principals of PSC (Payment Software Company) or Fortrex, Inc. (both Qualified Security Assessors) had any comment when asked about why their companies were put on probation by the PCI Security Standards Council in late January.

Both companies appear to be lacking the appropriate work papers that are required as supporting documentation to PCI assessments. All QSACs were told about the SSC reviews of work materials in July of last year, so unless they just weren't collecting or keeping their evidence, i'm unsure how you would screw up this badly. Maybe they didn't believe the QA program was real?

What will be interesting to see is whether or not they are able to recover from this. I suppose that if Trustwave can be the assessor of record for 2 of the 3 most major breaches in world history and noone wants to talk about it that these guys will be fine by next quarter.

PCI-DSS Compliance – Requirement 6.6: Web App Firewall, or Code Review?

In short – Yes.

Organizations that are in the process of determining whether or not they should install an application firewall in front of their web facing applications, OR do a code review should make a best effort to do both.

Why? Because, web application firewalls, while very useful, and generally very thorough are designed to perform a limited number of protection tasks, that are typically based on existing, deployed web technologies.

Web technologies are evolving, and more and more custom applications exist. For instance, CGI based vulnerabilities popped up as soon as CGI came into existence. Developers simply did not understand the threats associated with query string vulnerabilities, safe passage of variables, or safe backend system call execution. Then of course, php and asp represented new threats such as SQL injection, file path inclusion, XSS, etc.

Every time there has been a shift in web technology, a new threat landscape has emerged. More and more, open-source server-side web-apps are showing up in payment environments. Mambo CMS is a perfect example. It provides a great platform for easy deployment of nearly any site architecture. It’s also been compromised many times, and its been deployed as a front end for applications which process payments.

When you weigh the option that DSS provides of either source code review or web application firewall, you should understand that you’re going to obtain vastly different results from those two methods.

Installing a web application firewall will thwart the 99.9% of attacks that happen as a result of publicly disclosed vulnerabilities that are either being executed by a bot or an attacker with a luke warm degree of motivation.

A source code review will afford you visibility into the security of the application from otherwise unknown attack vectors and hopefully give you insight into not only vulnerabilities that exist as a result of insecure coding techniques, but along with a solid educational experience, the peace of mind that your developers are learning how to avoid common mistakes after you’ve received the results of the review.

Also, less vulnerabilities in the protected zone means less possibility of internal compromise. Don't forget that the majority of compromises happen from within.

So again, the answer to the question is yes. Install a web application firewall if your organization can afford the technology. Perform a source code review of both 3^rd party apps, and –especially- in-house developed code to provide a second layer of protection and valuable feedback to your development team.

This will allow you to use PCI as a valuable tool, instead of just one more exercise in compliance.

PCI Segmentation - Seriously?

A friend who recently went through the new annual QSA re-certification training a while back shared the most recent training manual with me. I have to say, that some of the clarifications are astonishingly... bad.

Specifically what I am taking issue with is the clarification around network segmentation. The title of the slide is:

"What are acceptable forms of Network Segementation?"

Then the slide describes Cisco access control lists.

Right.

Think I'm nuts? The slide goes on further to give the following example:

access-list 100 deny ip 10.0.0.0 0.255.255.255 any log

access-list 100 deny ip 127.0.0.0 0.255.255.255 any log

etc...

Another interesting sub bulletpoint is "Confirm audit logging is in place for all access to segmented network," suggesting that there are cases wherein you would not only be exclusively using ACLs, but that you may create specific ACLs which allow access to the "protected" network from the unprotected interface.

Translated:

"Cisco ACLs are effective protection for the cardholder environment, and if you need to make exceptions to your already bad security practice by allowing administrative traffic in from the outside, then go ahead."

Its any wonder that compliance numbers grow every year, and so do the number of compromises.