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AUDIT & COMPLIANCE

TR-39 Audit

Essentials

A TR-39 (PIN Security and Key Management) and/or VISA PIN Audit provides a certified report on an organization’s controls around PIN-based transactions; including encryption, key management, and key protection. This can include both symmetric and asymmetric encryption controls, key inventory and ceremony, inspection of datacenters, HSMs, Point of Sale (POS) devices and physical safes.

For retailers an audit is generally required as part of a contract from an Electronic Funds Transfer (EFT) or debit network for a bank; or, from a bank to a merchant retailer if they switch their own debit transactions. Generally, banks of whom drive their own ATMs or process debit card transactions are required to pass a TR-39 audit. However, Pulse requires all acquiring members to pass a TR-39 audit. Third parties such as key loading facilities may also need an audit to be performed.

Benefits

Having a Visa PIN/TR-39 audit performed validates that your policies and procedures surround PIN encryption and key management are compliant with Visa PIN and/or TR-39 standards. During the audit, non-compliant areas will be identified so corrective actions can be taken to remediate their issues. In the end, this helps to safeguard debit and ATM PINs that traverse your system to protect your customer’s finances and privacy. Finally, failing an audit could impact the organization’s ability process debit card transactions.

Expertise

SecureState’s Certified TR-39 Auditors (CTGA) are qualified to perform audits for PULSE, STAR and NYCE network members. Our auditors are experts in understanding both the technical aspects, as well as the business aspects of your organization; with backgrounds in cryptography and transaction security. Furthermore, SecureState not only has experience in auditing complex debit card environments, but they have also helped small to large retailers and financial institutions develop and implement compliant debit card systems as well.

Did You Know?

  • Visa PIN and TR-39 are two distinct standards which contain almost identical controls
  • It is cheaper to perform a Visa PIN and TR-39 audit at the same time instead of performing the audits separately
  • TR-39 audits are normally performed every two years
  • Visa PIN audits are performed annually
  • Weak policies and procedures are the most common reason companies fail Visa PIN/TR-39 audits. The second most common reason for failing the audit is poor key administrators or key custodians who do not follow the policies and procedures
  • SecureState can also help you create PIN management policies and procedures which are Visa PIN and TR-39 compliant
  • TR-39 was previously known as TG-3

Our Approach and Methodology

SecureState’s approach to a TR-39/VISA PIN Audit includes the following steps:

  • Review documented procedures for key management
  • Audit key loading facilities
  • Analyze data related to encryption techniques

What Makes Us Different

SecureState

  • Can handle credit card, debit card and ATM audit needs
  • Provides comprehensive on-demand security expertise during the engagement and throughout the year
  • Specializes in security assessments and provides a holistic approach to security beyond the PIN transaction
  • Has experience responding to encryption key compromises
  • Has helped design and implement TR-39 compliant debit transaction environments
  • Has extensive knowledge of encryption and COMSEC solutions based on SecureState’s experience in the commercial and government sector

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