Reminder: PCI DSS 2.0 is asking for Vulnerability Risk Rating

You know the story; if your systems/applications store transmit or process credit card data, you must meet PCI data security standards.

Since Q4 2010 all PCI shops are aware that their Cardholder Data Environments need a risk ranking procedure.

But, What is it and how does it change current practices?

PCI DSS Requirement 6.2 says "Establish a process to identify and assign a risk ranking to newly discovered security vulnerabilities"

And a new recommendation may certainly effect how you manage risk…

This recommendation (which will be a requirement by June 30, 2012) can be classified as Risk Management 101, and yet it may change several cornerstones of your processes.

Here is what 6.2.a is asking for:

1- Check your processes for identifying new security vulnerabilities (make sure you have one)

2- Assign risk ranking to identified vulnerabilities

6.2.b Continues with the  recommendation that you use and outside source for this risk ranking process.

This translates into a solid scoring system for risk. Enterprise options to collect data for a scoring system are:

1- Vendor Security Alerts

2- Vulnerability Management Advisories (Usually security scanner, and IDS/IPS shops)

3- Vulnerability Intelligence Advisories (e.g. Secunia, iDefense, Deepsight)

4- Internal risk scoring systems (yes we all love academic endeavors - that is why PCI SSC asks for "outside" source : )

Either way (using one of the options, using some/all of them) PCI recommendation 6.2 will push risk management practices in the right direction and make risk prioritization a priority...Eventually PCI shops will (6/30/2012) integrate risk management with vulnerability scanning devices, security alerts, advisories and patch management solutions to audit and validate PCI 6.2 with risk rankings.

Here are a few good links:

Common Vulnerability Scoring System (CVSS-SIG) - http://www.first.org/cvss/

Common Vulnerabilities and Exposures -CVE - http://cve.mitre.org/

National Vulnerability Database - NVD - http://nvd.nist.gov/

Secunia - http://secunia.com/advisories/

Verisign iDefense - http://www.verisigninc.com/en_US/products-and-services/network-intelligence-availability/idefense/index.xhtml

TippingPoint Zero Day Initiative ZDI - http://www.zerodayinitiative.com/advisories/upcoming/

Symanted DeepSight Alert Services - https://tms.symantec.com/

Cisco Security IntelliShield Alert Manager Service -http://www.cisco.com/en/US/products/ps6834/serv_group_home.html

IBM ISS XForce - http://www-935.ibm.com/services/us/iss/xforce/

VUPEN - http://www.vupen.com/english/research.php

McAfee Threat Intelligence Services (MTIS) - http://www.mcafee.com/us/mcafee-labs/technology/threat-intelligence-services.aspx

Bugtraq -http://seclists.org/bugtraq/

Full Disclosure - http://seclists.org/fulldisclosure/

p.s. I have written this article for RSA Conference 

PCI Reporting Requirements for Merchants

Facts:
- Check your PCI Merchant levels and validation requirements from the following post: http://security.24kasim.org/2009/06/pci-levels-for-merchants-2009.html

Amex

Level 1-
If compliant, Attestation of Compliance –AOC- (recommended) or exec summary of onsite security assessment report (QSA/internal) annually and quarterly network scan
If not compliant, AOC (recommended) or exec summary of onsite security assessment report and Remediation Plan annually and quarterly network scan and Remediation Plan

Level 2-
Quarterly Network Scans (and Remediation Plan if not compliant)
AOC (Recommended) or Executive Summary
In EU: PCI SAQ

Level 3- Level 4 -
No reporting Required for Amex at L3 and L4

Discover

Level 1 –
Network Merchants:
If compliant Appendix D of PCI DSS requirements and Security Assessment Procedures v1.2 - Attestation of Compliance –AOC-
If not fully compliant must also complete the Action Plan for Nono-Compliant Section of the AOC
Acquired Merchants:
Consult acquirer – Acquirer must submit the Discover Acquirer Network Portfolio Compliance Status Submission Form to Discover twice a year

Level 2:
Network Merchants:
If compliant Attestation of Compliance –AOC- from applicable SAQ
If not fully compliant must also complete the Action Plan for Non-Compliant Section of the AOC
Acquired Merchants:
Consult acquirer – Acquirer must submit the Discover Acquirer Network Portfolio Compliance Status Submission Form to Discover twice a year

Level 3:
Network Merchants:
If compliant Attestation of Compliance –AOC- from applicable SAQ
If not fully compliant must also complete the Action Plan for Non-Compliant Section of the AOC
Acquired Merchants:
Consult acquirer – Acquirer must submit the Discover Acquirer Network Portfolio Compliance Status Submission Form to Discover twice a year

Level 4:
Network Merchants
If compliant Attestation of Compliance –AOC- from applicable SAQ maybe required
If not fully compliant must also complete the Action Plan for Non-Compliant Section of the AOC
Acquired Merchants:
Consult acquirer – Acquirer must submit the Discover Acquirer Network Portfolio Compliance Status Submission Form or Level 4 Merchant Action Plan to Discover twice a year

JCB

JCB has no reporting requirements at this time

MasterCard

Level 1-
Acquirers register compliant merchants in the MasterCard Registration Program (MRP)
Acquirers report status of all merchants quarterly

Level 2-
Acquirers annually register compliant merchants in the MasterCard Registration Program (MRP)
Acquirers report status of all merchants quarterly

Level 3 –
Acquirers register compliant merchants in the MasterCard Registration Program (MRP)
Acquirers report status of all merchants quarterly

Level 4-
No requirements

Visa Inc

Level 1-
At least a twice a year , a statement of merchant compliance / non-compliance
Annual AOC form
Upon request a copy of Report on Compliance (ROC)

Level 2-
At least a twice a year , a statement of merchant compliance / non-compliance
Annual AOC form
Upon request a copy of Report on Compliance (ROC)

Level 3-
At least a twice a year , a statement of merchant compliance / non-compliance

Level 4-
Set by the acquirer

Visa Europe
Level 1-
Annual statement of merchant compliance
For merchants in progress, quarterly update until compliance confirmed
Upon request a copy of Report on Compliance (ROC) including indication of scan completion

Level 2-
Annual Statement of compliance / non-compliance
For merchants in progress, quarterly update until compliance confirmed

Level 3-
Quarterly statement of compliance / non-compliance for merchants above 20000 transactions/year. Annual statement for merchant below 20000 transactions/year

Level 4:
Annual statement of compliance / non-compliance for merchants processing < 1 million Visa transactions/year.



Service Providers are not merchants so if you are providing card processing for 3rd parties (Payment Service Provider) PSP or if you are a TPP (Third Party Processor) PCI levels, validation and reporting requirements are different. The charts above are for merchants only.

PCI Levels and Validation Requirements for Merchants 2009

This topic is always in the air so here are the official numbers for 2009 from PCI Security Standards Council the official governing body on the PCI requirements for merchants:

Facts:

- Payment Brands determine Merchant PCI levels. Payment Brands are Visa, Mastercard, Discover , Amex etc. They do have the last word on this topic

- Transaction volume is determined by Acquirer

- Transaction volume is aggregate number of transactions (chain stores do count if cards are processed centrally)

Amex

Level 1- Over 2.5 Million Amex card transactions/year, or any merchant who is Level 1 according to another Payment Brand

Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans

Level 2- 50000-2.5Million Amex transactions/year, or any merchant who is Level 2 according to another Payment Brand

Action: EU only annual SAQ, Quarterly ASV scans

Level 3- Less than 50000 AMEX transactions/year

Action Quarterly ASV scans (recommended) , EU only SQA (recommended)

Level 4- N/A

Action: None

Discover

Level 1 - Over 6 Million Discover card transactions/year, anybody who Discover thinks that they level 1 (discretionary) or any merchant who is validated/reported as Level-1 to another Payment Brand

Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans

Level 2- 1-6 Million Discover transactions/year, or any merchant who is validated/reported as Level-2 to another Payment Brand

Action: Annual SAQ, Quarterly ASV scans

Level 3- 20000-1 Million Discover transactions/year, or any merchant who is validated/reported as Level-3 to another Payment Brand

Action: Annual SAQ, Quarterly ASV

Level 4- Everybody else with Discover card processing

Action: Determined by Acquirer, Annual SAQ, Quarterly ASV recommended

JCB

Level 1 - Over 1 Million JCB card transactions/year or anybody who is compromised

Action: Annual Onsite QSA audit, Quarterly ASV scans

Level 2- Less than 1 Million JCB transactions/year

Action: Annual SAQ, Quarterly ASV scans

Level 3- N/A

Action: none

Level 4- N/A

Action: None

MasterCard

Level 1- Over 6 Million Mastercard card transactions/year, or any merchant who is Level 1 according to another Payment Brand or anybody who is compromised

Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans

Level 2- 1-6 Million Mastercard transactions/year, or any merchant who is validated/reported as Level-2 to another Payment Brand

Action: Annual SAQ, Quarterly ASV scans

Level 3- 20000-1 Million Mastercard “e-commerce” transactions/year, or any merchant who is validated/reported as Level-3 to another Payment Brand

Action: Annual SAQ, Quarterly ASV

Level 4- All other Mastercard merchants

Action: Compliance validation is at discretion of acquirer: Annual SAQ, Quarterly ASV recommended

Visa Inc

Level 1- Over 6 Million Visa card transactions/year (all transactions not just e-commerce), or any global merchant who is identified as Level 1 by Visa by any Visa Region

Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans and attestation of compliance form

Level 2- 1 Million to 6 Million Visa card transactions/year (all transactions not just e-commerce),

Action: Annual SAQ, Quarterly ASV scans and attestation of compliance form

Level 3- 20000-1 Million Visa “e-commerce” transactions/year

Action: Action: Annual SAQ (In Canada SAQs require QSA reviews), Quarterly ASV

Level 4- Merchants processing less than 20000 e-commerce transactions/year or merchants processing up to 1M any channel Visa transactions/year

Action: Compliance validation is at discretion of acquirer: Annual SAQ, Quarterly ASV recommended

Visa Europe

Level 1- Over 6 Million Visa card transactions/year (all transactions not just e-commerce), or compromised merchants

Action: Annual Onsite QSA or Internal Audit signed by Merchant Co, Quarterly ASV scans and attestation of compliance form

Level 2- 1 Million to 6 Million Visa card transactions/year (all transactions not just e-commerce),

Action: Annual SAQ, Quarterly ASV scans and attestation of compliance form

Level 3- 1 (one) to 1 Million Visa “e-commerce” transactions/year

Action: Annual SAQ, Quarterly ASV or use PCI DSS certified processor for all transactions

Level 4- Merchants processing up to 1 Million any channel Visa transactions/year

Action: Compliance validation is at discretion of acquirer: Annual SAQ, Quarterly ASV recommended

Of course all parties who process store or transmit credit cards must follow PCI requirements (PCI-DSS) regardless of their levels.

I will cover reporting requirements for merchants in another post.