Global Security, Privacy, & Risk Management

FTC to Audit PCI Industry March 9, 2016

(UPDATED) I have been in the PCI “industry” since before it was an industry.  I was fortunate to have worked with Visa in 2001 on a team that helped design the CISP requirements for Service providers and subsequently worked at MasterCard a major processor and numerous QSA firms.  I can claim (along with 2 or 3 other people) to be the FIRST assessor even before we were QDSPs then QSAs. I was the PCI SSC’s global QSA trainer and Visa’s CISP trainer.  There probably only 10 people in the industry that have been doing “PCI” type work as long as I have.  Unfortunately, we lost two of those fine folks in the last several years.  One of the most frustrating aspects of being in the PCI assessment business has been competing with the “pay and stamp” assessors.  PCI is complex and conducting a solid PCI assessment is complex and not trivial. There have always been the “bottom feeders” that will guarantee a compliant finding for a nominal  fixed price fee.  For those companies that do solid work (while I compete with them I am also friends with many and can respect their work as much as my own employers) we often find ourselves on the losing end of a bid when someone agrees to assess a Fortune 100 company for a Fixed fee of $40K.  Well..the Federal Trade Commission has taken notice!

The FTC has issued an order to 9 QSA firms to assess (pun intended) how they assess companies against the PCI DSS and how their business is structured. The 9 companies listed are:

Foresite MSP, LLC; Freed Maxick CPAs, P.C.; GuidePoint Security, LLC; Mandiant; NDB LLP; PricewaterhouseCoopers LLP; SecurityMetrics; Sword and Shield Enterprise Security, Inc.; and Verizon Enterprise Solutions (also known as CyberTrust).

Here is my beef with that list.  The one company (to remain un-named for fear of a lawsuit..but we all know who it is)..that has had 7 or so of the largest credit card breaches in history as it’s clients is not listed.  3 of the companies are ‘newbys’ and 3 are very well known and respected companies.  They should have asked for “Chris’ list” 😉

After reading the order it is clear the FTC has done their homework and knows the answers they expect to get.  This is not simply smoke and mirrors.  They are asking questions related to:

1. The bidding process for QSA work
2. Cost structure of PCI assessment work
3. Time associated with the average assessment
4. number of companies found ‘non compliant’
5. Whether a company is found ‘compliant’ BEFORE completing all work.
6. Sampling methodology (this is a gotcha because the required methodology is outlined in the training)
7. Qualifications

They are then asking for a sample ROC to be provided.  I cannot applaud the FTC enough for taking this step.  It is well past time that we get the “pay and stamp” providers  out of the industry! Read the Order Here!