ARE YOU REALLY PCI DSS COMPLIANT? Case Studies of PCI DSS Failure! Jeff Foresman, PCI-QSA, CISSP Partner PONDURANCE

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1 ARE YOU REALLY PCI DSS COMPLIANT? Case Studies of PCI DSS Failure! Jeff Foresman, PCI-QSA, CISSP Partner PONDURANCE

2 AGENDA PCI DSS Basics Case Studies of PCI DSS Failure! Common Problems with PCI DSS Compliance What is new in the PCI DSS v3 standard How to achieve PCI DSS compliance 2

3 PCI DSS BASICS 3

4 PCI SSC OVERVIEW The PCI Security Standards Council (PCI SSC) is responsible for the development, management, education, and awareness of the PCI Security Standards The Council's five founding global payment brands are: American Express Discover Financial Services JCB International MasterCard Worldwide Visa Inc. Enforcement of compliance and determination of any noncompliance penalties are carried out by the individual payment brands and not by the PCI SSC 4

5 PCI SSC RESPONSIBILITIES Issue new standards and manage the standards life cycle Enhance cardholder data security and create cardholder data security awareness Manage the certification process of: Assessors QSA, PA-QSA, PFI, ISA Vulnerability Scanning ASV Program Forensic Investigators PFI Program Payment Applications PA-DSS Validated Applications The PCI SSC does NOT validate or enforce PCI DSS compliance, nor does it impose penalties for noncompliance 5

6 PAYMENT BRAND RESPONSIBILITIES Payment brand compliance programs include: Tracking and enforcement Penalties, fees, compliance deadlines Validation process and who needs to validate Approval and posting of compliant entities Definition of merchants and service provider levels Payment brands are also responsible for forensics analysis and response to account data compromises 6

7 MERCHANT OR SERVICE PROVIDER? Merchant: Is any entity that accepts payment cards bearing the logos of any of the five members of PCI SSC (American Express, Discover, JCB, MasterCard or Visa) as payment for goods and/or services Note that a merchant that accepts payment cards as payment for goods and/or services can also be a service provider, if the services sold result in storing, processing, or transmitting cardholder data on behalf of other merchants or service providers Service Provider: Is a business entity that is not a payment brand, directly involved in the processing, storage, or transmission of cardholder data This also includes companies that provide services that control or could impact the security of cardholder data 7

8 CASE STUDIES OF PCI DSS FAILURE! 8

9 WHY DO COMPANIES FAIL PCI DSS? PCI DSS Compliance Is Really Hard! 300+ requirements and test procedures Requirements are not specific enough for easy implementation Organizations do not understand how to scope a PCI DSS assessment View PCI DSS compliance as a project and do not integrate it into business and IT processes PCI DSS should be implemented into business-as-usual (BAU) activities as part of an entity s overall security strategy Believe PCI DSS compliance will make them secure Successful completion of a system scan or PCI DSS assessment is only a snapshot in time Security exploits are non-stop and get stronger every day, which is why PCI compliance efforts must be a continuous process of assessment and remediation to ensure safety of cardholder data Believe the lowest priced PCI DSS assessment is the same as a higher priced assessment You get what you pay for! 9

10 PCI DSS COMPLIANCE BY SECTION Source: Verizon 2014 PCI Report / Red = 2013 Grey =

11 CARDHOLDER DATA SEGMENTATION Organizations do not understand PCI DSS segmentation requirements and improperly segment their networks The first step in achieving PCI DSS compliance is determining the scope of your Cardholder Data Environment (CDE) The scope of the CDE can be reduced through segmentation Segmentation is NOT a PCI DSS requirement Segmentation may not help an organization achieve compliance 11

12 PCI DSS SCOPING GUIDANCE The PCI DSS requirements apply to all system components included in or connected to the Cardholder Data Environment (CDE) The CDE is comprised of people, processes and technologies that store, process, or transmit cardholder data or sensitive authentication data. Examples of system components include but are not limited to the following: Systems that provide security services, facilitate segmentation, or may impact the security of the CDE. Virtualization components such as virtual machines, virtual switches/routers, virtual appliances, virtual applications/desktops, and hypervisors. Network components including but not limited to firewalls, switches, routers, wireless access points, network appliances, and other security appliances. Server types including but not limited to web, application, database, authentication, mail, proxy, Network Time Protocol (NTP), and Domain Name System (DNS). Applications including all purchased and custom applications, including internal and external (for example, Internet) applications. Any other component or device located within or connected to the CDE 12

13 PCI SCOPING CASE STUDY #1 No Segmentation All workstations and wireless networks are in scope for all PCI DSS requirements Corporate Desktops ` Mobile Users ` Wireless Access Point Router Firewall Web Server Internet All external facing systems are in scope for all PCI DSS requirements Corporate LAN All servers are in scope for all PCI DSS requirements Server Database Server E-Commerce Server All systems storing or processing CHD are in scope for all PCI DSS requirements Corporate Servers Application Server Audit Logging Server E-Commerce Database Server 13

14 PCI SCOPING CASE STUDY #2 With Segmentation Mobile Users Router Internet All workstations that access CHD are in scope for all PCI DSS requirements. IF no CHD is used on wireless network then it is out of scope. Corporate Desktops ` ` Server Wireless Access Point Corporate LAN Database Server Firewall Routers w/fw Feature Set Web Server E-Commerce Server PCI LAN All external facing systems are in scope for all PCI DSS requirements All systems storing or processing CHD are in scope for all PCI DSS requirements Corporate Servers Application Server Audit Logging Server E-Commerce Database Server 14

15 STORAGE OF CARDHOLDER DATA Organizations are storing Cardholder Data when it does not require retention Organizations are unknowingly storing Sensitive or Cardholder Data PCI DSS Requirements: Do not store sensitive authentication data after authorization (even if encrypted). If sensitive authentication data is received, render all data unrecoverable upon completion of the authorization process. Required to review transaction logs, error logs, history logs, debug files and databases for sensitive and cardholder data If Cardholder Data is stored then render it unreadable 15

16 CHD DISCOVERY CASE STUDY Users can store reports containing CHD on local drives Users can CHD to other users or customers Corporate Desktops ` CHD Mobile Users ` CHD Wireless Access Point Router Firewall CHD Web Server Internet Web servers can store transaction files that contain PAN and CVC/CVV codes Corporate LAN Users can store reports containing CHD in network shares CHD CHD Server CHD CHD Database Server CHD CHD E-Commerce Server Application servers can store transaction files that contain PAN and CVC/CVV codes CHD Corporate Servers Application Server Audit Logging Server E-Commerce Database Server CHD maybe be sent from one application server to another application server even though the data is not required. CHD maybe be stored in free-form text or note fields by users CHD maybe be sent to the Audit Logging server from other application and databases 16 16

17 SAMPLE TRANSACTION LOG 15 May :18:43,603 [2180] DEBUG WebCheckin.BasePage - TRANSID: {no_transid} - PageLoad: PleaseWait.aspx process=getreservation 15 May :18:44,134 [7652] INFO Kinetics.XmlUtil - XmlUtil::Transact - attempting transaction with Uri "http:// :64080" 15 May :18:44,134 [7652] DEBUG Kinetics.XmlUtil - XML Request : <?xml version="1.0" encoding="utf-8"? ><FindResByCardRequest><Input><Card><Number>3785XXXXX83000</Number><Type></ Type></Card><FName>REINHOLD</FName><LName>GRELLMANN</LName><DepartureCity></ DepartureCity></Input></FindResByCardRequest> 15 May :18:44,697 [6652] DEBUG WebCheckin.BasePage - TRANSID: DEN- NET PageLoad: PleaseWait.aspx process=buildseatmap 15 May :18:44,791 [796] DEBUG WebCheckin.BasePage - TRANSID: DEN- NET PageLoad: VerifyItinerary.aspx 15 May :18:44,791 [796] INFO Kinetics.XmlUtil - XmlUtil::Transact - attempting transaction with Uri "http:// :64080" 15 May :18:44,791 [796] DEBUG Kinetics.XmlUtil - XML Request : <?xml version="1.0" encoding="utf-8"?><buildseatmaprequest><transactionid>den-net </ TransactionID></BuildSeatMapRequest> 17

18 VULNERABILITY MANAGEMENT The recent announcements of major breaches such as Target and Neiman Marcus show that many organizations do not have effective vulnerability management program PCI DSS Requirements: Develop a Vulnerability Management Program to identify vulnerabilities using outside sources, assign a risk ranking and notify appropriate IT staff for remediation Install applicable critical security patches within one month of release Critical security patches should be identified according to the risk ranking process defined in Requirement 6.1 Installation of all applicable security patches within three months 18

19 PCI DSS 6.1 / 6.2 GUIDANCE The intent of this requirement is that organizations keep up-todate with new vulnerabilities that may impact their environment Sources for vulnerability information should be trustworthy and often include vendor websites, industry news groups, mailing lists, or RSS feeds Once an organization identifies a vulnerability that could affect their environment, the risk that the vulnerability poses must be evaluated and ranked The organization must have a method in place to evaluate vulnerabilities on an ongoing basis and assign risk rankings to those vulnerabilities This is not achieved by an ASV scan or internal vulnerability scan, rather this requires a process to actively monitor industry sources for vulnerability information Classifying the risks (for example, as high, medium, or low ) allows organizations to identify, prioritize, and address the highest risk items more quickly 19

20 SECURITY TESTING The largest failure area of the PCI DSS standard is Section 11 related to vulnerability scanning and penetration testing ** PCI DSS Requirements: Run internal and external network vulnerability scans at least quarterly Perform internal and external rescans after any significant change Scans must be performed by qualified personnel ** Verizon 2014 PCI Data Breach Report 20

21 SECURITY TESTING Requirements Internal Vulnerability Scan External Vulnerability Scan Frequency Quarterly & After Changes Quarterly & After Changes Scope Performed By Passing Scan Documentation All internal IP Addresses included in or connected to the CDE Qualified Independent Internal Staff or External Vendor No High Risk defined by Vulnerability Management Rating 4 Passing Internal Scan Reports Annually All external IP addresses in the CDE or providing a path to the CDE Approved Scanning Vendor (ASV) No vulnerabilities rated 4.0 or higher by the CVSS, and no automatic failures (ie SSL v2) 4 Passing External ASV Approved Scan Reports Annually 21

22 SECURITY TESTING The intent of a penetration test is to simulate a real-world attack situation with a goal of identifying how far an attacker would be able to penetrate into an environment PCI DSS Requirements: Develop and implement a methodology for penetration testing ** Perform external and internal penetration testing at least annually and after any significant infrastructure or application changes Testing includes network and application penetration testing Application penetration testing should include vulnerabilities listed in Requirement 6.5 Vulnerabilities found during penetration testing are corrected and testing is repeated to verify the corrections If segmentation is used, perform penetration tests to verify segmentation isolates all out-of-scope system ** Best practice until June 30,

23 SECURITY TESTING Requirements Internal Penetration Test External Penetration Test Frequency Annual & After Changes Annual & After Changes Scope Performed By Passing Test Documentation All internal IP Addresses included in or connected to the CDE and all internal in-scope applications Qualified Independent Internal Staff or External Vendor All noted exploitable vulnerabilities were corrected Internal Network Penetration Test Report Internal Application Penetration Test Report - Showing methodology used and vulnerabilities were corrected All external IP addresses in the CDE or providing a path to the CDE and all external facing applications Qualified Independent Internal Staff or External Vendor All noted exploitable vulnerabilities were corrected External Network Penetration Test Report External Application Penetration Test Report - Showing methodology used and vulnerabilities were corrected 23

24 24 VULNERABILITY SCAN CASE STUDY

25 AUDIT LOGGING The audit logging requirement in PCI DSS in one of the hardest requirements for most organizations to meet Audit Logging is critical in preventing, detecting and minimizing the impact of a data breach Determining the cause of a breach is very difficult, if not impossible, without logs PCI DSS Requirements: Implement audit trails to link all access to system components to each individual user Synchronize all critical system clocks Secure audit trails so they cannot be altered Review logs for all system components to identify anomalies or suspicious activity Retain audit trail history for at least one year 25

26 AUDIT LOGGING What to Log (10.2): All individual access to cardholder data. All actions taken by any individual with root or administrative privileges. Access to all audit trails. All actions taken by any individual with root or administrative privileges. Use of identification and authentication mechanisms. All elevation of privileges. All changes, additions, or deletions to any account with root or administrative privileges. Initialization of audit logs. Stopping or pausing of audit logs. Creation and deletion of system level objects. What is in each Log (10.3): User identification Type of event Date and time Success or failure indication Origination of event What to Review (10.6): All security events Logs of all system components that store, process, or transmit CHD and/or SAD, or that could impact the security of CHD and/or SAD Logs of all critical system components Logs of all servers and system components that perform security functions (for example, firewalls, intrusion-detection systems/intrusionprevention systems (IDS/IPS), authentication servers, e-commerce redirection servers, etc.) 26

27 27 AUDIT LOGGING CASE STUDY

28 FIREWALL RULES Very few organizations, firewall administrators or PCI QSAs understand the requirements for firewall rules and filtering traffic PCI DSS Requirements: A formal process for approving and testing all changes to firewall and router configurations Diagram that identifies all connections to the CDE and Cardholder Data flow Documented list of all services, protocols and ports, including business justification Identify insecure services and implement security features for each service (i.e. FTP only over VPN) Review firewall and router rule sets at least every six months Firewalls are installed between all wireless networks and the CDE 28

29 FIREWALL RULES Inbound Rules Restrict inbound traffic to that which is necessary for the CDE Other inbound traffic is specifically denied Limit inbound Internet traffic to IP addresses within the DMZ Do not allow any direct connections inbound for traffic between the Internet and the CDE Place system components that store cardholder data in an internal network zone, segregated from the DMZ and other untrusted networks. Outbound Rules Restrict outbound traffic to that which is necessary for the CDE Other outbound traffic is specifically denied Do not allow unauthorized outbound traffic from the CDE to the Internet Do not allow any direct connections outbound for traffic between the CDE and the Internet Do not disclose private IP addresses and routing information to unauthorized parties 29

30 FIREWALL RULE CASE STUDY PCI Segmentation Firewall Rule Example External Firewall Rule Example #1 30 External Firewall Rule Example #2

31 OTHER COMMON PCI DSS FAILURE POINTS Configuration Standards Based on Industry Hardening Standards Vulnerability Scan to validate compliance to standards Software Development Provide developers with secure code training and application vulnerability scanning tools Include application vulnerability scanning in testing process File Integrity Monitoring Deploy on all servers that store, process or transmit Cardholder data Security Awareness Training All employees must complete on annual security awareness training covering threats to cardholder data and covering information security policies and procedures 31

32 Q&A Jeff Foresman, PCI-QSA, CISSP

Case 2:13-cv-01887-ES-JAD Document 282-2 Filed 12/09/15 Page 1 of 116 PageID: 4879. Appendix A

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