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After Seven Months, Why Does The PCI Council Yet To Have Anyone P2PE Validated?
Third-party payment organizations that provide the benefits of a hopefully secure, reliable payment package to merchants without enormous IT and information security (InfoSec) staffs have essentially been forced to play the P2PE game with one hand tied behind their backs. That’s true at least until the PCI SSC decides to release an applicable set of guidelines.
Why has the council done this? Does it believe software is inherently less secure than hardware? I’m sure that’s a question engineers and programmers could debate for hours, but it’s irrelevant, because the HSM runs software. Strip away the fancy name and the physical tamper-proofing, and the HSMs that meet PCI SSC’s requirements are little more than off-the-shelf servers that could be picked up from HP or Dell for a few hundred bucks.
What, then, makes them any different from the secure servers some vendors have running their decryption software? A name? If we, for example, put our package on one of these magical boxes, could we become the first listed provider? As ridiculous as it sounds, maybe it’s worth looking into. It would certainly offer users more security than they will see from another provider that just blindly “follows the standard.”
Now let’s add one more layer to the irrationality. A PCI-compliant, Level 1 service provider running PA-DSS-validated applications is permitted by the PCI SSC to transmit cardholder data in the clear within a compliant datacenter. Now, we never do something so foolish, but by the PCI SSC’s own standard, our
security methodology has been judged stringent enough to allow us to do it if we desired.
Therefore, such a vendor could receive and/or hold merchants’ cardholder data in the clear, but they can’t decrypt it. Does that make any sense?
Either that vendor’s environment is secure and functional, or it isn’t. We would think that the Level 1 service provider status would prove that it is both secure and functional. If, by the new P2PE standard, we are now judged to be not secure, then the PCI SSC is—by extension—saying its Level 1 Service Provider standard is no longer sufficiently secure, at least for P2PE transactions. If that is true, then no merchant wanting to implement P2PE can currently be secured by a PCI-validated organization.
This seems ill-thought-out by the PCI SSC. Like everything else about this P2PE regulation, it seems reactionary rather than methodical. Now, we can’t be sure, but we have a theory as to why. Our hypothesis is that the council realized P2PE’s scope-reduction capabilities were about to make the PCI SSC all but irrelevant. When properly implemented, P2PE wipes out 10 of the council’s 12 security requirements. And so, while it still had power and clout enough to pull it off, the PCI SSC made a land grab, safely encompassing P2PE within its power before it was robbed of much of that power.
To give the council time to react and think things through, it issued a standard that keeps those organizations with the technology and presence to spread P2PE and its benefits safely out of play. Perhaps that is giving PCI SSC too much credit. It may well have been less malicious or simple ignorance. Either way, refusing to validate equally secure approaches, in my opinion, represents a potential restraint of trade for those in the payments space. It is not a move we take lightly, and we call upon the PCI SSC to immediately act to remedy such restraint or to prepare to face possible litigation.
-Marc
February 8th, 2013 at 11:32 am
As a QSA, (not a P2PE QSA), I’m concerned that there are no listings as pressure builds to validate software encryption solutions that vendors arrogantly push, merchants ignorantly accept and I’m on the hook to confirm a level of confidence in the security. I don’t agree with most of the article as it is very different than what I’ve seen both in the market and actually have read the standard (which is pretty good) but I do share the concern over listings.
February 8th, 2013 at 2:11 pm
DJ, please elaborate. I would like to know what you have seen in the market that contradicts the post. I would also like to know what you found good for merchants in the standard?
February 12th, 2013 at 4:10 pm
So many good points made in this article. The Payment Card Industry Security Standards Council certainly has had its share of shortcomings. I wish someone from the Council would read this article!
February 13th, 2013 at 7:05 pm
P2PE is a dead duck, imho.
Prior guidance for the PCI Council indicated that encrypted data, where the merchant cannot decrypt it (proven absence of keys etc), is out of scope.
All a terminal vendor needs to do is encrypt the payment message payload (SSL anyone?) and accept a token/hashed value in the and they have descoped most / of their internal store network, and maybe head office too.
Head office is always a more complex issue, since cardholder data may be present in other systems besides store payments/EJs/T-Logs.
Encrypting payment message payloads is a national standard in some jurisdictions, rendering the need for P2PE even less pressing.
February 14th, 2013 at 9:11 am
In PCI defense, some of the delays may be related to final approval and publishing of underlying ANS X9.119 part 1 standard. It has only recently received final approval and ANSI approval and publishing is in progress.
That said…
This standard is neither scalable nor sustainable beyond transmission between merchant and acquiring host. Standard does not reduce risk for acquirer to network or issuer because PAN/Track Data must be decrypted for either processing locally or before it can be forwarded to another network or processor (either encrypted or in the clear). For environments where processor must both decrypt PANs/track data and process PINs, this actually increases risk for PIN compromise by enabling PIN processing HSMs commands that decrypt data. Improperly managed key separation would allow PIN blocks to be decrypted, creating a significanly larger gold mine if compromised. Intended purpose of this standard was to provide a mechanism to reduce scope of PCI DSS compliance reviews. In fact, this scope reduction can only occur at the merchant or location where PAN can never decrypted.