Full Disclosure mailing list archives

Re: Compliance Is Wasted Money, Study Finds


From: Digital X <digitalx00 () gmail com>
Date: Wed, 07 Apr 2010 15:52:00 -0600


Whether said checkbox is actually the best solution *for the actual problem*
is the issue.  I've seen cases where checkbox auditors insisted that a
certain critical system "absolutely positively *HAD* to have a firewall".

This is where compensating controls come in with PCI. If there is an
even better solution you are free to implement it.

Yes, the PCI "compensating controls" are overall a Good Thing.  Unfortunately,
a lot of regulatory regimes don't see things that way yet.  And it still
requires a clued PCI auditor who actually understands the real world enough
to deal with compensating controls.

Having just gone through a PCI audit I can safely say a few things:
 
A)  Approaching compliance from a risk management approach went out the
window
B)  Items the auditor didn't understand absolutely went back to a checkmark
mentality
C)  Items that were gray areas were treating VERY liberally in their
interpretation

Bleh


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