|
Most merchants and application vendors seriously underestimate both the scope and the force of the Payment Applications Data Security Standard (PA DSS). If so, it’s only because they haven’t read the standard or don’t immediately grasp what’s involved. Essentially, this standard could cause merchants of all sizes in all industries to have to switch payment application vendors, argues GuestView Columnist David Taylor. Read more. |
October 3rd, 2008 at 3:05 pm
David, you state: “What are the compensating controls for PA DSS? There are none…”
Well, yes and no. While there are no compensating controls for PA-DSS, there is technology to take POS payment applications out-of-scope of PCI and thus act as a compensating control. Take for instance our 4Go application, it intercepts cardholder data (CHD) prior to the data entering the POS payment application and substitutes faux or fake CHD. The real CHD is relinked to the transaction when the fake CHD is used on the backend side, after it leaves the POS. In this model, the POS is completely taken out-of-scope because the POS never collects, processes, or stores CHD.
Just to clarify, 4Go only takes the POS out-of-scope; the merchant is still in PCI scope and thus all other PCI requirements apply (firewalls, merchant procedures, etc.).
October 9th, 2008 at 12:49 am
You might be able to skate by the rules by declaring the POS software “out of scope” but the fact is, if the 4Go encryption software runs on the POS system then the POS software — and any other app running on that machine — really should be audited. Otherwise, weaknesses in poorly written POS software can be exploited to give an intruder control of the machine, at which point it’s game-over, because the thieves can just grab the card data before the 4Go software can encrypt it.
October 9th, 2008 at 8:28 pm
Actually no. 4Go has both sanity checks and tamper detection built in and is included in several software layers (system level, service level, tray app level) so these exploits would be noticed and the merchant would be alerted. Also, because one of the levels is very low in the O/S, while not impossible, it would be very difficult to accomplish what you’re describing and even more difficult to go unnoticed.
Let’s face it, there is no such thing as a 100% secure system. Yes, with enough effort you might be able to compromise a 4Go protected system, as well as any other system. I would argue however, that because 4Go is specifically written to secure cardholder data in a wide variety of environments and POS applications, more thought and coding is put into the security of this product than the average PABP or PA-DSS approved application.
While you might call it skating the rules, I disagree and I would call it making PCI more affordable to the average merchant. Since you can never be 100% secure, what’s the goal of software security? To be secure enough to have the thief move on to easier prey. 4Go does this.
October 10th, 2008 at 11:06 am
Ever heard of a root kit? It lets an interloper take 100% control of the machine and is completely transparent to anything else running on that computer. Root kits are widely used by hackers. Your solution might be better than no solution, but you are mostly providing a false sense of security and in some ways that is worse. It would be better to have the POS software audited. That, too, is not a guarantee of security, but it is the technical equivalent of making sure all the doors and windows are closed and locked while your solution by itself is somewhat closer to hiding the valuables in the underwear drawer: Better than nothing, but not much.
October 10th, 2008 at 1:09 pm
Well, we’ll just have to agree to disagree. Even with using root kits it would be very difficult to circumvent 4Go — moreso than most audited applications. 4Go encrypts the information as soon as it enters and it remains encrypted from that point forward until after it leaves the merchant network. Most POS applications, compliant, audited or not, do not encrypt end-to-end — it is in the clear within the applications physical memory. It may be encrypted prior to storage, but within the RAM is is most often in plain text and could be sniffed and compromised. Most POS application do not install themselves in low levels of the O/S and most do not do any sort of process scan for what applications are loaded below or above them — it does not even need be a root kit to compromise the average compliant POS. Using your analogy, I still would argue that 4Go protected systems have stonger security measures in place out-of-the-box than most peoples window and door locks. PM me. I would love to schedule a time for you to come to our offices and do any test you want. We want skeptics to review the product. We only ask for an honest review done with an open mind.
October 10th, 2008 at 5:24 pm
Do you disagree with the facts? They are: (1) A root kit can be undetectable to software running on the same computer. (2) The 4Go product does not and cannot prevent or detect the installation of a root kit. (3) With a root kit installed, it is trivial for an attacker to read credit card data from the keyboard or serial port before the data can be encrypted.
A poorly written POS application can provide an attack vector through which a root kit can be installed. The purpose of a PA-DSS assessment is to eliminate potential attack vectors. It seems to me you are being reckless and irresponsible in declaring that your 4Go product removes the need for PA-DSS review of the POS software. Does the PCI Standards Council agree with you on that? (Even if they do, that does not make it wise — they still allow using WEP for wireless networks!) I do not even see the “4Go” product listed as a validated application.
Thanks for the invite to your offices, but I am sure my hacker talents are far lower than those who make it their business to steal credit card data. And keep in mind, the more popular your product becomes, the more likely it is those folks will design attacks for it.
October 12th, 2008 at 1:39 am
Like I said, agree to disagree. This may be the foundation for another article by a better writer than I, but if anyone thinks a PA-DSS assessment will protect an application, any application, from a root kit compromise, they will be sadly mistaken.
I never said that 4Go removes the merchant from PCI scope, only applications. Firewalls and the like still need to be in place, computers and computer access still need proper lock down processes, virus protection needs to be installed, etc. More times than not, more PCI rules will have been broken installing the components for a root kit attack than just a POS’s PA-DSS certification.
October 12th, 2008 at 8:45 pm
I never said a PA-DSS assessment will protect an application from a root kit compromise, and I never claimed you said 4Go removes the merchant from PCI scope.
I said a PA-DSS assessment will [help] eliminate potential attack vectors. If there are no attack vectors then a root kit could not be installed.
YOU said 4Go takes the POS out-of-scope [for PA-DSS], and I think your claim is just plain wrong. (I don’t know if your claim is technically correct within PCI rules but, even if it is, that’s a very bad position to take.)
A poorly written POS application can easily provide the path by which the POS system becomes compromised. Once that happens, the POS system is “owned” and the attacker can access all of the sensitive data before 4Go can touch it.
The 4Go product should not be considered (or promoted) as some sort of “magic elixir” that eliminates the need for a PA-DSS assessment.
October 13th, 2008 at 2:29 pm
This will be my last posting on this thread.
Yes, root kits can potentially allow a system to be “owned,” per your word. I still firmly believe that a 4Go protected system has more solid security protections than most PA-DSS audited and certified applications. Yes, since 4Go is a “generic” application designed to protect virtually any POS application running on the PC, there is an unknown vector factor involved. But even if the POS applications has a hot key configured to open a command prompt with full administration access, getting a root kit on will not go unnoticed. Most QSA’s doing PA-DSS audits would not catch this hot key command prompt “feature” in an application so I don’t have the same confidence in PA-DSS certifications than you do. PA-DSS somewhat assures that an application is compliant, not necessarily secure and there is definitely no guarantee of either.
Obviously I’m not going to sway your opinion nor will you mine. Thanks for the voicing your opinion here as I don’t have a problem showing both sides of an argument, especially security related since opinions can vary so greatly. We’ll just have to let the viewers, community, and eventually time decide.
–Steve