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Amazon Confirms EC2/S3 Not PCI Level 1 Compliant
Jason writes "After months of digging though speculation and polar opposite opinions from PCI experts, I finally sent a direct request to Amazon's AWS sales team asking if they are in fact PCI compliant and will provide documentation attesting that they are as is required by PCI guidlines. I fully expecting them to dodge the question and refer me to a QSA, but to my relief, they replied with a refreshingly honest and absolute confirmation that it is currently impossible to meet PCI level 1 compliance using AWS services for card data storage. They also very strong suggest that cardnumbers never be stored on EC2 or S3 as those services are inherently noncompliant. For now at least, the official verdict is if you need to process credit cards, the Amazon cloud platform is off the table."
That is ok, you can just use amazon payments, and probably pay less commissions than you would on your own and not have to worry about storing cc data
I'm glad this was posted to slashdot. Now I know not to buy the EC2 or S3 cards for my machine. I mean, if they're not PCI compliant, I'm going to guarantee they don't have FOSS linux kernel drivers. The PCI spec is so old anyway. Any word on when Amazon will make new boards compliant to PCIE with FOSS drivers? Someone who knows, please post a reply.
Why would you jump through the hoops of processing credit card data yourself, instead of getting one of the many - including, as another poster pointed out, Amazon - credit card processing sites to do it for you?
It's awfully considerate of you to invest large amounts of effort in research to avoid bothering the sales team with, you know, sales inquiries.
It sounds like they really are behind the times. I mean, not even PCI compliant, I'd have expected at least AGP or PCI-X as a bare minimum.
Mind you, I wonder if this is an old story as I'm fairly sure S3 stopped making video cards many years ago.
On another point, I too have often turned to the Queensland Swimming Association for all of my questions about All Women Shortlists, I find they are very knowledgeable.
Requirement 1: Install and maintain a firewall configuration to protect cardholder data
Err.. quite tricky when your machine is a virtual host that you're accessing over the Internet. Whatever firewall you set up, _you_ need to have a way around it. Very few people bother with VPNs or the like; most virtual hosting packages I've seen have FTP and other services open to all. This seriously compromises its security.
Requirement 4: Encrypt transmission of cardholder data across open, public networks
Most web development companies I've worked with always want to transfer data around over unencrypted FTP, often including database backup files. The chances are, if you have a subcontractor handling your e-commerce web site, they're violating this requirement on a regular basis.
Requirement 5: Use and regularly update anti-virus software
Oh, yeah. Everyone has antivirus installed on their web servers. Wait... you mean they don't? What's this Linux thing?
Requirement 6: Develop and maintain secure systems and applications
Ha!
Requirement 9: Restrict physical access to cardholder data
Somewhat difficult when you're not hosting the system yourself, so this requirement can only be met by less than 1% of e-commerce retailers out there.
Requirement 11: Regularly test security systems and processes
When was the last time you performed a penetration test on your network?
There are dozens of requirements that EC2 will never ever be able to fulfil. It's just not possible. Take requirements for network segregation. The machines with cardholder data must be on a separate vlan with no direct access to the outside, in or out. There are physical requirements not just for the datacenter (locked racks, surveillance cameras), but for the workstations.
It's just impossible to do that on EC2 or anything like it.
In any case, you don't want to manage cardholder data. Leave it to someone who is willing to go through the trouble.
"As for PCI level 2 compliance, that requires external scanning via a 3rd party, PCI-approved vendor. It is possible for you to build a PCI level 2 compliant app in our AWS cloud using EC2 and S3, but you cannot achieve level 1 compliance. And you have to provide the appropriate encryption mechanisms and key management processes. "
There seems to be a dangerous misunderstanding about PCI validation requirements in the reply from Amazon. There's no such thing as "level x compliance", the levels refer to merchant levels set by the acquirer. The merchant level is determined by the volume of credit card transactions for a single card brand (e.g. Visa). The actual security requirements for all 4 merchant levels are EXACTLY the same, the only difference is how the compliance has to be validated. Level 1 merchants are required to perform an on-site audit by a QSAP annually, whereas the other levels only require filling a self-assessment questionnaire (SAQ) once a year. Quarterly vulnerability scans by an ASV are required for all levels except 4, where they are optional.
We looked into this at one point: got details on the audit, etc. Technically, it seemed to be a pretty trivial check of your systems. As I recall, you also had to agree to pay for a annual remote check - basically a port scan - which also cost a pretty penny.
Basically, it's a way of raking in money. Of course, the people who go through with the audit wind up passing the costs on to consumers. This is in addition to the transaction costs of 3-4%, the transaction processing costs, the fees paid by the consumers, etc, etc.
Can we please find a secure way of using direct debit, so we can cut the credit-card companies out of the loop?
Enjoy life! This is not a dress rehearsal.
The remote check is just one tiny part of it. You also need an internal check of the network every three months.
You need a web application firewall.
You need to log every single change on the server configs.
You need an IDS.
You need file integrity monitoring for the logs.
You need to backup the log.
You need multi factor authentification.
And so on and so forth.
You could be mislead while perusing the doc, because the really hard parts are not contrasted with the trivial ones ("run an antivirus"), and if you don't know what they entail, you could confuse them with something much harder. Take network segregation; at last count we have about a dozen VLANs.
A connection to our intranet goes through 7 of them, one each for the SSL front end, Web app firewall, web server, app server, web database, which is fed sanitized data from a database that is, in turn, twice removed from the cardholder application itself. Application that doesn't even talk directly to either terminals or banks, they go through at least one proxy, on another vlan.
This is not spelled out in the PCI standard, but was the only to respect it.
This is in addition to the transaction costs of 3-4%, the transaction processing costs, the fees paid by the consumers, etc, etc.
That number is a bit high, you can get a much better deal if you have a million TX a year, I think.
Can we please find a secure way of using direct debit, so we can cut the credit-card companies out of the loop?
Card hardware companies are currently all working on end-to-end encryption, whereby no unencrypted data will be stored anywhere between the card itself and the bank.
But that would require smart cards, something we've had here since, oh, 1989 (I've never had a card without a chip). And that doesn't cover card-not-present use cases. As long as you have to store any clear text card numbers, you'll have to abide by PCI, I'm afraid.
All considered, PCI is a very good thing. I was skeptical at first but no one would be doing a tenth of what's needed without it.
PCI: Payment Card Industry. The full acronym should be PCI DSS for Payment Card Industry Data Security Standard.
AWS: Amazon Web Services, an API offered by Amazon to allow access to their internal back-end.
QSA: Quality Security Assesors, security firms certified by the PCI council to audit payment card processors.
EC2: Elastic Computing Cloud, Amazon's virtualized hosting system.
S3: Simple Storage Service, Amazon's cheap web-based storage.
Cheers!
-dZ.
Carol vs. Ghost
Sir, if you want to write a better security standard that can easily be applied to every operating system from embedded payment terminals to Windows NT3 to AIX, every environment from a cloud-hosted webshop to ones consisting of hundreds of datacenters or a chain of tens of thousands of stores around the planet, and be easily applied to every piece of commercial or custom software on the planet, yet still include specific settings for certain versions of Apache and Joomla, go right ahead.
For example, PCI argues that credit card information should never be stored on a server.
"3.1 Keep cardholder data storage to a minimum. Develop a data retention and disposal policy. Limit storage amount and retention time to that which is required for business, legal, and/or regulatory purposes, as documented in the data retention policy.
In other words, it does not say that. In fact, the whole requirement 3 deals with how to secure stored cardholder data.