Wednesday, July 22, 2009

PCI Wireless Insanity

I'm not sure if this de-thrones what I previously referred to as the Stupidest PCI Requirement Ever, but it's close. Sometimes the PCI people are flat-out crazy, maybe stupid even. This is another example of when.

Fresh off the presses, the PCI Security Standards Council has just released (on July 16th) a 33 page wireless guidance document that explains in detail just exactly what requirements a PCI compliant organization MUST meet in the PCI DSS. (The wireless document is here.) A few things to highlight in that document ...

1. EVERYONE must comply with the wireless requirements. There's no getting out of it just because you do not use wireless:
"Even if an organization that must comply with PCI DSS does not use wireless networking as part of the Cardholder Data Environment (CDE), the organization must verify that its wireless networks have been segmented away from the CDE and that wireless networking has not been introduced into the CDE over time. " (page 9, first paragraph)
2. That includes looking for rogue access points:
"Regardless of whether wireless networks have been deployed, periodic monitoring is needed to keep unauthorized or rogue wireless devices from compromising the security of the CDE." (page 9, third paragraph)
3. Which could be ANYWHERE:
"Since a rogue device can potentially show up in any CDE location, it is important that all locations that store, process or transmit cardholder data are either scanned regularly or that wireless IDS/IPS is implemented in those locations." (page 10, third paragraph)
4. So you cannot just look for examples:
"An organization may not choose to select a sample of sites for compliance. Organizations must ensure that they scan all sites." (emphasis theirs, page 10, fourth paragraph)
5. So, how in the world can you implement this?
"Relying on wired side scanning tools (e.g. tools that scan suspicious hardware MAC addresses on switches) may identify some unauthorized wireless devices; however, they tend to have high false positive/negative detection rates. Wired network scanning tools that scan for wireless devices often miss cleverly hidden and disguised rogue wireless devices or devices that are connected to isolated network segments. Wired scanning also fails to detect many instances of rogue wireless clients. A rogue wireless client is any device that has a wireless interface that is not intended to be present in the environment." (page 10, sixth paragraph)
6. You have to monitor the air:
"Wireless analyzers can range from freely available PC tools to commercial scanners and analyzers. The goal of all of these devices is to “sniff” the airwaves and “listen” for wireless devices in the area and identify them. Using this method, a technician or auditor can walk around each site and detect wireless devices. The person would then manually investigate each device." (page 10, seventh paragraph)
7. But that's time consuming and expensive to do:
"Although [manually sniffing the air] is technically possible for a small number of locations, it is often operationally tedious, error-prone, and costly for organizations that have several CDE locations." (page 11, first paragraph)
8. So, what should an enterprise-grade organization do?
"For large organizations, it is recommended that wireless scanning be automated with a wireless IDS/IPS system." (page 11, first paragraph)

In other words, you must deploy a wireless infrastructure at each location where cardholder data may exist, because that's what it takes to implement a wireless IDS. You must, at least, deploy an access point operating as a beacon to monitor the airwaves. But that has all the same (or more) costs that just using wireless in the first place has. So you might as well deploy wireless at each location. At least for now, the document does go on to indicate that wireless scans can still be performed quarterly and that a wireless IDS/IPS is just a method of automating that process. I will not be surprised to see a later revision demand full-time scanning via an IDS/IPS, ditching the once-every-90-days current requirement.

Apparently, one or more of the following are true:
  • The PCI Security Council are not of the ilk of security practitioners that believe in not deploying wireless as a measure of increasing security, because clearly they want you to buy wireless equipment-- and lots of it.
  • The PCI Security Council are receiving kickbacks from wireless vendors who want to sell their wares even to customers outside of their market and forcing wireless on all PCI merchants is a means to achieve that goal.
  • The PCI Security Council does not believe merchants will ever band together to say "enough is enough".
  • The PCI Security Council are control freaks with megalomaniacal (want to dictate the world) tendencies.

The irony here is that the PCI Security Council is paranoid extremely concerned about the use of consumer-grade wireless data transmission equipment in a credit card heist. By that, I mean they are concerned enough to mandate merchants spend considerable time, energy, and dollars on watching to make sure devices that communicate on the 2.4 GHz and 5 GHz spectrums using IEEE 802.11 wireless protocols are not suddenly introduced into cardholder data environments without authorization. What's next on this slippery slope? What about the plausibility of bad guys modifying rogue access point equipment to use non-standard ranges of the wireless spectrum (Layer 1 -- beware the FCC!) or modifying the devices' Layer 2 protocols to not conform to IEEE 802.11? The point is, data can be transmitted beyond those limitations!

[Imagine a conspiracy theory in which wireless hardware manufacturers are padding the PCI Security Council's pocketbooks to require wireless devices at every merchant location, while at the same time, the wireless hardware manufacturers start producing user-programmable wireless access points in a pocket-sized form factor to enable the credit card skimming black market to evade the 2.4/5 GHz and 802.11 boundaries in which a merchant has been dictated they must protect.]

There are no published breach statistics (that I am aware of) that support this type of nonsensical approach.

To make matters worse, in PCI terms, an organization is non-compliant IF a breach CAN or DOES occur. In other words, the PCI Data Security Standards (DSS) are held in such high regard that they believe it is impossible to both comply with every requirement contained within them AND experience a breach of cardholder data. In the case of these new wireless explanations of requirements (because the PCI Security Council will argue these requirements already existed, this is just a more elaborate explanation of them), if an organization experienced a breach, and previously had an accepted Report On Compliance (RoC) based on wired scanning for rogue wireless devices, they will be immediately considered out-of-compliance and thus have to pay the higher fines for non-compliance that all out-of-compliance organizations face.

Ah, what fun the PCI Security Council has dropped on merchants this month!



The academic security research community will find this interesting, because what the PCI Security Council is trying to do is prevent "unintended channels" of information flow. This is very difficult (if not computationally impossible-- such as Turing's Halting Problem). Even more difficult may be to detect "covert channels" which are an even more tricky subset of "unintended channel" information flow problems. What's next, PCI mandating protection against timing-based covert channels?

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