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The 13th Requirement

September 1st, 2010

Now, at long last and after much personal expense and toil, I am proud to bring to you the fabled 13th Requirement of PCI DSS. Long rumored to exist, I recently managed to wrest these from the dank basement stronghold of a Masonic Lodge in Milwaukee, while dodging capture by their roaming guard of free-range chickens (those things are DANGEROUS!).

Just as you would expect, this is essentially the Rosetta Stone of PCI. All the confusion, all the gray areas that weren’t clear, all the ambiguous references to technology and technical specifications – cleared up with one section that the Council did not want you to ever see. So, without fail, I give you – Requirement 13.

Requirement 13: It’s somebody else’s problem.

13.1 PCI Merchants and Service Providers, under no circumstances, should take responsibility for sound information security practices and satisfactory compliance status.

13.1.1 PCI Compliance is the QSA’s problem. Never admit that you’re doing anything wrong, or that your practices are not sound.

13.1.2 If a passing ROC cannot be obtained from your QSA, attempt to discredit him/her and their organization.

13.1.3 If a passing ROC is obtained, but is completely bogus (see section 13.2.2, “Rubber Stamping”), and an incident/compromise occurs, attempt to discredit him/her and their organization.

13.2 Qualified Security Assessors will claim to be objective, but in actuality will be subjective based on prior knowledge, perception of customer, and QSA consulting firm contracts and business needs.

13.2.1 PCI Compliance is the customer’s problem. Never imply that anyone but the customer is directly and wholly responsible for all facets of PCI compliance, regardless of whether the QSA has a clue about the technology, business processes, or CHD flow.

13.2.2 As long as sufficient “evidence” of controls can be provided, keeping the customer happy and paying the bills should be the QSA’s primary concern. This is often referred to as “rubber stamping,” and is often encountered when merchants and service providers prioritize compliance over actual security measures that meet best practices.

13.2.3 Neither the PCI Council nor the payment card brands will offer the slightest assistance throughout the course of the PCI assessment. Verbal “blame shifting” is acceptable when clients demand specific answers.

13.2.4 In the case that a client is compromised, or experiences a breach of CHD, a QSA must never admit fault. Disavow all knowledge of the technical or procedural shortcomings that may have led to the breach, and strongly insinuate that the client may have been “hiding” things during the assessment.

Well. Hope this clears things up. 🙂

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