Pen tested ... Compliant???

[Craig Wright <Craig.Wright () bdo com au>]

"This is untrue. I've seen many *compliant* systems be compromised by
exploits that targeted unknown vulnerabilities."

Well you have seen systems perceived to be compliant taken down, this does not make it compliant. Passing an audit is 
not being compliant. What other controls are in place? Having a patched system does not mean it is compliant.

Compliance and the perception thereof as well as the same for security are different. Yes it would be great if they are 
the same, but they are not. The same goes for metrics.

Compliance IS defined. It is a term of legal art. Compliance means that you meet or Exceed ALL requirements that are 
imposed. 80% there is not compliant. Few systems are compliant. Many non-compliant systems pass audit. In my role as an 
audit manager I suffer extreme pressure to pass non-compliant systems. Many cave into this pressure, esp. when the 
chance of being discovered is low.

"Craig, can you define the difference between a Penetration Test, Vulnerability Assessment, and an Audit for me?"
Please read my papers, Buy a book, or similar. I have detailed this in several published papers and have a taxonomy in 
the SANS RR.
http://www.sans.org/reading_room/whitepapers/auditing/1801.php

This is not based on opinion, it is based on quantification and scientific testing. There has also been subsequent 
research that has validated my view. I say things when they have been tested and I can state them with data that is 
supported with a minimum 99% CI.

Regards,
Craig



Craig Wright
Manager, Risk Advisory Services

Direct : +61 2 9286 5497
Craig.Wright () bdo com au
+61 417 683 914

BDO Kendalls (NSW-VIC) Pty. Ltd.
Level 19, 2 Market Street Sydney NSW 2000
GPO BOX 2551 Sydney NSW 2001
Fax +61 2 9993 9497
http://www.bdo.com.au/

The information in this email and any attachments is confidential. If you are not the named addressee you must not 
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Any views expressed in this message are those of the individual sender and not necessarily endorsed by BDO Kendalls. 
You may not rely on this message as advice unless subsequently confirmed by fax or letter signed by a Partner or 
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viruses and other defects. BDO Kendalls does not accept liability for any loss or damage however caused which may 
result from this communication or any files attached. A full version of the BDO Kendalls disclaimer, and our Privacy 
statement, can be found on the BDO Kendalls website at http://www.bdo.com.au/ or by emailing mailto:administrator () 
bdo com au.

BDO Kendalls is a national association of separate partnerships and entities. Liability limited by a scheme approved 
under Professional Standards Legislation.
-----Original Message-----

From: listbounce () securityfocus com [mailto:listbounce () securityfocus com] On Behalf Of Adriel Desautels
Sent: Friday, 6 June 2008 1:30 AM
To: Craig Wright
Cc: Erin Carroll; 'Scott Race'; security-basics () securityfocus com
Subject: Re: How does a customer get PCI audited?

My comments are embedded.

> Hi Erin,
> I would disagree. I would split off "compliance" and "perception of
> compliance". Passing an audit is evidence that a system could be
> compliant. A compromise of a system using a know vulnerability is
> strong evidence that it is not compliant.

I do not think that compliance and perception of compliance should be
any different. I think that the act of being compliant needs to be
properly defined.

> A system that is breached due to a complex password and secured key
> that was "guessed" is possible, though unlikely. This would one of the
> few examples of a compliant system that is also breached. Basically,
it >will be rare to find a compliant system (to any jurisdiction) that
is >easily compromised.

This is untrue. I've seen many *compliant* systems be compromised by
exploits that targeted unknown vulnerabilities.

> What I learnt completing my LLM was how few systems are complaint. How
> little knowledge there is of the law and legal frameworks already in
> place (even with politicians) and the lack of due care. An ABSOLUTE
> baseline for a compliant system that has not other effect other than
> being owned by a company would be the CISecurity.org baselines at 100%.

> The combination of technical people with no knowledge of the legal
> system, laws and processes with lawyers who can not turn on a PC is an
> issue here.

> "I would agree with Adriel that finding a worthwhile auditor is
> difficult". Actually so would I. Finding an staff with half a brain
> provides enough difficulty to want to give up on the whole idea.

> "The problems are analyzed from a primarily financial and business
risk >avoidance perspective" Here I have to disagree. I work with
financial >auditors and I am yet to meet one who understands risk and
have met >very few who have the faintest comprehension of finance. Audit
and >finance are NOT the same thing. I did finance at a masters level
and I >think audit is wacky for the most part. For the rest, there is an
> approach of try to find nothing wrong or it will upset the client.

I think that you misunderstood what was being said. The lifeblood of all
businesses is money and as such the biggest risk that any business can
face is the sudden loss of money. Acceptable risk is best defined as how
much financial damage one can accept before it becomes a problem.
Malicious hackers can create a significant amount of costly damage,
especially if the media gets wind of an incident.

> I have developed statistically based continuous audit programs for
> financial systems. These have a significantly lower cost and deliver
> more. What I get back is "Craig, we are watch dogs and not blood
> hounds. Please try not to find so much". So I use these with the
> Insolvency teams and on forensic audits, but it is a hard sell to
audit >teams. Clients seem to love it though.

> "I'm curious as to what vulnerable points you're thinking of." Pen
> Testing is by nature externally focused. Many of the biggest issues
are >in the system. Static analysis of code, business process reviews
and >system walkthroughs all add additional layers of testing.

You are incorrect Craig. Penetration Testing and Vulnerability
Assessments are not externally focused. Many of the penetration tests
that we offer (and vulnerability assessments) include business process
reviews, system reviews, policy reviews, etc. This is particularly true
if Social Engineering is a component of the Penetration Test. Everything
and anything *might* be useful when being tested the *right* way.

> Many controls are not tested using Pen testing ion any effective
> manner. Take a banking application. Pen tests look at the system from
a >software and protocol implementation aspect. They do not go into the
> business process controls. In this case I would be asking, how do I
get >the money off the system. This requires an understanding of the
> controls in the application. This is not something a pen test will
> provide.

Again you are incorrect. In fact, our team just finished an assessment
with a bank where we covered all aspects of the technology and the
processes used to protect a particular target. At the sake of being
redundant, a *good* service will cover this. Providers that don't at the
very least offer this are not doing their job.

> An attacker can do this by compromising the system and modelling the
> application functions. Or the attacker could be internal and know
them. >This takes time, it can take months or longer. The same process
can be >done in a matter of weeks with a cryptal box and business
process >approach. The pen test provides valuable information as to a
known >vulnerability, but this is where it stops.

You are generalizing too much in what you say and are saying things as
if they are fact when they are not. A Penetration Test does not only
provide valuable information about known vulnerabilities, but a good one
will also identify unknown vulnerabilities via research. To date, every
single penetration test that I have ever been involved in has identified
new/0day risks and exploited those risks.

Craig, can you define the difference between a Penetration Test,
Vulnerability Assessment, and an Audit for me?

> When there are no obvious points of access that may be exploited, a
pen >test does nothing to state a system is secure, just that it failed
to >determine the state of the system and was unable to determine if a
> system was secure or not.

What the hell are you talking about again? Penetration Tests should not,
and normally do not only search for "obvious points of access". A
penetration tester's job is to research each individual target and
identify any POSSIBLE way of entry including social engineering if
applicable. If the tester is unable to get into the system then a report
is issued that states that the system is secure and usually includes
some theoretical about risks that have a very low probability of
exploitation.

> Prof. Cohen developed the concept of protection testing over a decade
> ago. This mitigates many of the problems with a pen test methodology
> (that where noted as far back as 1977 by Distraka). The issue is that
> the tester needs more knowledge than a pen tester.

What methodology? There is no one single methodology to any sort of
testing. Methodologies vary and good methodologies are dynamic. Also, a
methodology that was developed over 1 year ago and not updated/kept
current is ineffective and mostly useless.

> Protection testing really requires a combination of technical and
> business process skills. Teams can do this, but this increases cost
and >also requires a co-ordination factor with knowledge.

I agree that prices change as services and time requirements also change.

> "what if the economics aspect were ignored"
> Not my world. We live in a world where EVERTHING is subject to
economic >constraints and interrelationships.

But what if they were ignored?

> Time for instance is a economic constraint. They only way to remove it
> is to have an instantaneous pen test. A detective control that reports
> faster than a pen test is more effective. The lengthy of the pen test
> is one factor, but also the frequency. 1 test a quarter is detection
> every 3 months at best.

Craig I can't say that I agree with most of your views on Penetration
Testing. I'd like you to define a penetration test for me to make
certain that we are on the same page. It sounds to me like you've got
penetration testing defined at a very basic level. Granted, one of the
biggest problems in this industry as a whole is that most businesses do
not properly define their offerings. How are consumers supposed to know
what is what if every business calls a car a different thing? Also,
please stop telling people things as if they are fact, when they are
opinion based on your own experience or a lack thereof.




Regards,
        Adriel T. Desautels
        Chief Technology Officer
        Netragard, LLC.
        Office : 617-934-0269
        Mobile : 617-633-3821
        http://www.linkedin.com/pub/1/118/a45

        Join the Netragard, LLC. Linked In Group:
        http://www.linkedin.com/e/gis/48683/0B98E1705142

---------------------------------------------------------------
Netragard, LLC - http://www.netragard.com  -  "We make IT Safe"
Penetration Testing, Vulnerability Assessments, Website Security

Netragard Whitepaper Downloads:
-------------------------------
Choosing the right provider : http://tinyurl.com/2ahk3j
Three Things you must know  : http://tinyurl.com/26pjsn


Craig Wright wrote:
> Hi Erin,
> I would disagree. I would split off "compliance" and "perception of compliance". Passing an audit is evidence that a 
> system could be compliant. A compromise of a system using a know vulnerability is strong evidence that it is not 
> compliant.
>
> A system that is breached due to a complex password and secured key that was "guessed" is possible, though unlikely. 
> This would one of the few examples of a compliant system that is also breached. Basically, it will be rare to find a 
> compliant system (to any jurisdiction) that is easily compromised.
>
> What I learnt completing my LLM was how few systems are complaint. How little knowledge there is of the law and legal 
> frameworks already in place (even with politicians) and the lack of due care. An ABSOLUTE baseline for a compliant 
> system that has not other effect other than being owned by a company would be the CISecurity.org baselines at 100%.
>
> The combination of technical people with no knowledge of the legal system, laws and processes with lawyers who can 
> not turn on a PC is an issue here.
>
> "I would agree with Adriel that finding a worthwhile auditor is difficult". Actually so would I. Finding an staff 
> with half a brain provides enough difficulty to want to give up on the whole idea.
>
> "The problems are analyzed from a primarily financial and business risk avoidance perspective"
> Here I have to disagree. I work with financial auditors and I am yet to meet one who understands risk and have met 
> very few who have the faintest comprehension of finance. Audit and finance are NOT the same thing. I did finance at a 
> masters level and I think audit is wacky for the most part. For the rest, there is an approach of try to find nothing 
> wrong or it will upset the client.
>
> I have developed statistically based continuous audit programs for financial systems. These have a significantly 
> lower cost and deliver more. What I get back is "Craig, we are watch dogs and not blood hounds. Please try not to 
> find so much". So I use these with the Insolvency teams and on forensic audits, but it is a hard sell to audit teams. 
> Clients seem to love it though.
>
> "I'm curious as to what vulnerable points you're thinking of." Pen Testing is by nature externally focused. Many of 
> the biggest issues are in the system. Static analysis of code, business process reviews and system walkthroughs all 
> add additional layers of testing.
>
> Many controls are not tested using Pen testing ion any effective manner. Take a banking application. Pen tests look 
> at the system from a software and protocol implementation aspect. They do not go into the business process controls. 
> In this case I would be asking, how do I get the money off the system. This requires an understanding of the controls 
> in the application. This is not something a pen test will provide.
>
> An attacker can do this by compromising the system and modelling the application functions. Or the attacker could be 
> internal and know them. This takes time, it can take months or longer. The same process can be done in a matter of 
> weeks with a cryptal box and business process approach. The pen test provides valuable information as to a known 
> vulnerability, but this is where it stops.
>
> When there are no obvious points of access that may be exploited, a pen test does nothing to state a system is 
> secure, just that it failed to determine the state of the system and was unable to determine if a system was secure 
> or not.
>
> Prof. Cohen developed the concept of protection testing over a decade ago. This mitigates many of the problems with a 
> pen test methodology (that where noted as far back as 1977 by Distraka). The issue is that the tester needs more 
> knowledge than a pen tester.
>
> Protection testing really requires a combination of technical and business process skills. Teams can do this, but 
> this increases cost and also requires a co-ordination factor with knowledge.
>
> "what if the economics aspect were ignored"
> Not my world. We live in a world where EVERTHING is subject to economic constraints and interrelationships.
>
> Time for instance is a economic constraint. They only way to remove it is to have an instantaneous pen test. A 
> detective control that reports faster than a pen test is more effective. The lengthy of the pen test is one factor, 
> but also the frequency. 1 test a quarter is detection every 3 months at best.
>
> Regards,
> Craig Wright GSE LLM ...
>
>
> Craig Wright
> Manager, Risk Advisory Services
>
> Direct : +61 2 9286 5497
> Craig.Wright () bdo com au
> +61 417 683 914
>
> BDO Kendalls (NSW-VIC) Pty. Ltd.
> Level 19, 2 Market Street Sydney NSW 2000
> GPO BOX 2551 Sydney NSW 2001
> Fax +61 2 9993 9497
> http://www.bdo.com.au/
>
> The information in this email and any attachments is confidential. If you are not the named addressee you must not 
> read, print, copy, distribute, or use in any way this transmission or any information it contains. If you have 
> received this message in error, please notify the sender by return email, destroy all copies and delete it from your 
> system.
>
> Any views expressed in this message are those of the individual sender and not necessarily endorsed by BDO Kendalls. 
> You may not rely on this message as advice unless subsequently confirmed by fax or letter signed by a Partner or 
> Director of BDO Kendalls. It is your responsibility to scan this communication and any files attached for computer 
> viruses and other defects. BDO Kendalls does not accept liability for any loss or damage however caused which may 
> result from this communication or any files attached. A full version of the BDO Kendalls disclaimer, and our Privacy 
> statement, can be found on the BDO Kendalls website at http://www.bdo.com.au/ or by emailing mailto:administrator () 
> bdo com au.
>
> BDO Kendalls is a national association of separate partnerships and entities. Liability limited by a scheme approved 
> under Professional Standards Legislation.
> -----Original Message-----
>
> From: Erin Carroll [mailto:amoeba () amoebazone com]
> Sent: Thursday, 5 June 2008 3:24 AM
> To: 'Adriel Desautels'; Craig Wright
> Cc: 'Scott Race'; security-basics () securityfocus com
> Subject: RE: How does a customer get PCI audited?
>
> Very interesting points from both of you that I'd like to respond to and
> follow up on though it does range farther away from the Scott's original
> question.
>
> I think we can agree that standards and compliance controls only provide a
> functional framework for potential security but are by no means a valid
> indicator of actual security. Security Compliance isn't security, just
> compliance. It's easy to become PCI compliant without increasing your
> overall real-world security defense but PCI DSS is one of the better
> standards in that the control guidelines map to actual security fairly well.
> It's one of the few widely adhered-to standards I can point to where this is
> the case the majority of time, though focused on a particular aspect (CC
> info).
>
> I would agree with Adriel that finding a worthwhile auditor is difficult but
> I believe it's a problem endemic to the compliance and audit mindset in
> general. The problems are analyzed from a primarily financial and business
> risk avoidance perspective, not security, so increased real-world security
> is just a side effect of the compliance process. Until security is viewed as
> something other than a cost center I don't see the auditor services industry
> making a push away from the "scan & report" practice. IMHO, QSA's whose
> primary business is the technical security services (pen-testing, VA, etc)
> as opposed to auditing will provide the best ROI.
>
> One thing that I found interesting was Craig's statement that "Pen testing
> is about a 30% option that ignores many of the vulnerable points of a
> system." I'm curious as to what vulnerable points you're thinking of. I
> agree that pen-testing doesn't address all vulnerability aspects but maybe
> you could provide some examples for context. You say that economic
> constraints limit it and that pen-testing isn't the best bang-for-the-buck
> detective control but what if the economics aspect were ignored? Some idea
> of the effectiveness of each detective control (VA, pen-test, policy,
> process, etc) as applied to overall security to assign a weight value (minus
> cost) would level the discussion playing field to debate the merits of each
> aspect. Obviously cost changes those weight values but you'd get a sense of
> how big a slice of the pie chart for each and can more intelligently
> determine a ROI for securing your systems/business. A 20% option at $10
> isn't as cost efficient as a 30% option at $15.
>
> I have yet to read all the way through Craig's paper but I'm working on it
> :)
>
>
> --
> Erin Carroll
> Moderator, SecurityFocus pen-test mailing list
> amoeba () amoebazone com
> "Do Not Taunt Happy-Fun Ball"
>
>
>
>
>
>
> -----Original Message-----
> From: listbounce () securityfocus com [mailto:listbounce () securityfocus com] On
> Behalf Of Adriel Desautels
> Sent: Wednesday, June 04, 2008 8:08 AM
> To: Craig Wright
> Cc: Scott Race; security-basics () securityfocus com
> Subject: Re: How does a customer get PCI audited?
>
> Craig,
>         I'm afraid that you didn't read what I wrote carefully enough or
> that I
> wasn't sufficiently clear in my communications. If you go back and read
> what I said, I explicitly used the words "real" and "good".
>
>         You can be purple in the face with controls and training, but if you
>
> are never PROPERLY tested by a REAL team then you will never know where
> your REAL risks are. The end solution consists of the PROPER
> implementation of controls mixed with the right amount of training. You
> can't create a GOOD solution without knowing details about the problem.
>
>         The unfortunate truth is that MOST businesses that provide
> "auditing"
> type services, or assessing type services do not know what they are
> doing. In fact, very sadly most of them run automated scanners and
> produce deliverables that are the product of those scanners. Those
> deliverables should be free in my opinion as they are usually poor quality.
>
>         In order to properly defend a network you must first know what you
> need
> to defend it against. You must have a strong understanding of the threat
> and how the threat might align with your risk and exposure profile. The
> only way to do that is to either have good threat intelligence, or work
> with a qualified penetration testing team that has REAL threat
> intelligence.
>
>         Once you've identified such a firm your IT Infrastructure,
> personnel,
> policies, etc. need to be tested at the same or higher threat level as
> you'd face in the real world. That will identify your risks and help you
> to build the proper CONTROLS to counter those risks. Suggesting that
> anyone build controls without first having a GOOD and REAL assessment is
> horrible advice. That would be akin to building defenses against Russia
> during the cold war with no intelligence about their capabilities.
>
>         With respect to your paper, I still need to go read it. That said,
> even
> if Penetration Testing is 30% of the total solution, it is clearly the
> foundation to building the solution. Else you are building a blind
> defense that most probably won't work.
>
>         Its common sense Craig, know your enemy, know yourself, and then you
>
> can build a good defense.
>
> Regards,
>         Adriel T. Desautels
>         Chief Technology Officer
>         Netragard, LLC.
>         Office : 617-934-0269
>         Mobile : 617-633-3821
>         http://www.linkedin.com/pub/1/118/a45
>
>         Join the Netragard, LLC. Linked In Group:
>         http://www.linkedin.com/e/gis/48683/0B98E1705142
>
> ---------------------------------------------------------------
> Netragard, LLC - http://www.netragard.com  -  "We make IT Safe"
> Penetration Testing, Vulnerability Assessments, Website Security
>
> Netragard Whitepaper Downloads:
> -------------------------------
> Choosing the right provider : http://tinyurl.com/2ahk3j
> Three Things you must know  : http://tinyurl.com/26pjsn
>
>
> Craig Wright wrote:
> > "You secure your systems by having an IT Security Company perform a real
> > good assessment"
> > No, good controls and training help secure a system. Pen testing is a
> detective control. No more. In fact, it is not even close to being the best
> (bang for buck) detective control.
> > Actually, Pen testing is about a 30% option that ignores many of the
> vulnerable points of a system. Economic limits constrain it. The difficulty
> > I did some scientific research into this in the past. I published in the
> IIA journal and a few others and a paper is on the sans reading room as
> well:
> > http://www.sans.org/reading_room/whitepapers/auditing/1801.php
> >
> > The difficultly is that there are very few auditors with a deep technical
> level of knowledge.
> > Craig
> >
> >
> > Craig Wright
> > Manager, Risk Advisory Services
> >
> > Direct : +61 2 9286 5497
> > Craig.Wright () bdo com au
> > +61 417 683 914
> >
> > BDO Kendalls (NSW-VIC) Pty. Ltd.
> > Level 19, 2 Market Street Sydney NSW 2000
> > GPO BOX 2551 Sydney NSW 2001
> > Fax +61 2 9993 9497
> > http://www.bdo.com.au/
> >
> > The information in this email and any attachments is confidential. If you
> are not the named addressee you must not read, print, copy, distribute, or
> use in any way this transmission or any information it contains. If you have
> received this message in error, please notify the sender by return email,
> destroy all copies and delete it from your system.
> > Any views expressed in this message are those of the individual sender and
> not necessarily endorsed by BDO Kendalls. You may not rely on this message
> as advice unless subsequently confirmed by fax or letter signed by a Partner
> or Director of BDO Kendalls. It is your responsibility to scan this
> communication and any files attached for computer viruses and other defects.
> BDO Kendalls does not accept liability for any loss or damage however caused
> which may result from this communication or any files attached. A full
> version of the BDO Kendalls disclaimer, and our Privacy statement, can be
> found on the BDO Kendalls website at http://www.bdo.com.au/ or by emailing
> mailto:administrator () bdo com au.
> > BDO Kendalls is a national association of separate partnerships and
> entities. Liability limited by a scheme approved under Professional
> Standards Legislation.
> > -----Original Message-----
> >
> > From: listbounce () securityfocus com [mailto:listbounce () securityfocus com]
> On Behalf Of Adriel Desautels
> > Sent: Wednesday, 4 June 2008 7:25 AM
> > To: Craig Wright
> > Cc: Scott Race; security-basics () securityfocus com
> > Subject: Re: How does a customer get PCI audited?
> >
> > Craig,
> >         You secure your systems by having an IT Security Company perform a
> real
> > good assessment. It should be either a Penetration Test or a
> > Vulnerability Assessment. Penetration Tests are more in-depth,
> > Vulnerability Assessments are more safe. If you want information on both
> > of those services I've got a few white-papers that we've written that
> > you can download. Unfortunately, it is very hard to find good vendors
> > these days.
> >
> > Regards,
> >         Adriel T. Desautels
> >         Chief Technology Officer
> >         Netragard, LLC.
> >         Office : 617-934-0269
> >         Mobile : 617-633-3821
> >         http://www.linkedin.com/pub/1/118/a45
> >
> >         Join the Netragard, LLC. Linked In Group:
> >         http://www.linkedin.com/e/gis/48683/0B98E1705142
> >
> > ---------------------------------------------------------------
> > Netragard, LLC - http://www.netragard.com  -  "We make IT Safe"
> > Penetration Testing, Vulnerability Assessments, Website Security
> >
> > Netragard Whitepaper Downloads:
> > -------------------------------
> > Choosing the right provider : http://tinyurl.com/2ahk3j
> > Three Things you must know  : http://tinyurl.com/26pjsn
> >
> >
> > Craig Wright wrote:
> > > "What are the chances of them getting audited?"
> > > PCI Top level = 100%
> > > A break-in occurs = 99.5%
> > >
> > > A better question is how do I pass an audit and better yet, how do I
> secure my systems.
> > > PCI-DSS is just the tip of the iceberg for potential issues. In fact it
> is the low risk consideration. Think class action. PCI-DSS compliance is at
> least a small defence. That is being ACTUALLY compliant and not just doing
> enough to fool the QSA.
> > > Regards,
> > > CSW GSE LLM
> > >
> > >
> > > Craig Wright
> > > Manager, Risk Advisory Services
> > >
> > > Direct : +61 2 9286 5497
> > > Craig.Wright () bdo com au
> > > +61 417 683 914
> > >
> > > BDO Kendalls (NSW-VIC) Pty. Ltd.
> > > Level 19, 2 Market Street Sydney NSW 2000
> > > GPO BOX 2551 Sydney NSW 2001
> > > Fax +61 2 9993 9497
> > > http://www.bdo.com.au/
> > >
> > > The information in this email and any attachments is confidential. If you
> are not the named addressee you must not read, print, copy, distribute, or
> use in any way this transmission or any information it contains. If you have
> received this message in error, please notify the sender by return email,
> destroy all copies and delete it from your system.
> > > Any views expressed in this message are those of the individual sender
> and not necessarily endorsed by BDO Kendalls. You may not rely on this
> message as advice unless subsequently confirmed by fax or letter signed by a
> Partner or Director of BDO Kendalls. It is your responsibility to scan this
> communication and any files attached for computer viruses and other defects.
> BDO Kendalls does not accept liability for any loss or damage however caused
> which may result from this communication or any files attached. A full
> version of the BDO Kendalls disclaimer, and our Privacy statement, can be
> found on the BDO Kendalls website at http://www.bdo.com.au/ or by emailing
> mailto:administrator () bdo com au.
> > > BDO Kendalls is a national association of separate partnerships and
> entities. Liability limited by a scheme approved under Professional
> Standards Legislation.
> > > -----Original Message-----
> > >
> > > From: listbounce () securityfocus com [mailto:listbounce () securityfocus com]
> On Behalf Of Scott Race
> > > Sent: Tuesday, 3 June 2008 8:37 AM
> > > To: security-basics () securityfocus com
> > > Subject: How does a customer get PCI audited?
> > >
> > > I have a client (same one from a previous post) who has some pretty
> > > serious security issues on their network (unsecured .mdb file with
> > > credit card into, etc).  I will be fixing the major security holes in
> > > their network, but they still have PCI compliance issues, and I'm
> > > assuming they need to have a quarterly scan done.
> > >
> > > They've had this setup for about a year, they knows nothing about PCI
> > > and compliance (myself included, I am not a QSA and still learning about
> > > the compliance procedure).
> > >
> > > What are the chances of them getting audited?  How does all that work?
> > > Could they potentially fly under the radar for years?  I thought there
> > > was something they had to report quarterly to show they're working on
> > > compliance, or something.
> > >
> > > I want to be able to tell they company "Listen, here's what could happen
> > > if you get audited, and here's the chances of you getting audited" in
> > > hopes they would take it seriously.  I don't want to scare them without
> > > knowing the facts, first I want to know the facts, then I will scare
> > > them.  Thanks.
> > > Scott Race
> > > Technology Manager
> > >
> > > JD+A NETWORK SERVICES
> > > 1264 Hawks Flight Court, Suite 200
> > >
> > > El Dorado Hills, CA 95762
> > > P:  916.941.3700  |  F:  916.941.3777
> > >
> > >
> > > ethingHo????