RE: How does a customer get PCI audited?

["Erin Carroll" <amoeba () amoebazone com>]

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????