PIN Security and Key Management to Prevent Data Breaches

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1 white paper PIN Security and Key Management to Prevent Data Breaches January 2009»»Summary In 2008, it was shown that persistence can indeed pay off for the criminal element. Data breaches and compromises are plentiful and appear to be gaining momentum in frequency and scope. According to the Identity Theft Resource Center as of November 13, 2008, there have been an estimated 33,585,557 records exposed in 572 data breaches in 2008 alone. Other organizations, such as the Privacy Rights Clearinghouse, put the number of reported compromised records at over 245 million since January This number may actually be larger because many organizations are not compelled by local laws to divulge this information or are unaware a breach has even taken place. The sheer amount of information that has been breached forces the industry to focus less on breach prevention and more on loss mitigation as the resulting fraud losses accumulate. The financial industry s task in recent months has been to focus on cleaning up from breach aftermaths and scripting customer service and media responses to consumers and reporters alike. Meanwhile, the criminal elements focus on identifying and exploiting additional weaknesses that range from compromising PCI compliant merchants to accessing authorization systems to increase the value of a payment card. This white paper will examine best practices in several areas of ATM processing and computer security that any financial institution or service provider can use as a starting point to secure its processing infrastructure against the latest internal and cyber attacks. Make Every Decision Count TM

2 »»Encryption to Authorization (and back again) Financial institutions and service providers focus on providing their constituents with the most innovative services at competitive prices. Criminals, on the other hand, expend tremendous amounts of resources on attacking the soft spots in the financial services value chain. The financial services industry views fraud as a nuisance and criminals view fraud as a line of business. As criminals become more successful in their attacks, they reinvest in identifying new attacks. Each time the financial services community responds with a counter-measure, the criminals apply another twist to circumvent the change. One of the most difficult positions to be in is the defender of a system. As defenders we have difficulty identifying the actual threat scenarios criminals will mount. A common example of this is the Maginot Line problem. The French built a wall along the Maginot Line which blocked Germany s attack route to France in World War I. The well constructed bunkers made France feel safer since Germany won t be able to attack us there again. In World War II, when the Germans came back they left a decoy force at the Maginot Line and attacked into Belgium and then down through a less fortified part of the French border. This situation is similar to the mindset that a firewall and an intrusion prevention system (IPS) are all one needs to stop marauding cyber criminals. That might have worked twenty years ago, but criminals have moved way beyond this point. Keeping an open and flexible awareness will allow you to identify (and anticipate) new risks as they come up. Looking at your systems in a holistic fashion will minimize vulnerabilities and therefore move criminals elsewhere to lower hanging fruit. If every organization is able to do this effectively, we might move the criminals into another line of business. Fraud demands a heightened awareness of the problem and a constant focus on hardening the soft spots. This starts with a complete review of your payment processing infrastructure to understand where card and PIN data is touched, processed and stored. Once you get started, you will find many more soft spots than you expected. Security is a journey not a destination. Every single step in a systematic process can have exploitable weaknesses. It is very important to know how your organization s systems operate, who has access to them and how they access them. One of the requirements of the PCI Data Security Standard (PCI DSS) is that transaction acquirers (merchants, financial institutions or other ATM deployers) must not improperly store detailed card (Track 1 and 2) data after authorization. Distressingly, 95% of brick-and-mortar merchants surveyed in a recent study are running non-compliant software and are storing track data after authorization. Online merchants aren t doing much better 60% of them are improperly storing card validation codes on the back of a card that aims to provide one extra layer of security ATM Marketplace ; Bickers, James 09/16/08 *including Top Ten Data Compromise sources used in Fig Fair Isaac Corporation. All rights reserved. page 2

3 »»Top Ten Data Compromise Methods Figure 1: Compromise sources & Preventative measures Compromise Source SQL Injection Trojans/Backdoor Attacks Remote Access Perimeter Security Weak Passwords Remote Exploitation Internal Attacks Physical Security Wireless Intrusion Fair Isaac Recommended Preventative Measures Use secure application coding practices. Implement application firewalls. Application testing should include security tests. Limit the number of allowable characters in a data entry field to the actual size of the field in the database table. All data entry fields should be tested and verified to only allow the maximum field length of characters in the database field. Prohibit any stored procedure that allows in-bound calls to the operating system. Deploy anti-virus software on servers. White list executable files on servers and validate files with a hash. Monitor for unusual network activity and data transmissions to unknown hosts. Secure session tokens. Install secure internet access points. IP address profiling to prevent unauthorized access. Use multi-factor authentication for employees, business partners and customers. Monitor and maintain firewalls. Maintain redundant IPS and monitor their activity. Certify every IPS and firewall change, after implementation including regression testing to verify prior rules are correct and functioning. Segment production networks with firewalls and router access control list (ACL). Lock down IP addresses for internal and external hosts. Monitor for unusual file transmission patterns. Convert to longer passwords and require variety of characters. Force passwords changes every 90 days. Change default User IDs and passwords. Audit/eliminate User IDs that are no longer required. Monitor and segment Hardware Security Modules (HSM) with router access control list (ACL). Segment HSM duties by application. Disable unnecessary HSM commands. Limit in-bound and out-bound IP addresses from production networks. Verify business reasons for each employee s system access and remove it when no longer necessary. Log and monitor employee use of applications to identify unusual system access. Use groups to give access to applications rather than granting specific access to an individual s User ID. Educate employees on data security and storage to reduce breaches from carelessness. Get employees involved as your first line of defense. Perform periodic criminal background and financial checks on employees during their employment. Combine responsibility for physical and computer security. Eliminate WEP protocol from any wireless access points. Segment wireless networks from production networks. Monitor network activity on wireless networks Fair Isaac Corporation. All rights reserved. page 3

4 »»PIN Security and Key Management for Acquirers Use caution in selecting an Encryption and Service Organization (ESO) for any of the following services: 1. Loading software into an ATM or terminal that accepts cards 2. Loading or injecting encrypting keys into an ATM or terminal/pin pads 2 3. Providing help-desk support that includes re-programming of ATM/terminal software Don t use the same encryption key for both PIN and key encryption. Ensure that agreements with ESOs clearly state the required standards of operation. Utilize separate keys for test and production systems. This limits the magnitude of exposure in case any key is compromised. Require ESOs to be registered by the acquirer as agents with the payments network(s) that your organization participates in. Verify registration for any ESO before you engage in a contractual relationship. Securely manage all keys used for the protection of PIN data during all key life cycle stages, from creation of the key to its eventual destruction. ATM, Point-of-sale (POS) PIN entry devices (PED), Encrypting PIN Pad (EPP) and Hardware Security Module (HSM) must be securely loaded with encryption keys upon initialization. 3 Never store clear text PINS or encrypted PINS (PIN blocks). Never store clear text keys. Log every organization and all individuals who have a copy of your key encryption keys (KEK) to ensure that everyone is held accountable for the highest degree of security. Require ESOs to be PCI PIN and ANSI TG-3 certified upon initiation and then on a periodic basis no less than every other year. Only TDES and unique keys should be generated and injected into an ATM environment. Insist on dual control and a separate key for each function loaded and maintained.»»atm Security Best Practices All PIN encryption activity should take place on an Encrypting PIN Pad (EPP) or PIN Encryption Device (PED) to prevent the compromise of a PIN in the clear at a terminal. ATM PIN encryption should be triple DES and PC DSS compliant. PIN Blocks should never be stored in ATM log files. Personal Account Numbers (PAN) should be truncated and protected in ATM logs. Secure remote access controls must be established for all ATMs. Anti virus and Malware detection systems should be installed, updated and tested frequently. Insist upon a vendor s written results of each test. Segment ATM network traffic from other network activity. ATM vendor supplied default passwords must be re-set with unique passwords. Make sure that core ATM processing applications do not store exploitable information like magnetic stripe data, PANs or PIN blocks. Core processing applications should be PCI DSS and in some even cases PA-DSS compliant Definition appears on ATMIA ESO Registration Clearinghouse page of 3. VISA PIN Security and Key management Best Practices for Debit Issuers with ATMs; web seminar; September Fair Isaac Corporation. All rights reserved. page 4

5 »»Issuer Security Best Practices Use the PCI PIN security requirements as a best practice for issuer key management. Validate the Card Verification Values (CVV) or Card Verification Code (CVC) and PIN Verification Key (PVK) for all ATM transactions, including debit cards that only initiate PIN transactions (ATM only cards). Consult with your internal risk manager and then adjust daily limits if appropriate for POS purchases, cash withdrawals, cash-back and quasi-cash transactions. Monitor non-cash transactions (balance inquiries and denials) to detect phishing attempts. Review Hardware Security Module (HSM) activity for automated voice response systems (AVR) and branches to detect unusual activity such as brute force decryption processes. Use a real-time neural net fraud monitoring system to ensure adequate fraud monitoring for all debit cards issued by your organization. Use account hotlists to monitor cards that have been reported as compromised. This enables the issuer to deny risky transactions at authorization. Review processes for securing and maintaining branch PIN pads. Review the process for cardholder PIN changes. It is important to know who has access to such changes. Manage PIN offset tables securely. Regularly review access records and monitoring practices. Double-length PIN verification keys (PVK) are recommended. Payment Application-Data Security Standard or PA-DSS should be required for all vendorsupplied or internally developed payment applications. This includes card authorization and card management systems. All card issuers, acquirers and card processors must comply with the PCI DSS Standard. The method and frequency of the audit depends on the number of transactions processed by the organization on an annual basis. See PCI Standard for details.»»hardware Security Modules Best Practices A Hardware Security Module or HSM is installed and used to protect encrypted data like critical keys. Critical keys should always be stored using an HSM. These are also sometimes known as Tamper Resistant Hardware Security Modules (TRHSMs). Every HSM should only be accessed via an access control list (ACL) on a router to limit access. All inbound and outbound traffic should be logged and monitored. The router should accurately log and record every IP address and critical data that travelled through the HSM. All addresses should be blocked from contacting the HSM, except specific IP addresses authorized to communicate with the HSM. Each PIN, CVV, and CVV2 must be encrypted via HSM. Segregation of functionality is very important. Multiple HSMs should be used for critical functions like On Us PIN validation and AVR/VRU PIN validation. These require two separate HSMs to be secure. An automated voice response system (AVR) should have its own separate HSM. PIN encryption via AVR must be secure. Disable HSM commands that are not used by your organization to avoid potential attacks and misuse. File integrity security monitoring is essential and required as part of PCI compliance. This includes database access, user access and third party vendor services. Note: Check with your organization s vendor as to how your HSM is being used Fair Isaac Corporation. All rights reserved. page 5

6 Figure 2: Example of stronger security measures for various access points SECURING ACCESS POINTS ATM IPS SECURITY ZONE CORPORATE ZONE IPS HSM Router Secure Network ATM HSM Log Monitoring IPS Employee ATM Processing Server»»Intrusion Monitoring Intrusion detection systems (IDS) detect potential security breaches within a system and send alerts. During an attack, the IDS will also log pertinent information and signal an alarm. An intrusion prevention system (IPS) is a network security device that monitors network traffic activities for malicious or unwanted behavior and can react, in real-time, to block or prevent those activities. Network-based IPS, for example, will operate in-line to monitor all network traffic for malicious code or attacks. When an attack is detected, it can drop the offending packets while still allowing all other traffic to pass. An IPS is an evolution of an IDS and should be considered a replacement for IDS since an IPS not only detects unusual network activity, it can also prevent it. Criminals are constantly pinging networks and hosts waiting for moments of vulnerability to attack. The vulnerabilities come about during application and infrastructure upgrades and during merger or migration activities. It is critical to have redundant IPS hardware so that when an IPS fails, your network is not open to attack Fair Isaac Corporation. All rights reserved. page 6

7 »»Intrusion Prevention Systems Best Practices Make sure that your organization maintains an intrusion prevention system (IPS) that monitors network traffic. An IPS is any device (hardware or software) that has the ability to detect AND take actions to automatically block various attacks based on a set of rules established by a network administrator. An IPS can be monitored and maintained by a third-party vendor. Select a third-party vendor very carefully by verifying all references. Contractually require your IPS vendor to create and implement a crisis incident procedure that is specific to your organization. It is important to do this as soon as your business relationship is formalized. Identify members of your team who will be responsible for handling escalation relating to the IDS/IPS. It is critical to re-set all system default passwords on all newly installed IPS. Third party installed systems may still have default passwords. Frequently, one password is used over and over throughout one system leaving the entire organization exposed to intrusion risk. Suggestion: Vendor contracts should require the third party vendor to re-set all passwords after installation of the IDS/IPS. Test the IDS/IPS to ensure that every facet is working. It is very important that intrusion notifications are always monitored and tested on a monthly basis to ensure that they are functional. An IPS should be installed on BOTH sides of a perimeter firewall. Implementing redundant IPS is critical if one goes down, your network will still be protected. Intrusion alerts should be automatically sent to people on a contact list with an escalation procedure to ensure that someone is always available to react to any suspected intrusion. It is also important to decide the type of communication required based on the severity of an attack, such as or direct voice contact. Some severe events may require higher levels of escalation sooner in the process. IPS passwords should be changed every 90 days and more often if third-party vendors have recently worked on any internal controls. Password security should include a minimum length of 8 various characters, letters and numbers or symbols. Never disable IPS. A disable action should trigger an immediate alert. Regularly perform independent intrusion testing weekly to ensure that all IPS are working properly. It is important to stress that these tests be random and unannounced particularly if a third-party vendor is providing the IPS monitoring service. Network penetration testing should regularly be performed by targeting the IP addresses inside of the organization from external IP addresses.»»firewall Security Port 80: The port that the server listens to or expects to receive from a web client can also be a vulnerable area that requires security monitoring to prevent unauthorized entry or export of data. Security monitoring reports should be collected on each port and IP address. The number of incidents by port should be monitored for an increase in inbound or outbound activity each day. Compare historical port activity to current activity to identify unusual patterns of activity. Study recently opened or closed ports to see if someone is trying to stealth or hide an intrusion or data transfer Fair Isaac Corporation. All rights reserved. page 7

8 A regular scan of server logs for common hacker character usage can reveal an early warning for intrusions. #, {}, ^, and [] requests may show up in logs if an attacker is echoing some source code into a file of C program. Once a file is created and interpreted, the attacker could bind a shell to a port providing easy access. 4 Employees who need to browse the internet should be required to log into a secure internet access point like Citrix MetaFrame Secure Access Manager. This infrastructure software provides secure, single-point access over the Internet to virtually any internal and external information resources, including applications, data sources, documents, Web content and services. Improperly configured systems: Just who is to blame for those improperly configured systems? Sixty-three percent of the time it s a third party a POS developer, an integrator or a local IT firm. An alarming finding is that many local IT integrators will use the same passwords for all of their clients that run a particular piece of software. So the attacker knows, If I can get into one of them, I can get into all of them. It is entirely possible that old servers and applications are still using default passwords at your organization today. 5 Keep in mind that if you are blocking foreign (non-us) IP addresses, US-based proxy servers could be used to disguise the originating address.»»crisis Management Create a data intrusion crisis plan. Take into consideration severity levels that will drive reaction and workforce requirements. A periodic intrusion procedure test similar to a fire drill should be carried out without warning several times a year to gauge the effectiveness of the plan. This plan should include an up-to-date Incident Response Plan from all of your PCI providers and kept online if possible. Contact names and numbers should be verified at least annually. Don t neglect the aspects of customer care. Every solid intrusion crisis plan will involve customer service representative scripts and media templates which can easily be customized to fit a particular event. Immediately disconnect all infected servers and PCs. Do not reboot to prevent a loss of critical forensic evidence. Block all servers from outbound activities. Reintroduce safe IP addresses slowly based upon the critical needs of your organization. Never remove Malware, worms or any other evidence of an intrusion prior to a thorough forensic examination. It is acceptable to disable these to prevent additional damages. Forensic examinations should only be provided by vendors who are approved by the card associations and/or debit networks. In most cases, these vendors mirror the Qualified Security Assessors (QSA s) noted on the PCI Security Standards Councils website under QSA s Always alert your partner payment companies in the wake of any data breach. Not on us foreign cards and any other miscellaneous information should be disseminated quickly to protect external organizations from as much loss as possible. Blocking the IP address attributed to Malware is not enough to prevent its spread. The Malware must be disabled by qualified professionals. Eventual removal of all Malware should be performed as soon as a complete forensics examination has been completed Reference appears 5. ATM Marketplace Bickers, James 09/16/ Fair Isaac Corporation. All rights reserved. page 8

9 A wise person once said, The time to fix the roof is while the sun is shining. This simple phrase tells us that preparedness is simply the wise anticipation of future challenges. The tools and information provided within this publication echo the same sentiment. So prepare, plan and implement now to reduce your organization s exposure to data security weaknesses before a crisis develops. Please consider that there are two things that one cannot retrieve in the wake of a security breach: Your data and your reputation.»»helpful Resources ATM Industry Association Fair Isaac s Card Alert Service Network Information Security & Technology News PCI Knowledge Base PCI Security Standards Council ThoughtKey, Inc Visa Cardholder Information Security Program Special thanks to our key industry partners including ThoughtKey, Inc for providing guidance and content for this publication Fair Isaac Corporation. All rights reserved. page 9

10 about Fair Isaac Fair Isaac Corporation (NYSE:FIC) is the leader in Decision Management, transforming business by making every decision count. We use predictive analytics to help businesses automate, improve and connect decisions across organizational silos and customer lifecycles. Clients in 80 countries work with Fair Isaac to increase customer loyalty and profitability, cut fraud losses, manage credit risk, meet regulatory and competitive demands, and rapidly build market share. Most leading banks and credit card issuers rely on Fair Isaac solutions, as do insurers, retailers, healthcare organizations and other companies. Through the Web site, consumers use the company s FICO scores, the standard measure of credit risk, to manage their financial health. Fair Isaac provides leading fraud protection systems to the financial services industry, including the Fair Isaac Falcon Fraud Manager system used to protect 2 out of 3 cards and the Fair Isaac Card Alert network that protects 11,000 ATMs for thousands of US banks. Learn more at Fair Isaac, Falcon, FICO, myfico, and Make every decision count are trademarks or registered trademarks of Fair Isaac Corporation. Other product and company names herein may be trademarks or registered trademarks of their respective owners Fair Isaac Corporation. All rights reserved. 2530WP 01/09 PDF For more information US toll-free International toll-free web FIC info@fairisaac.com

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