Friday, June 17, 2011

How the Stolen Card Market Works

There were a couple of interesting reports on NPR today. Each covers much of the same ground, but they provide some interesting background for all of us in the card business.

Here are a couple of links:

How to Buy a Stolen Credit Card

The FBI Agent who Broke the Black Market

Also, here is a podcast from PlanetMoney with Keith Mularski (same guy) on dark market and the how credit cards get stolen and fenced.

The bad guys are out there. They go for credit cards because (of course) that's where the money is.

Monday, June 13, 2011

PCI Virtualization Guidance Published

The PCI Council's Virtualization Special Interest Group (SIG) just released their report. You can download it here.

I'd recommend it to any school looking at or implementing virtualization in their PCI network.

Thursday, June 2, 2011

News From the PCI Council

As all of you know (I hope), NACUBO is a Participating Organization with the PCI Security Standards Council. As NACUBO's representative, I get a periodic newsletter from the Council with updates and news. Often, these newsletters are pretty dull, but the current one has some interesting information I -- in my role as your representative to the PCI Council -- want to share with you.

There is good news (I hope) for all of you looking at virtualization as potential technology that can make PCI compliance easier and less costly. The good news is that the Virtualization Special Interest Group has delivered its report, and the Council will be releasing it soon. Here are some details from the newsletter:
I know you've all been eager for the Council to release the findings of the Virtualization Special Interest Group (SIG). Thanks to their hard work and collaboration with the Council's Technical Working Group, guidance on the use of virtualization in accordance with the Payment Card Industry Data Security Standard (PCI DSS) will be released this month! We'll be hosting a webinar at the end of June to provide greater detail on the information supplement and address your questions.

To register for the Tuesday, June 28th session, click here.

To register for the Thursday, June 30th session, click here.
Another piece of good news is that the Prioritized Approach 2.0 (to match PCI DSS v 2.0) has been released. There are some good improvements in this version. If you are interested in this or if you wish to use it with the current version of PCI DSS, you can download a copy at the PCI Council's website.

The Council is offering a range of PCI training options. You can view the schedule (and pricing) for their instructor-led and online PCI training courses here. I guess I'd be remiss if I didn't also mention the Treasury Institute's own PCI training. The two are different: the Council focuses on the PCI DSS itself, where the Institute's workshops emphasize hands-on case studies of what other schools have done to become compliant (along with a PCI briefing). The training sessions are complimentary, so even if you have been to the Treasury Institute workshops, it may make sense to check out the Council's offerings.

Lastly, for all you PCI fanboys, you now can follow the comings and goings of the world of PCI on LinkedIn. Click here to follow the Council.

Thursday, May 26, 2011

Visa Chargeback Publication: More than Meets the Eye

I recommend every one of you who is responsible for payments, card processing, PCI for your campus download a copy of Visa's Chargeback Management Guidelines for Merchants (click here). It's a long pdf, but it is worthwhile.

Here are some of my favorite parts, and you'll notice this document (which I first learned about from Branden Williams' excellent blog) has a lot more than just Chargebacks. Actually, it's a pretty good primer on payment cards.
  • Starting on page 10 is a great "Payment Card 101" that describes how a credit or debit card transaction flows through the system. The graphics are a lot slicker than the version I developed when I was at Visa (after all, it has been about 15 years!), and there is good text, too.
  • Page 14 offers a description of "convenience fees." The short answer is "the merchant must [Visa's emphasis] adhere to Visa rules." Want to know what the rules are? Simple... "please contact your acquirer."
  • Also on page 14 is one of my favorite topics: transaction laundering. It says that "Depositing transactions for a business that does not have a valid merchant agreement is called laundering. Laundering is not allowed." That means you don't process for unrelated third parties using your merchant ID. In fact, I wouldn't even allow a third-party merchant on my network. Either it is laundering (I call this "LaunderNet") or you are a Service Provider, and each is bad news from a risk and PCI perspective.
  • Page 15 tells you not to do cash or check refunds for card transactions. You are supposed to issue a credit back to the original card used. Even if it isn't a Visa requirement, this procedure is a good idea since it prevents another form of transaction laundering: charging a transaction with someone else's card (e.g., their parent's or roommate's, with or without permission) then getting a cash refund. Bad news all around.
  • Page 17 talks about your third-party service providers.
  • Check out page 22 for good advice on your POS receipts.
  • Page 35, and later page 80 cover the CVV2 (the security code on the back of the card).
  • And of course, if you actually want to learn more than you ever wanted to know about chargebacks and copy requests, that all starts getting serious around page 41.
That Visa released this to the broader merchant community is to be commended. Good job! so do your part and download it now.

Beware of Changes to SAQ C

Many schools use SAQ C for auxiliaries or other businesses. Sometimes, they will have a point of sale (POS) system that doesn't store cardholder data, but that accesses the Internet for authorizations. If that is you, read on, because a change to PCI v 2.0 may mean you no longer can use SAQ C.

SAQ C previously had five requirements:

  • the payment system and an Internet connection had to be on the same device
  • that device was not connected to any other system in the merchant’s environment
  • the merchant kept only paper reports or receipts
  • the merchant stored no electronic cardholder data
  • remote vendor support was managed securely.

The payoff for meeting these requirements was that a school or campus merchant could qualify to use this simplified SAQ and avoid the much longer, more involved, and significantly more costly process of using SAQ D.

Unfortunately some of you will no longer qualify to use SAQ C. The reason is that SAQ C now includes an additional, sixth requirement:

  • your company store is not connected to other store locations, and any LAN [local area network] is for a single store only.

This change means if your bookstore or food service operation or whatever supports a branch or second (or more) location(s) using their single POS system, they would need to use SAQ D.

The change to SAQ C will affect many universities that have retail or food service operations, and support multiple campus locations with a single POS system. I doubt cashiering operations will be affected very much.

We talked about this issue at the Treasury Institute's recent PCI workshop. I described the changes as part of covering what is new in PCI 2.0. It surprised me how many schools had not noticed the change in the SAQ. I admit it is a subtle change, but it is an important one for a lot of schools. It likely means they either have to license some additional POS applications so they have one for each location, or they are thrown into SAQ D.

If this situation describes your campus, I suggest you get to work on it now and not wait until the last minute. I hate to be the bearer of bad news, but better you should know than get caught up at the last moment

Friday, April 15, 2011

Is Your Website Sending Spam?

I just saw an updated story on how a number of Higher Ed and government sites have been hijacked by spammers. The sites are used to redirect people to fake online stores.

Are you on the list?

According to the original post at Zscaler there seem to be about a hundred schools that have been compromised including (according to them):
  • UC Berekely
  • Harvard
  • Purdue
  • Oklahoma State, and
  • Australian government
The fake stores claim to sell discounted Microsoft and Apple software. Heaven only knows what they are really doing, but the point is that you don't want your institution being part of it.

And the QSA in me has to wonder if parts of the institution's website has been compromised, what about the rest of the site? For example, are you sure your campus merchants who re-direct customers to third-party hosted order pages are really sending them there and not to badguys.com?

Thursday, April 7, 2011

Get Ready for Increased Phishing Attacks on Campus

If the phishing season were not already open, the Epsilon data breach certainly opened it. I recommend two recent articles that you should read and digest.

Over at Threatpost, there is an interview that highlights the vulnerability of higher education institutions. An excerpt is:

Threatpost: What trends are you seeing in the phishing arena these days?

Aaron Higbee: We’re seeing a lot of attacks aimed at verticals like government, financial services, insurance, health care and especially education. You wouldn’t have thought that education would be on that list, but we see a lot of universities targeted.

Threatpost: Why is that?

Aaron Higbee: Students are vulnerable. They’re required to put their Social Security Number into different forms, so they’re susceptible to being phished.

For the best summary of what to expect, surf over to the always informative and insightful blog by Brian Krebs. In this post he assesses the situation and offers some good advice and warnings for your users, particularly staff. This is required reading.

If you ever doubted why PCI requires you segment (read: isolate) your payment environment from other applications and systems in your environment, the Epsilon and RSA data breach should make the wisdom of that requirement clear.

Have a read, then take a look at your own training to make sure you minimize the possible risk to your institution from the expected surge in phishing scams.