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I know this is going to sound kind of sad, but I am really excited to see what’s going to happen with some of the latest PCI breaches and the organizatio’s response. In the two the biggest, latest ones we see both Hannaford and Heartland stating their case that they were both PCI compliant. To the average person, the initial response is going to be something like, “Then the PCI DSS sucks!”. However, a recent statement from a VISA exec was more along the lines of “We have yet to see a company that was breached that was compliant.” So how do we judge this wrestling match?

First and foremost, we need to make a clear distinction about what it means to be PCI compliant. The position being taken by the the organizations above needs clarified. What they mean is that they had successfully completed their compliance validation activities. More specifically, that means they had their audit performed and submitted it along with the ASV scans. They met their due diligence obligation.

But now we need to reconcile that with the execs position. What he was talking about is more akin to PCI Safe Harbor. That states a company is ‘safe’ if they are fully compliant to the PCI DSS at the time of the breach and can be demonstrated during an audit with forensics. That, my friend, ai’t easy. Compliance is something you will ultimately have to defend and is not the plaque or certificate on the wall for you did once a year.

So now we need to actually do some sort of prognostication here so you get my point. I do’t have all the details for either breach, so I will make some assumptions. Let’s assume both of them were breached due to malware on a system. I’ll also assume they had anti-malware in place. What is’t an assumption is if it’s possible to bypass malware. So I am going to assume is it did get bypassed. I am not sure if we’ll know how the malware got there. Did that portion of PCI fail? Not at all. It’s a good requirement and they did meet it. But PCI has many layers to it as all security programs should.

If I had to guess what will the final outcome is, it will be something like this. From what we know the big problem is that the data was breached i.e. it left their network. So just how did the data get into the hands of the the evildoers? I think that’s the real question. Exactly what kind of firewall rules were in place that allowed the malware sniffers in place to send the traffic out of their network? Did the processor or the registers have direct access to the internet? I sure as heck hope not. If the attackers had some live connection into those systems, that’s one thing. But I would suspect there is a lack of good egress filtering and not that the malware did some crazy cool method to bounce traffic out of their network. This kind of excessive egress would likely be caused by a lack of good process to reign in the poor rules adopted through “business justification”. Personally, I think the business card trumps way too often as I have seen time and time again at clients.

So who is to blame here? I think an easy, but not necessarily correct, choice is the assessor. An auditor’s job is to assure formalized, good processes and perform some testing as well. It may not be possible to audit every rule of every firewall. Even so, the auditor has to be pretty strong to push back when “business justification” has been established. It means possible rumbling with their client and their bank. But yes, the auditor may not have been thorough and some rubber stamping occurred here.

Well, only time will tell if I should quit security and become a psychic. Speaking of, my money is on the VISA exec to win the match. Even if I am wrong, there is some lessons learned here. In reality, there needs to be a strong, collaborative relationship between the auditor and the organization to both agree on a defensible position in gray or soft areas of the PCI DSS. I often say you need to imagine standing at the podium and feeling confident as you describe that position to reporters and the world. And never forget, compliance does not equal security. Business justification is not a loophole. Or if it is, a lot more can slip through that hole like malware and fines.