PCI Compliance - A Realistic Approach. Harshul Joshi, CISM, CISA, CISSP Director, Information Technology CBIZ MHM

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1 PCI Compliance - A Realistic Approach Harshul Joshi, CISM, CISA, CISSP Director, Information Technology CBIZ MHM

2 What What is PCI A global forum launched in September 2006 for ongoing enhancement of security standards for account data protection. Standard created by 5 major credit card association resulting from security programs of the individual card brands Visa MasterCard American Express Discover JCB

3 Who Who Any company who stores, processes or transmits cardholder data must comply with PCI. This includes all brick and mortar and e-commerce merchants as well as service providers. Merchants are broken into 4 levels Level 1 Greater than 6 million Visa and MC transactions Level 2 Between 1 million and 6 million transactions Level 3 Between 20,000 and 1 million e-commerce transactions annually Level 4 Less than 20,000 e-commerce and Less than 1 million any other way.

4 Why Non Compliance and Security Breaches = Fines Penalties include Up to $500,000 per security breach Up to $25,000/month per every merchant non-compliant from card brand to merchant bank Barred from processing credit card transactions Escalation to Level 1 for any security breach irrespective of transaction volume

5

6 PCI common failures

7 PCI Storage

8 2 Phased Approach Phase 1: Card Holder Data Environment (CDE) Present flow and architecture Current service providers and processors Possible changes in business process and/or arrangement with service providers Contracts and Service Level Agreements (SLA) with third party service providers Possible changes in the infrastructure

9 2 Phased Approach Phase 2: PCI Technical requirements: Network segmentation Synergies with current security policies and procedures Synergies with efforts put into SOX, GLBA, HIPAA etc. Most practical way to deal with requirement 6.6 SILO approach Vs Overlap approach

10 Phase 1 Understand the current flow of customer credit card in your environment Figure out all the avenues by which credit card information is accepted Web site Customer care call center Regular mail IVR (Interactive Voice Response)

11 Process Flows Flow Diagram Customer calls 800 number Cust. Rep will take The order over the phone System X interacts with Processing bank Transaction is entered in system X

12 Flow Diagram Incomplete Information Is the call recorded? If yes, then what happens to the tapes? Is the call center internal or outsourced? Who system is the order entered? Is the interaction with processor real time or batch? If batch then how is the data stored?

13 Process Flows Take into account interaction with Service Providers Understand the contractual agreement with Service providers and hosting providers Inter-country encryption laws for customer care

14 Phase 2 Technical Aspect 12 Key requirements Install and maintain firewall configuration to protect data Do not use vendor supplied defaults for system passwords and other security parameters Protect stored data Encrypt transmission of card holder data across open, public networks Use and regularly update anti-virus software Develop and maintain secure systems and applications Restrict access to cardholder data by business need-to-know Assign a unique ID to each person with computer access Restrict physical access to cardholder data Track and monitor all access to network resources and cardholder data Regularly test security systems and processes Maintain a policy that addresses information security

15 Phase 2 Before jumping into the requirements: System scope analysis should be the top priority The PCI DSS security requirements apply to all system components. A system component is defined as any network component, server, or application that is included in or connected to the cardholder data environment. The cardholder data environment is that part of the network that possesses cardholder data or sensitive authentication data. Network components include but are not limited to firewalls, switches, routers, wireless access points, network appliances, and other security appliances. Server types include, but are not limited to the following: web, database, authentication, mail, proxy, network time protocol (NTP), and domain name server (DNS). Applications include all purchased and custom applications, including internal and external (internet) applications.

16 Scope Analysis Scope Reduction Network Segmentation Firewall VLAN

17 Scope Analysis The scope of compliance validation is focused on any system(s) or system component(s) related to authorization and settlement where cardholder data is stored, processed, or transmitted, including the following: All external connections into the merchant network (for example; employee remote access, payment card company, third party access for processing, and maintenance) All connections to and from the authorization and settlement environment (for example, connections for employee access or for devices such as firewalls and routers) Any data repositories outside of the authorization and settlement environment where more than 500 thousand account numbers are stored. A point-of-sale (POS) environment the place where a transaction is accepted at a merchant location (that is, retail store, restaurant, hotel property, gas station, supermarket, or other POS location) If there is no external access to the merchant location (by Internet, wireless, virtual private network (VPN), dial-in, broadband, or publicly accessible machines such as kiosks), the POS environment may be excluded

18 Scope Analysis Process and Technology Standardization Reduce sampling Easier manageability Virus definitions Application security

19 Ok Some Deep Diving Approach Start with Requirement 12 Requirement 12 covers policies and procedures which drives all other requirements Operational security procedures Usage policy and procedures Information security responsibilities for all employees and contractors Monitoring and analyzing security alerts Security awareness program Employee screening Contractual agreements with third party service providers Asset management

20 Application Level Requirement Addresses SQL injection, cross-site scripting and other application level attacks Complements existing requirements for secure coding of web applications (6.5) and application level penetration testing (11.3.2) Seeks to provide added assurance that sites are not vulnerable, by either of the following methods: Having all custom application code reviewed for common vulnerabilities by an organization that specializes in application security Installing an application layer firewall in front of web-facing applications

21 Requirement 6 6 Develop and maintain secure systems and applications 6.1 All system components have the latest vendor supplied security 6.2 Establish a process to identify newly discovered security vulnerabilities. Update standards to address new vulnerability issues. 6.3 Develop software application based on industry best practices and incorporate security throughout the SDLC testing of all patches before deployment separate development, test and production environments

22 Requirement Follow change control procedures for all system and software configuration changes Documentation of impact Management sign-off 6.5 Develop all web applications based on secure coding guidelines such as OWASP guidelines. Review custom application code to identify coding vulnerabilities. Cover common coding vulnerabilities to include the following: Unvalidated input Broken access control

23 Requirement 6.6!! 6.6 Ensure that all web-facing applications are protected against known attacks by applying either of the following methods: Option 1: Application Code Reviews: 1. Manual review of application source code 2. Proper use of automated application source code analyzer 3. Manual web application security vulnerability assessment 4. Proper use of automated web application security vulnerability assessment tools

24 Requirement 6.6!! Option 2: Install application layer firewall in front of webfacing applications Recommended capabilities: Inspect web application input and respond based on active policy or rules Inspect both web page content such as HTML, DHTML and the underlying protocols Support SSL and/or TLS termination or be positioned such that encrypted transmissions are decrypted before being inspected by WAF.

25 Some More Examples Requirement 1: Install and maintain a firewall configuration to protect cardholder data Justification for non-standard protocols Voice data Video Extranet customized applications Inbound traffic restrictions

26 Some More Examples Requirement 1: (1.3.1, 1.3.2, 1.3.3) Internet Border Router Web server Firewall Internal LAN

27 Some More Examples Requirement Wireless Environment Changing of WEP keys if used Default SSID changed and Broadcast disabled WPA or WPA2 technology enabled WPA2 and i are the same. WPA2 is the name used by the Wi-Fi Alliance, whereas i is the name given to the standard by the IEEE WPA draft / uncompleted version of i WPA and WPA2 can use the same authentication methods, because they are all EAP based. EAP stands for Extensible Authentication Protocol and, as the name suggests, many different protocols can be built on top of EAP. So both EAP/TLS as well as EAP/PEAP-MSCHAPV2 will work both for WPA and for WPA2

28 Some More Examples Wireless transmitting cardholder data Appropriate encryption If WEP used (In conjunction with WPA or WPA2, VPN or SSL/TLS) Shared WEP keys rotated quarterly and whenever there are changes in personnel with access to keys MAC based filtering For new wireless implementations, it is prohibited to implement WEP after March 31, For current wireless implementations, it is prohibited to use WEP after June 30, 2010.

29 Some More Examples 11.3 Vs 11.2 Penetration Testing Vs Vulnerability scans One just identifies and reports vulnerabilities where as other actually exploits it What methodology to use for Penetration testing Black Box Vs Informed? Inform internal or external monitoring staff? How often?

30 Some More Examples 11.4 Use of Intrusion Detection System What is the best placement? How to deal with false positives and false negatives? IDS Vs IPS?

31 Examples - Logging and Monitoring 10.2 Implement automated audit trails for all system components to reconstruct the following events: All individual accesses to cardholder data All actions taken by any individual with root or administrative privileges Access to all audit trails Invalid logical access attempts Use of identification and authentication mechanisms Initialization of the audit logs Creation and deletion of system-level objects

32 Examples - Logging and Monitoring 10.6 Review logs for all system components at least daily. Log reviews must include those servers that perform security functions like intrusion-detection system (IDS) and authentication, authorization, and accounting protocol

33 Compensating Controls When an entity cannot meet a technical specification of a requirement, but has sufficiently mitigated the associated risk. The effectiveness of a compensating control is dependent on the specifies of the environment in which the control is implemented, the surrounding security controls, and the configuration of the control.

34 Compensating Controls Constraints / Objective / Identified Risk / Definition of Compensating Controls Some examples: Need to use FTP No budget to upgrade to WPA or WPA2 6.1b Not feasible to install security patch within 30 days Legacy system will not accept alpha-numeric and 7 character passwords

35 For More Information Harshul Joshi Director, Information Technology CBIZ MHM

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