Educause Security Discussion mailing list archives

Re: PCI


From: Paul Kendall <PKendall () ACCUDATASYSTEMS COM>
Date: Mon, 27 Jun 2011 13:22:59 -0500

That's correct. Yes, the 'letter of the law' within PCI does conflict with IPv6. HOWEVER, there are numerous ways 
around it. Compensating controls are the first and foremost that come to mind, and it does not necessarily require a 
huge effort or workaround.

Once again, proper segmentation of the network to isolate the CDE will bring the most beneficial results here, and 
minimize the effort required for PCI compliance..

Paul L. Kendall
===================================
Paul L. Kendall, CGEIT, CISM, CISSP, CSSLP
Certified HIPAA Professional
Certified HIPAA Security Specialist
PCI Qualified Security Assessor
Senior Consultant - Assessments & Compliance

Main 281.897.5000  |  Direct 817.496.6450  |  Cell 713.446.5259  |  http://www.accudatasystems.com
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-----Original Message-----
From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Sam 
Hooker
Sent: Monday, June 27, 2011 11:36 AM
To: SECURITY () LISTSERV EDUCAUSE EDU
Subject: Re: [SECURITY] PCI


Unless I've missed something, the DSS (2.0) itself doesn't precisely define the "network vulnerability scans" referred 
to under requiremet 11, at least not with respect to host discovery. On page 13 of the PCI "Approved Scanning Vendors 
Program Guide"[1] (v1.0, dated March of 2010) though, I find the following, under "ASV Scan Solution - Required
Components":

'Perform host discovery

The ASV scan solution must make a reasonable attempt to identify live systems, including live systems that do not 
respond to ICMP echo
("ping") requests.'


Presuming the same standard applies to your internal scans, the question then becomes: What constitutes "reasonable"?


Cheers,

-sth

[1]https://www.pcisecuritystandards.org/documents/asv_program_guide_v1.0.pdf

--
Sam Hooker | samuel.hooker () uvm edu
Systems Architecture and Administration
Enterprise Technology Services
The University of Vermont


On 20110627 11:44 , John Ladwig wrote:
DSS 2.0 clarifies that RFC1918 may be used in the CDE, *or* you may use global addresses, but then MUST NOT advertise 
those networks to the global Internet.  That latter is certainly doable for v6 networks, such as they exist.  There's 
still the nagging issue of almost no commercial gear implementing NAT66, which would also impact the ability to use 
Unique-local addressing for the CDE hosts.

Fortunately, my world seems to have no particular interest in moving to v6 in general, much less in our in-scope 
environments.

   -jml

"Curtis, Bruce" <Bruce.Curtis () NDSU EDU> 2011-06-27 10:01 >>>

On Jun 27, 2011, at 9:41 AM, Jacobson, Dick wrote:

I attended a IPv6 seminar last week and am wondering if I heard something correctly. This did not register with me 
until after the seminar and  since the seminar I have been looking for an email address for Johannes Ullirich (the 
instructor), but have not found one, and asked a few people around here about this.  I have not been able to get a 
half-way-confident answer so I am bringing the question here.
 
I think I heard that on an IPv6 network, you can not be PCI compliant because (I think) the size of the address 
space makes it impossible to scan in a timely manner, as required. 
 
Does this question make sense ?  Any comments/thoughts for me ?

There are several things about PCI that do not make any sense.

  For example PCI requires that a network implement NAT.  Since there is no NAT in IPv6 PCI appears to have it's head 
in the sand about the future of the Internet.  PCI does have some provisions for compensating methods so perhaps 
there is a way around the NAT requirements but it just seems silly that PCI has not considered the implications of 
IPv6.

  I'm less familiar with the PCI requirements on scanning but I have heard that there were issues with NIST or other 
government agency requirements and scanning but they may have made progress on those issues by now.

  Essentially it is impossible to scan all of the IPv6 addresses in a subnet from a remote host that is not on that 
subnet.  If the scan of an IPv6 subnet is performed from that subnet then there may be ways of scanning all active 
IPv6 hosts on that subnet.

http://www.ietf.org/rfc/rfc5157.txt

---
Bruce Curtis                         bruce.curtis () ndsu edu 
Certified NetAnalyst II                701-231-8527
North Dakota State University        


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