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PCI Merchant Levels for American Express | PCI DSS

PCI merchant levels have been clearly defined by all the major payment brands (VISA, MasterCard, American Express, Discover Card, and JCB). What’s important to note is that you should also look at each of the payment brand’s respective Levels for truly understanding where you fall.

Thus, PCI merchant levels for American Express are defined as the following:

Level 1: Merchants processing over 2.5 million American Express Card transactions annually or any merchant that American Express otherwise deems a Level 1.

Level 2: Merchants providing 50,000 to 2.5 million American Express transactions annually or any merchant that American Express otherwise deems Level 2.

Level 3: Merchants processing less than 50,000 American Express transactions annually.

Thus, the requirements for these respective Levels as far as compliance is concerned are the following:

Level 1: Annual onsite review by QSA (PCI DSS Assessment) and Quarterly Network Scan by ASV.
Level 2: Quarterly Network Scan by ASV.
Level 3: Quarterly Network Scan by ASV.

To learn more about PCI Merchant Levels and the Payment Card Industry Data Security Standards (PCI DSS), visit pciassessment.org

Compliance with PCI DSS | Expert Advice from a PCI QSA

Compliance with PCI DSS can be daunting and a challenge indeed. However, simply breaking down the PCI DSS requirements and looking at it in a thought manner will help alleviate your concerns. As a Payment Card Industry Qualified Security Assessor (PCI QSA), i’m often asked the who, what, when, where, and why of compliance with PCI DSS.

So, with that said, here is some important advice in truly understanding compliance.

1. You need to find out if you are identified as a merchant or a service providers in the eyes of PCI compliance. Contact a PCI QSA for advice on this issue if you are not sure of your answer.

2. Once you have accomplished this, you need to identify what “Level” of compliance is mandated for your organization. This can be done by calculating the total number of transactions your organization undertook or will undertake in a full year’s time. Take note, that for merchants, most organizations will fall into Levels 2,3, and 4, which can allow you to conduct a PCI DSS self-assessment (with oversight and guidance from a PCI-QSA is what i highly recommend). Level 1 merchants will have to undergo an actual on-site PCI DSS assessment by a QSA. As for service providers, most of you will also have to undergo an on-site PCI DSS assessment. Again, find your level based on your transaction volume.

3. If you can self-assess, then visit pcisecuritystandards.org and obtain the self assessment questionnaires. There are five (5) of them, so read carefully as to which one is for you. If you have to have an actual on-site PCI DSS assessment done, then contact a firm who can conduct this for you.

PCI DSS Merchants Levels | Learn Your Requirements for PCI DSS Compliance

Regarding PCI DSS merchant levels, it is paramount that these very merchants properly identify the level they fall under for compliance with PCI DSS. Most merchants will be able to undergo their own payment card industry data security standards (PCI DSS) self assessment questionnaire (SAQ). However, many will also be required to conduct and go through an annual on-site assessment by a Qualified Security Assessor (QSA).

Again, this all depends on the merchant levels and you have to understand that these PCI DSS merchant levels are different for each of the respective payment brands. So, let’s take a closer look at this.

Discover Card: They do not even use merchant level categories, rather, they use a risk based approach for assigning PCI DSS requirments.

VISA: Visa uses Levels 1 to 4 for classifying merchant levels. Learn more about VISA Merchant requirments

American Express, JCB, MasterCard: These major payment brand heavyweights also have identify merchants from Levels 1 to 4, and again, this is based on transaction volume. Learn more about their PCI DSS merchant levels.

PCI DSS and SAS 70 Audits | Audit Efficiencies? Maybe…just Maybe

As a SAS 70 auditor and a PCI QSA, i’m often asked about the efficiencies of scale that can be achieved with SAS 70 audits and PCI DSS assessments. I have blogged about this a few times before, so let me be more clear and transparent in what i believe can actually be obtained in regards to audit efficiencies when conducting a SAS 70 and a PCI DSS assessment on an entity.

First and foremost, as an auditor, there should still be independence within the SAS 70 audit and the PCI DSS assessment. Independence how? Simple, do not treat them as one audit, because they are simply not that. Technically speaking, a PCI assessment is just that, an assessment, not an audit, which requires “attestation”. Moreover, there are significant differences between the audit and the assessment, which can be discussed at length (and will be) in a whole different blog.

I stress in the title of this blog that “maybe” there can be audit efficiencies, however, it many times is dependent on the quality of the auditors, their expertise in both conducting a PCI and a SAS 70 audit, and how much they are willing to rely on evidence from the PCI DSS assessment for the SAS 70 audit, and vice versa. Good auditors will find ways to create these efficiencies; other auditors might want to conduct a PCI DSS assessment and rubber stamp a SAS 70-this is a BIG NO NO.

Want to learn more about where these efficiencies of scale can be maximized? To learn more about SAS 70 audits, visit the official SAS 70 Resource Guide and to learn more about PCI DSS Assessments, visit the PCI Resource Guide.

SAS 70 Audits and PCI DSS Compliance | A Two for One Audit? Not Quite

As an accountant and a PCI Qualified Security Assessor (QSA), i’m seeing more and more auditors essentially provide audit and fieldwork services for both a SAS 70 and a PCI DSS assessment at the same time, then issue a PCI DSS Report on Compliance (ROC) and a SAS 70 Type II Service Auditor’s Report. While I am all for audit efficiencies, there does need to be some degree of engagement independence, both in an administrative manner (different engagement letters, etc.) and in terms of audit expertise (both CPA’s and QSA’s need to be involved in their respective assignments and committed to the work at hand).

Furthermore, SAS 70 audits will also examine areas not covered by PCI DSS assessments, and the same is true for PCI DSS assessments covering technical areas traditionally not under the scope of a SAS 70 audit. As professionals, we need to be careful in not blurring the lines and distinctions between CPA’s and QSA’s and still try to maintain professional indepedence in regards to the work that each does and what they are qualified to do.

To learn more about SAS 70 audits, visit the official SAS 70 Resource Guide.
To learn more about PCI DSS assessments, visit pciassessment.org

SAS 70 Audits and PCI DSS Compliance |What you NEED to Know

As an auditor, I am constantly approached by my clients desperately wanting to know if efficiencies can be obtained within the audit and assessment process for companies undergoing both a SAS70 audit and a PCI DSS assessment. There’s no simple yes or no, black or white answer to this, as many variables come into play when conducting a SAS70 audit or a PCI DSS assessment for organizations.

What I can tell you though is that there are some common themes and drivers seen in both a SAS70 audit and a PCI DSS assessment. Both a SAS70 audit and a PCI DSS assessment rely heavily on the existence of documented policies & procedures. Furthermore, both of these examinations also examine various aspects of physical security, network security, logical security, change management, to name a few. Quickly, you can see some overlapping themes in both a SAS70 audit and a PCI DSS assessment. So, that’s the YES answer to “audit efficiencies can be obtained” when a company has to undertake a SAS70 audit and a PCI DSS assessment. So, what’s the NO or the gray erea? Keep in mind that the PCI DSS assessment is a very technical examination, much more so than a SAS70 audit. At the same time, a SAS70 audit also covers comprehensive business process controls applicable to that specific entity being examined for a SAS70. A PCI DSS assessment does generally not cover or assess these specific business processes that a SAS70 would. Thus, you can see the gaps between these two examinations.

To learn more about what SAS70 is, visit the official SAS70 Resource Guide

To learn about Payment Card Industry (PCI) DSS compliance, visit the official PCI Resource Guide.

Payment Card Industry (PCI DSS) Compliance | Requirement 1.1.2

Payment Card Industry (PCI) Data Security Standards (DSS) compliance for PCI DSS requirement 1.1.2 calls for “Current network diagram with all connections to cardholder data, including any wireless networks” Thus, testing for validating 1.1.2 requires verification “that a current network diagram (for example, one that shows cardholder data flows over the network) exists and that it documents all connections to cardholder data, including any wireless networks.”

Okay, once again here, the key phrase is “current network diagrams”. What does this essentially mean? It means having a subject matter expert within your I.T. department developing a current network diagram and topology documents showing all critical connection points along with a visual of all critical hardware and network components that make up the network topology. More importantly, these diagrams and network topology documents should be current and updated on a quarterly basis to reflect overall changes in the network layout of the organization. Keep in mind that these documents will also be valuable for other regulatory compliance mandates, such as a SAS 70 Type II audit, which many merchants and service providers have to have at some point in their business lifecycle.

And though the requirement for PCI DSS 1.1.2 calls for these network diagrams for only “connections to cardholder data” its a very good and wise idea to draw and map out your organization’s entire network topology. Why? Because it just makes good business sense and again, it helps with other regulatory compliance mandates that your organization may have to endure.

To learn more about SAS 70 audits, visit the official SAS 70 Resource Guide
To learn more about PCI DSS compliance, visit pciassessment.org

Payment Card Industry (PCI DSS) Compliance | Requirement 1.1.1

PCI DSS Requirement 1.1.1 calls for “A formal process for approving and testing all network connections and changes to the firewall and router configurations”. Thus, the test to validate this, in accordance with PCI DSS 1.2 standards is to “Verify that there is a formal process for testing and approval of all network connections and changes to firewall and router configurations”. Thus, network connections, firewall rulesets/configurations and settings to routers must be placed in a proactive mode for ensuring continuous protection for the organization. As threats become known and as business needs change, this formal process needs to be documented to address this specifically.

The key phrase here my friends is “formal process”. What does that really mean? It means having documented policies and procedures in place for approving and testing connections/changes to these critical devices. Easier said than done as most organizations do not have the time or resources to formally write out documented policies and procedures. Beware, as this is a very large part of ensuring PCI DSS compliance. To learn more about PCI DSS and documented policies and procedures for PCI DSS compliance, visit pciassessment.org.

Payment Card Industry (PCI DSS) Compliance | Requirement 1.1

Payment Card Industry (PCI) Data Security Standards (DSS) for Requirement 1.1 require organizations to “Establish firewall and router configuration standards”. This requirement falls under the functional area of the overall Requirement 1.0, which states that organizations must “Install and maintain a firewall configuration to protect cardholder data”. So, what does this requirement 1.1 specifically mean and what do merchants, service providers and other supporting organizations need to be aware of? In short, PCI DSS requirements for 1.1 call for organizations to “Obtain and inspect the firewall and router configuration standards and other documentation specified below to verify that standards are complete”. In essence, its a rather straightforward testing approach that requires that configuration standards are commensurate and in line with the business needs of the organization for ensuring that no unwanted or malicious traffic is kept out and that only the traffic designated is allowed through. A PCI QSA can verify this requirement by consulting and inspecting the current firewall settings and configurations. Take note, as all unnecessary ports and configurations should be closed if they are not suitable or conducive to the cardholder environment. To learn more about PCI DSS, visit pciassessment.org

PCI DSS Compliance in Today’s Heightened Security World

PCI DSS stands for Payment Card Industry Data Security Standards. If you are a merchant or service provider who is directly involved in the processing, storage, or transmission of transaction data or cardholder data, then you should be looked upon as PCI DSS candidates for compliance.

As with any compliance mandate, costs can be expensive, it can be time consuming to go through the assessment, and it’s something that has to be conducted annually.

The very first thing organizations should do to prepare for PCI DSS compliance is to make sure their organization has documented policies and procedures in place. And why? Because a large part of the success of obtaining PCI DSS compliance is dependent on having these very documented policies and procedures in place. Don’t believe me? Well, take a look at the PCI DSS standards for yourself and read between the lines and you will quickly find that this is an absolute necessity.

If you do not have them or do not have the time and skills to write them, then I highly recommend you hire a consulting firm who is an expert at writing policies and procedures for PCI DSS.

Time and time again, this is one of the biggest weaknesses I seen in merchants, service providers and any other organization looking to become PCI DSS compliant.