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Major Chain Loses PCI Compliance When Data Center Moves
A conference call was quickly scheduled with the merchant’s acquiring bank and key card brands to discuss the PCI compliance reporting options. And, yes, there were some serious differences of opinion between the retailer and the QSA. Those options were: (1) mark the network flat and not segmented and reference the new data center project as the reason for the situation and non-compliance or, (2) develop a compensating control for the flat network. The reason that the current network configuration results in non-compliance is that not all of the devices on the network are properly configured and controlled to ensure PCI compliance because these devices have been out of scope in past PCI assessments.
If marked non-compliant, this will require that the acquiring bank monitor the data center project through completion and then ensure that the ACLs are placed back in operation to properly segment the network. Although this is the QSA’s preferred option, the chain does not want to be flagged as non-compliant, so they are pushing for a compensating control.
During the acquiring bank conference call, the reporting options are discussed. Although the QSA and internal audit push for the non-compliant Report On Compliance option, the merchant’s management pushes for a compensating control. The QSA discusses the fact that the controls the merchant intends to rely upon do not appear to meet the “above and beyond” requirement.
At the end of the call, the acquiring bank decides they also do not want to deal with a non-compliant ROC, and they tell the QSA to prepare a compensating control that they will evaluate prior to submission of the ROC. A few weeks later, the QSA submits the compensating control for the acquiring bank’s review. Except for a few wording changes, the compensating control is accepted and the merchant’s ROC is completed.
What are the lessons that can be learned from this incident?
Jeff can be reached at email@example.com.