This is page 3 of:

PCI 2.0 Changes: The Good, The Bad And The Hashing

October 28th, 2010

The clarification to Requirement 11.1 is a sensible one that may make compliance easier for retailers with a large number of locations. That requirement also dealt with wireless security and formerly instructed retailers to “test for the presence of unauthorized wireless access points by using a wireless analyzer at least quarterly or deploying a wireless IDS/IPS.” The requirement now states, “methods that may be used in the process include, but are not limited to, wireless network scans, physical site inspections, network access control (NAC) or wireless IDS/IPS.” That means you don’t necessarily have to carry a wireless analyzer. A little physical observation and war-walking might do the trick. Don’t let this be a throwaway; rogue wireless devices are a very real threat, and you should take these (at least) quarterly inspections very seriously.

Going beyond the changes to the actual PCI DSS, the Council announced a number of initiatives to improve communication with merchants and processors. These initiatives include a new Web site (with special sections for small merchants), a new “Navigating the PCI DSS Document” and revised Self-Assessment Questionnaires (SAQs). There may even be a new SAQ or two, if I understood some of the hints at the Community Meeting.

At the risk of being picky, there is one area that I wish had been addressed and one statement in the PCI DSS that I believe is incorrect and needs to be changed.

The area that didn’t get addressed is Requirement 12.8. It seems uniquely unfair that retailers need to get their service providers to acknowledge in writing their responsibility for the security of the retailers’ data in their control, but there is no corresponding requirement for the service providers to actually give that acknowledgement. I pointed this out during one of the sessions with the PCI Council and the group noted it thoughtfully, so maybe we will see this reflected in an updated version.

The change that didn’t get made is the definition of the scope of external vulnerability scans. Both the previous and new documents state that “Scan[s] must cover all externally accessible (Internet-facing) IP addresses in existence at the entity.” I had hoped the PCI Council might update it to specify only IP addresses in the cardholder data environment. This specific issue was raised at last year’s Community Meeting, and the response was that scanning only applied to the cardholder data environment. Given that a lot of retailers and processors can have thousands of IP addresses, I would have thought this definition might be corrected. At least, I hope it’s a correction!

There are many other clarifications, some small and some large. Which items caught your attention? What changes did you want to see? I’d like to hear your thoughts. Either leave a comment or E-mail me at


Comments are closed.


StorefrontBacktalk delivers the latest retail technology news & analysis. Join more than 60,000 retail IT leaders who subscribe to our free weekly email. Sign up today!

Most Recent Comments

Why Did Gonzales Hackers Like European Cards So Much Better?

I am still unclear about the core point here-- why higher value of European cards. Supply and demand, yes, makes sense. But the fact that the cards were chip and pin (EMV) should make them less valuable because that demonstrably reduces the ability to use them fraudulently. Did the author mean that the chip and pin cards could be used in a country where EMV is not implemented--the US--and this mis-match make it easier to us them since the issuing banks may not have as robust anti-fraud controls as non-EMV banks because they assumed EMV would do the fraud prevention for them Read more...
Two possible reasons that I can think of and have seen in the past - 1) Cards issued by European banks when used online cross border don't usually support AVS checks. So, when a European card is used with a billing address that's in the US, an ecom merchant wouldn't necessarily know that the shipping zip code doesn't match the billing code. 2) Also, in offline chip countries the card determines whether or not a transaction is approved, not the issuer. In my experience, European issuers haven't developed the same checks on authorization requests as US issuers. So, these cards might be more valuable because they are more likely to get approved. Read more...
A smart card slot in terminals doesn't mean there is a reader or that the reader is activated. Then, activated reader or not, the U.S. processors don't have apps certified or ready to load into those terminals to accept and process smart card transactions just yet. Don't get your card(t) before the terminal (horse). Read more...
The marketplace does speak. More fraud capacity translates to higher value for the stolen data. Because nearly 100% of all US transactions are authorized online in real time, we have less fraud regardless of whether the card is Magstripe only or chip and PIn. Hence, $10 prices for US cards vs $25 for the European counterparts. Read more...
@David True. The European cards have both an EMV chip AND a mag stripe. Europeans may generally use the chip for their transactions, but the insecure stripe remains vulnerable to skimming, whether it be from a false front on an ATM or a dishonest waiter with a handheld skimmer. If their stripe is skimmed, the track data can still be cloned and used fraudulently in the United States. If European banks only detect fraud from 9-5 GMT, that might explain why American criminals prefer them over American bank issued cards, who have fraud detection in place 24x7. Read more...

Our apologies. Due to legal and security copyright issues, we can't facilitate the printing of Premium Content. If you absolutely need a hard copy, please contact customer service.