It was an interesting time in Las Vegas this year. Part of that is due to the fact that we are in Las Vegas. But part of it was that the Community Meeting seemed to be devoid of the usual anticipation for the Community Meeting and expected pronouncements. While there were announcements for various standard updates, these were well anticipated and were not a surprise. Some of the slide decks have been released, but others will not be available until the European Community Meeting is held in a few weeks.
While there were a number of good presentations this year, in my very humble opinion, the best session was the Assessor Session at the end of the meeting. The good news this year was that a lot of QSAs and ISAs made sure to stick around for this session. There were a number of good questions asked after the Council’s presentation, but I will wait for the Council’s transcript to be published before weighing in on those.
As in years past, the Council had a presentation at the start. The following are highlights from that presentation.
AQM Program Highlights
As usual, the AQM team did a bang-up job pointing out common issues found in the various assessment types they review.
On the PA-DSS side of the ledger, a lot of PA-QSAs are having issues with requirement 5.1.6.b regarding application least privilege. The Council clarified that what they are looking for in this requirement is proof that the application does not run as ‘root’, ‘administrator’ or some other default privileged account in order to run properly.
For P2PE assessments, there have been issues regarding when a double length 3DES key can be used. The Council explained that a double length 3DES key is only allowed when using derived unique key per transaction (DUKPT). All other uses must be triple length keys to be in compliance with P2PE.
Apparently, QSAs and their QA minders are totally missing what is meant by “describe how”. When describing “how” a QSA must describe all of those procedures used to determine the requirement was satisfied as well as how those procedures prove the requirement was met.
QSAC QA manuals still are not covering topics such as evidence retention and destruction, security incident response plans and code of conduct policy. The Council reminded everyone to make sure all topics in the QSA Qualifications Requirements document are covered.
Compensating controls were a continuing problem area and that should not be a surprise. I am constantly fascinated when I receive a ROC for proof of PCI compliance performed by another QSAC and get to see what passes for a valid compensating control worksheet (CCW) at other firms. Apparently ‘intent and rigor’ of the requirement and ‘above and beyond’ are foreign phrases to a lot of QSAs. Never mind the fact that the controls used, tested and maintained are usually vague in description. The Council pointed people to their Portal for remedial training of QSAs that cannot comprehend writing a CCW. I have written a number of posts on compensating controls. If you want to write good CCWs, start here for the most current post and it will point you to prior posts.
The Council got some interesting questions from QSAs over the year. The first one is one that a lot of clients ask us, “Do you really have to come onsite?” Yes, an onsite visit by the QSA is actually required. However, how long a QSA needs to be onsite can vary from as little as a couple of days for a long-time client to a week or more for a new client. Onsite visits can be supplemented by video meetings when needed. Not unusual these days when a client has worldwide operations and not everyone is located at headquarters or will not be available when the QSA is onsite.
The other question was regarding ROC and AOC dates. How people keep messing these up is beyond me, but as with the CCWs, I see a lot of ROCs and AOCs out of other firms where the dates on the documents are not consistent. Basically, the last thing any QSAC should do is to set all of the dates in the ROC and AOC to match as part of their document finalization processes. That way you will avoid this problem.
There was a brief discussion of the Software Security Standard (S3) that will replace the PA-DSS. Most of the discussion revolved around the proposed timeline. The standards themselves will be published sometime before year end. Reporting materials will be published around mid-2019 with training commencing in the Fall of 2019. The big deadline is that PA-DSS Reports On Validation (ROV) will only be accepted through mid-2020 requiring all reports going forward to be under the S3. That will mean that by mid-2022, all PA-DSS validated applications will move to “Acceptable for Pre-Existing Deployments”.
Finally, SSL and early TLS got a discussion. Somehow the word has not gotten around that if a company still uses SSL and/or early TLS, there must be a compensating control developed for the relevant requirements since Appendix A2 no longer exists in v3.2.1 of the DSS. They also reminded everyone that having SSL or early TLS is NOT an automatic fail. However, vulnerability scans will have to have explanations developed justify the use of the protocols as well as what is done to mitigate their use.
Card Production Security Assessor Program
If you were not aware, the PCI SSC took over the various card brands’ card production programs and created a single common program similar to what the Council did with the Data Security Standard back in 2006.
In response the Council is creating a new assessor program in 2019. Card Production Assessor Companies (CPAC) will not need to be existing QSACs nor will assessors need to be QSAs. The new assessor training program will be rolled out next year for this standard. The Council did note that existing card production assessors will be somehow recognized by the new program but did not specify how that recognition would be implemented.
As with QSACs and QSAs, the Council will maintain a database of CPACs and qualified card production assessors.
PIN Assessor Program
As with card production, the Council has also been responsible for PIN standards for a few years now. As a result, the Council is developing a program for creating PIN Assessor Companies and PIN Assessors.
There will be no need for the PIN Assessor Company to be a QSAC nor will assessors be required to be QSAs. This program will also start in 2019.
Global Executive Assessor Roundtable (GEAR)
This is a new group that was established this year. Its role is to provide a direct communication channel between the PCI SSC and 20 qualified security assessor companies’ (QSAC) senior executive leadership. This group met for the first time a few days before the start of the Community Meeting. Each member of GEAR serves for a two-year term.
The 20 QSACs on the GEAR are:
- @sec
- Advantio
- Coalfire
- Control Case
- Foregenix
- IBM Security
- isec
- K3DES
- nccgroup
- Protiviti
- PSC
- RSM
- Security Metrics
- Shellman
- SISA
- Sysnet
- Trustwave
- UL
- usd
- Verizon
As usual, it was great catching up with everyone and meeting new Guru fans. I really appreciate all of the great comments about the blog. Even though I see the statistics for the blog, it still amazes me how many people read it and appreciate it particularly when you meet so many of them in person. It is very humbling.
Hopefully I will see you all next year in Vancouver.