What To Do If Compromised

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What To Do If Compromised

Visa Europe Data Compromise Procedures

March 2011

Version 5.0 (Europe)

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Version Date Description 1.0 June 2009 Initial Version

2.0 March 2010 Reviewed

3.0 May 2010 Appendix B date for completion added 4.0 December

2010

References changed to Data Compromise team and Appendices A & B updated

5.0 March 2011 Updated with information on PCI SSC PCI Forensic Investigator (PFI) programme

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Introduction

What constitutes a security incident? The answer to this question is crucial to any organisation looking to minimise the impact an incident might have on its business operations.

In general, incidents may be defined as deliberate electronic attacks on communications or information processing systems. Whether initiated by a disgruntled employee, a malicious competitor, or a misguided hacker, deliberate attacks often cause damage and disruption to the payment system. How you respond to and handle an attack on your company’s information systems will determine how well you will be able to control the costs and consequences that could result. For these reasons, the extent to which you prepare for security incidents, and work with Visa Europe, will be vitally important to the protection of your company’s key information.

In the event of a security incident, Visa Europe members and their agents must take immediate action to investigate the incident, limit the exposure of cardholder data, notify Visa Europe, and report investigation findings to Visa Europe.^*

The What To Do If Compromised guide is intended for Visa Europe members (i.e., acquirers and issuers), merchants, agents, and third-party service providers. It contains step-by-step instructions on how to respond to a security incident and provides specific time frames for the delivery of information or reports outlining actions taken by Visa Europe, its members, and its agents.

In addition to the general instructions provided here, Visa Europe may also require an investigation that includes, but is not limited to, access to premises and all pertinent records including copies of analysis.

*Visa Europe Operating Regulations--- Section 2.1, General Security Requirements, Section 2.1.E.3, Loss or Theft of Account or Transaction Information, Section 2.1.E.4, Investigations and Section 2.1.E.5, Member Co-operation.

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Identifying and Detecting Security Breaches

It is often difficult to detect when a system has been attacked or an intrusion has taken place. Distinguishing normal events from those that are related to an attack or intrusion is a critical part of maintaining a secure payment processing environment.

Security breaches come in many different forms and, while detecting them may be challenging, there are certain signs that tend to appear when a security breach has occurred:

• Unknown or unexpected outgoing internet network traffic from the payment card environment

• Presence of unexpected IP addresses on store and wireless networks

• Unknown or unexpected network traffic from store to headquarter locations

• Unknown or unexpected services and applications configured to launch automatically on system boot

• Unknown files, software and devices installed on systems

• Anti-virus programs malfunctioning or becoming disabled for unknown reasons

• Failed login attempts in system authentication and event logs

• Vendor or third-party connections made to the cardholder environment without prior consent and/or a trouble ticket

• SQL Injection attempts in web server event logs

• Authentication event log modifications (i.e., unexplained event logs are being deleted)

• Suspicious after-hours file system activity (i.e., user login or after-hours activity to Point-of-Sale (‘‘POS’’) server)

• Presence of .zip, .rar, .tar, and other types of unidentified compressed files containing cardholder data

• Presence of a rootkit, which hides certain files and processes in, for example, Explorer, the Task Manager, and other tools or commands

• Systems rebooting or shutting down for unknown reasons

• If you are running Microsoft, check Windows registry settings for hidden malicious code. (Note: Make sure you back up your registry keys before making any changes and consult with Microsoft Help and Support).

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Attack Vectors

The following are examples of attack vectors that hackers use to gain unauthorised access to organisation’s systems and steal sensitive information, such as payment card data and passwords.

SQL Injection Attacks

SQL injection is a technique used to exploit Web-based applications that use member-supplied data in SQL queries. SQL injection attacks can occur as a result of unpatched Web servers, improperly designed applications (i.e, incorrectly filtered escape characters or error-type handling) or poorly configured Web and database servers.

The SQL attack methods most recently detected were targeted against Websites and Web applications that were improperly designed or resided on unpatched systems, making them susceptible to attack. These latest SQL injection attacks pose serious additional risks to cardholder data stored or transmitted within systems (e.g., Microsoft and UNIX-based) and networks connected to the affected environment.

Improperly Segmented Network Environment

Payment card account information has been compromised at organisations that lack proper network segmentation. This attack method originates on the Internet, resulting in penetration to the organisation’s payment card environment and often leading to costly remediation efforts and increased fraud attacks. Such compromises can often be prevented if the organisation’s networks are properly segmented, limiting intruders to non-sensitive parts of the network that do not contain payment card information.

Network segmentation is a concept that refers to the practice of splitting a network into functional segments and implementing an access control mechanism between each of the boundaries. The most common example of network segmentation is the separation between the internet and an internal network using a firewall/router.

Malicious Code Attacks

Malicious codes or malware can be programs such as viruses, worms, Trojan applications, and scripts used by intruders to gain privileged access and capture passwords or other confidential information (e.g., user account information).

Malicious code attacks are usually difficult to detect because certain viruses can be designed to modify their own signatures after inflicting a system and before spreading to another. Some malicious codes can also modify audit logs to hide unauthorised activities.

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In recent investigations, Visa Europe has identified malicious codes designed to capture payment card data. These are examples of malicious code attacks:

• Malware that allows interactive command shell or backdoor. This type of malware allows an intruder to run commands to the compromised system. In some cases, the malware is hard-coded with the intruder’s Internet Protocol (‘‘IP’’) address.

• Packet sniffers. Packet sniffing is the practice of using computer software or hardware to intercept and log traffic passing over a computer network. A packet sniffer, also known as a network analyser or protocol analyser, captures and interprets a stream or block of data (referred to as a ‘‘packet’’) travelling over a network.

Packet sniffers are typically used in conjunction with malicious software or malware. Once intruders gain entry into a critical system using backdoor programs or deploying rootkits, the sniffer programs are installed, making the malware more difficult to detect. Intruders can then ‘‘sniff’’ packets between network users and collect sensitive information such as usernames, passwords, payment card data or Social Security numbers. Once a critical system or network is compromised, sniffers are used to eavesdrop or spy on network users and activity. This combination of tools makes this attack scheme effective in compromising systems and networks.

• Key logger malware. Key logging is a method of capturing and recording keystrokes. There are key logger applications that are commercially available and are used by organisations to troubleshoot problems within computer systems. Visa Europe investigations reveal that there are key logger applications that are developed by intruders to capture payment card data and/or users credentials, such as passwords. The key logger captures information in real time and sends it directly to the intruder over the Internet.

Additionally, newer advances provide the ability to intermittently capture screenshots from the key logged computer.

Key logger malware are widely available via the Internet and can be installed on virtually any operating system. Key loggers, like most malware, are distributed as part of a Trojan horse or virus, sent via e-mail (as an attachment or by clicking to an infected web link or site) or, in the worst case, installed by a hacker with direct access to a victim’s computer.

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Insecure Remote Access

Many Point-of Sale (‘‘POS’’) vendors, resellers and integrators have introduced remote access management products into the environments of organisations that they support. A variety of remote access solutions exists, ranging from command-line based (e.g., SSH, Telnet) to visually-driven packages (e.g., pcAnywhere, Virtual Network Computing, Remote Desktop). The use of remote management products comes with an inherent level of risk that may create a virtual backdoor on your system. The exploitation of improperly configured and unpatched remote management software tools is the method of attack most frequently used by hackers against POS payment systems. An improperly configured system can be vulnerable in the following ways:

• Failure to regularly update or patch a system can render the system vulnerable to exploits that defeat the security mechanisms built into the product.

• Lack of encryption or weak encryption algorithms can lead to the disclosure of access credentials.

• Use of default passwords can provide easy access to unauthorised individuals.

• Disabled logging mechanisms eliminate insight into system access activity and signs of intrusion.

Insecure Wireless

The adoption of wireless technology is on the rise among participants in the payment industry; particularly merchant retailers, many of whom use wireless technology for inventory systems or check-out efficiency (e.g., ‘‘line busting,’’

ringing up customers while they are in line). Wireless technologies have unique vulnerabilities; organisations must carefully evaluate the need for such technology and understand the risks, as well as the security requirements, before deploying wireless systems.

Following are some of the common methods used to attack wireless networks.

These methods are widely documented on the Internet, complete with downloadable software and instructions.

• Eavesdropping --- An attacker can gain access to a wireless network just by

‘‘listening’’ to traffic. Radio transmissions can be freely and easily intercepted by nearby devices or laptops. The sender or intended receiver has no means of knowing whether the transmission has been intercepted.

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• Rogue Access --- If a wireless Local Area Network (LAN) is part of an enterprise network, a compromise of the LAN may lead to the compromise of the enterprise network. An attacker with a rogue access point can fool a mobile station into authenticating with the rogue access point, thereby gaining access to the mobile station. This is known as a ‘‘trust problem,’’ and the only protection against it is an efficient access-authentication mechanism.

• Denial of Service (DOS) --- Due to the nature of radio transmission, wireless LANs are vulnerable to denial-of-service attacks and radio interference. Such attacks can be used to disrupt business operations or to gather additional information for use in initiating another type of attack.

• Man-in-the-Middle (MITM) --- Packet spoofing and impersonation, whereby traffic is intercepted midstream then redirected by an unauthorised individual for malicious purposes, are also valid threats.

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Steps and Requirements for Compromised Entities

Entities that have experienced a suspected or confirmed security breach must take prompt action to help prevent additional exposure of cardholder data and ensure compliance with the Payment Card Industry Data Security Standard (PCI DSS) and PCI Payment Application Data Security Standard (PA-DSS)^†.

1. Immediately contain and limit the exposure. Minimise data loss. Prevent the further loss of data by conducting a thorough investigation of the suspected or confirmed compromise of information. Compromised entities should consult with their internal incident response team. To preserve evidence and facilitate the investigation:

o Do not access or alter compromised system(s) (i.e., don’t log on at all to the compromised system(s) and change passwords; do not log in as ROOT).

o Do not turn the compromised system(s) off. Instead, isolate compromised systems(s) from the network (i.e., unplug network cable).

o Preserve logs (i.e., security events, web, database, firewall, etc.).

o Log all actions taken.

o If using a wireless network, change the Service Set Identifier (SSID) on the wireless access point (WAP) and other systems that may be using this connection (with the exception of any systems believed to be compromised).

o Be on ‘‘high’’ alert and monitor traffic on all systems with cardholder data.

†Visa Europe Operating Regulations--- Section 2.1, General Security Requirements; Section 2.1.E.3, Loss or Theft of Account or Transaction Information; Section 2.1.E.4, Investigations; and Section 2.1.E.5 Member Co-operation.

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2. Alert all necessary parties immediately:

o Your internal incident response team and information security group.

o If you are a merchant, contact your merchant bank.

o If you do not know the name and/or contact information for your merchant bank, notify Visa Europe Data Compromise Team Manager immediately:

- +44 (0) 20 7795 5453 or datacompromise@visa.com

If you are a financial institution, contact Visa Europe at the number provided above.

3. Notify the appropriate law enforcement agency.

4. Provide all compromised Visa, Interlink, and Plus accounts to the Visa Europe acquiring bank or to Visa Europe within seven (7) business days. All potentially compromised accounts must be provided and transmitted as instructed by the Visa Europe acquiring bank and Visa Europe. Visa Europe will distribute the compromised Visa account numbers to issuers and ensure the confidentiality of entity and non-public information.

5. Within three (3) business days of the reported compromise, provide a Compromised Entity Details Report to the Visa Europe member or to Visa Europe. (See Appendix A, on page 16, for the Compromised Entity Details Report template.) If you are a financial institution, provide the Compromised Entity Details Report to Visa Europe.

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Steps and Requirements for Visa Europe Members (Acquirers and Issuers)

Notification 1. Immediately report to Visa Europe the suspected or confirmed loss or theft of Visa cardholder data. Members must contact Visa Europe Data Compromise Management at the secure email address datacomp@visaonline.com.

2. Advise Visa Europe whether the entity was in compliance with PCI DSS and, if applicable, PCI PA-DSS at the time of the incident. If so, provide appropriate proof.

3. Ensure that the compromise has been contained to prevent future loss or theft of account information.

4. Ensure that the law enforcement agencies are informed, if appropriate, to comply with national law.

Preliminary Investigation

5. Within three (3) business days perform an initial investigation and provide Visa Europe with a completed Compromised Entity Details Report (Appendix A^‡) that should be sent to the secure email address datacomp@visaonline.com.

6. The information provided will help Visa Europe understand the potential exposure and assist entities in containing the incident. Documentation must include the steps taken to contain the incident.

FOR MORE INFORMATION

To find out more about conducting an initial investigation, see Appendix A: Initial InvestigationRequest on page 16.

Account Numbers

7. Within 7 (seven) business days from the initial notification provide ‘‘at risk’’ account numbers to Visa Europe, these should be sent to the secure email address datacomp@visaonline.com.

‡ If entity compromised is a direct connect to Visa, please complete Appendix F.

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Forensic Investigation

Determine if a forensic investigation is required or not.

8. If the incident involves more that 10,000 accounts at risk, based on the exposure period defined by the issuers’ fraud reporting, it is required that a forensic investigation is completed.

9. If less than 10,000 accounts at risk, acquirer must complete an Acquirer Investigation Report (Appendix B) and send it to Visa Europe within 21 days from initial notification at the secure email address datacomp@visaonline.com.

10. This must include a detailed reason why it has been determined that a forensic investigation is not required and how the compromise has been contained.

If an entity has a public IP address, the acquirer must initiate a remote vulnerability scan by a PCI SSC approved scan vendor. A list of approved scan vendors is available on www.pcisecuritystandards.org

The acquirer must ensure that compromised entity has passed the scan.

11. If a forensic investigation is required the acquirer must ensure that a PCI Forensic Investigator (PFI) is engaged to perform the forensic investigation.

List of PCI Forensic Investigators (PFIs) -

https://www.pcisecuritystandards.org/approved_companies_providers/pfi_compa nies.php

For more information on the PCI SSC’s PFI programme please use the link below:

PFI Supplementary Requirements -

https://www.pcisecuritystandards.org/security_standards/documents.php?d ocument=PFI_Supplemental_Requirements#PFI_Supplemental_Requirements 12. Visa Europe reserves the right to insist upon a forensic investigation if

deemed necessary, irrespective of the number of accounts at risk.

13. If an independent forensic investigation is required, members must:

o Identify the PFI within seven (7) business days of initial notification of a suspected compromise.

o Ensure that the PFI is engaged (or the contract is signed) within ten (10) business days initial notification of a suspected compromise.

o The PFI must be onsite to conduct a forensic investigation within five (5) business days from the date the contract agreement is signed.

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14. The Visa Europe member must ensure that there is no conflict of interest for the PFI and must ensure that the PFI did not certify any of the Payment Applications being used by the compromised entity or having undertaken the PCI DSS audit for the compromised entity. The Visa Europe member should engage the PFI directly. However, Visa Europe, has the right to engage a PFI to perform a forensic investigation as it deems appropriate, and will assess all investigative costs to the member in addition to any fine that may be applicable.

15. Within five (5) business days from the onset of the forensic investigation provide a Preliminary Incident report (Appendix C) to Visa Europe. This

report should be sent to secure email address

datacomp@visaonline.com.The report should contain identification of any further account numbers that are at risk, details of how the compromise has been contained, estimated time to complete the full investigation. If further account numbers have been identified they should be sent to the secure email address datacomp@visaonline.com.

16. Within ten (10) business days from the completion of the forensic investigation provide a Final Forensic report to Visa Europe. This report should be sent to secure email address datacomp@visaonline.com.

Containment/

Remediation

17. Ensure that the compromised entity has contained the incident and has implemented security recommendations provided by the PFI, including any non-compliance with the PCI PIN Security Requirements.

18. Within 30 days from notification by Visa Europe, if the entity is retaining full-track data, CVV2, and/or PIN blocks, submit confirmation that the entity has removed the data (this includes any historical data). This should be sent to datasecuritystandards@visa.com.^§

19. Validate that full-track data, CVV2, and/or PIN blocks are no longer being stored on any systems. Even though this is the member’s responsibility, Visa Europe requires that the validation be performed by the PFI.

20. Within 90 days of the notification from Visa Europe, confirm that sufficient remediation has been completed. This should be sent to datasecuritystandards@visa.com. If required by Visa Europe, members must provide a remediation plan with implementation dates related to findings identified by the PFI. ^**

§Visa Europe Operating Regulations--- Section 1.6 Regulation Enforcement, Section 1.6.D.24.f Account Information Security Program.

**Visa Europe Operating Regulations--- Section 1.6 Regulation Enforcement, Section 1.6.D.24.e Sufficient remediation

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21. A revised remediation plan must be provided to Visa Europe, if requested.

22. Monitor and confirm that the compromised entity has implemented the action plan.

PCI DSS Compliance

23. Ensure that the compromised entity achieves full PCI compliance by adhering to the PCI DSS and, if applicable, PCI PA-DSS. Compliance validation is required per Visa EuropeOperating Regulations (Section 2.1.E).

KEY POINT TO REMEMBER

Please visit www.pcisecuritystandards.org for more information on PCI DSS and the PCI PIN Entry Device Testing Program.

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Requirements for Account Data Requests

In the event of a compromise, Visa Europe requires that ‘‘at risk’’ accounts be provided to Visa Europe through the secure email address datacomp@visaonline.com.

In some cases, Visa Europe may require the entity to provide accounts via a CD using encryption software such as PGP^†† or Winzip^‡‡with 256-AES encryption and strong password. The following guidelines must be followed when providing accounts to Visa Europe.

Account Data Format

• File submitted must be a plain-text, comma delimited file containing account numbers and expiration dates. For example:

--- The card number, followed by a comma, followed by the expiration date in YYMM format:

4xxxxxxxxxxx1234,0801

Visa Europe may require additional data for further fraud analysis and will inform the compromised entity and the Visa Europe member if additional data is required.

1. Submitted data should be limited to one file. In cases where one file isn’t possible, make every effort to minimize total file counts. If multiple files are provided, all of them MUST be consistent (i.e., they MUST contain the same formatting and transaction details).

2. The windows of exposure or period of compromise must be indicated with the file containing the accounts at risk.

Visa accounts copied to a CD or other removable media must be encrypted using PGP or Winzip with 256-AES encryption with strong password.

†† PGP (Pretty Good Privacy) is a computer program that provides cryptographic privacy and authentication. For more information on PGP, go to www.pgp.com.

‡‡ WinZip is a data compression utility with the ability to compress using 256-AES encryption. For more information on WinZip, go to www.winzip.com.

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Visa Account Bulletin (VAB)

The Visa Account Bulletin (VAB) service offers a secure and efficient way for Visa Europe issuers to view compromised and recovered account data received by Visa from acquirers, processors, PFIs and law enforcement agencies. Each member organisation will receive an alert if they have accounts affected in order to implement their own initiatives for fraud reduction.

On receipt of a VAB alert, issuers should analyse the card accounts reported.

Based on the results of this analysis, issuers can either block and re-issue, or flag the accounts (either manually or through an automated facility) so that future authorisations are viewed with more scrutiny and a more strict set of approval parameters is applied.

The VAB service can be located in the Fraud, Security & Risk section in Visa Online and the Visa Account Bulletin subsection.

To register for VAB alerts issuers will need to contact their Visa Online Access Manager (VAM). To find out whom your VAM is please contact Customersupport@visa.com.

To receive e-mail notifications advising you when VAB alerts are published which include your card ranges please add your details in the Fraud Contact List within VAB .

For further information regarding VAB Visa Europe members can access the VAB Best Practices document published on Visa on Line under the Global Fraud Information Service/ Latest News. Member can also obtain a copy of the VAB User Guide. Please contact our customer support team on Customersupport@visa.com.

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Appendix A: Compromised Entity Details Template

Upon notification of a suspected account data compromise, Visa Europe will request that the Visa Europe member initiate a preliminary investigation of any entity involved in a potential cardholder data compromise.

To comply with Visa Europe’s initial investigation request, the Visa Europe member must provide the following information.

The information required below is applicable to suspected/confirmed compromised entities such as Visa Europe members, merchants, processors, or third-party service

providers.

Compromise

Entity Details

Compromise Entity Details

Information to be provided by the Acquirer within 3 business days.

Entity Details

DESCRIPTION RESPONSE

Acquirer name:

Visa Europe Case Reference:

Entity name:

Entity Address:

If a merchant, MCC:

Acquiring BIN:

E-commerce merchant: Yes/No

POS transactions: Yes/No

Entity PCI DSS Validation Level: 1/2/3/4

(before the compromise)

Is entity a direct connect to Visa: Yes/No * Entity PCI DSS Compliance status:

Name of Service Provider or Hosting Provider:

If merchant, date entity began processing with

acquirer:

If merchant, date entity stopped processing with acquirer (if applicable):

Approximate number of

transactions/accounts handled per year

1) ATM:

2) POS:

3) e-commerce:

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Compromised Entity Details

* If Yes, please complete Appendix F – Request for Information-External Compromise

Data Elements at Risk:

Account Number: Yes/No

Expiration Date: Yes/No

CVV2: Yes/No

Track 1: Yes/No

Track 2: Yes/No

PIN: Yes/No

Cardholder name/address: Yes/No Number of Visa Cards affected:

Window of Exposure or Period of

Compromise:

Steps taken to contain the compromise:

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Appendix B: Acquirer Investigation Report Template

If the incident has less than 10,000 accounts at risk a forensic investigation may not be required. However, the acquirer must complete an Acquirer Investigation Report and include a detailed reason why it has been determined that a forensic investigation is not required and how the compromise has been contained.

Acquirer must complete this report within 3 weeks from initial notification.

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Acquirer Investigation Report

Further information that must be provided by the acquirer if no forensic examination is to be conducted.

Acquirer name:

Visa Europe Case Reference:

Entity name:

How did the compromise take place?

Has the compromise been contained? If so how?

How many Visa cards were compromised?

Was the entity storing track2 data?

Was the entity storing CVV2?

Was the entity storing PAN and expiry date?

What data elements were compromised?

Was the entity PCI DSS compliant? If not what were

the major non compliances?

Has the entity completed a PCI DSS gap analysis?

Has the entity a remediation Plan?

Is the entity having its public IP addresses scanned

by a ASV?

Are they passing those scans?

Has the entity engaged a PFI?

When will the entity be PCI DSS compliant?

Network/Host Information

Is there Internet connectivity?

Is there wireless connectivity

Does entity utilise a high-speed connection (e.g.,

cable modem, DSL)?

Is there remote access connectivity? If so, who has

remote access?

Is remote access always on or is it enabled upon

request?

What type of remote access software is used?

Is the terminal PC-based or is it connected to a PC-

based environment?

Has entity noticed any abnormal activity on its

systems?

Is the entity retaining full track data, CVV2 or

encrypted PIN blocks?

How long is the data stored on the system(s)?

Have there been any recent changes to the network and host such as:

• Upgrade to the payment application

• Installation of a firewall

• Installation of anti-virus program

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• Changes to remote access connectivity

Provide a transaction flow for credit and debit, as well as remote access to the network. The data flow must include:

• Cardholder data sent to a central corporate server or data centre

• Upstream connection to third-party service providers

• Connection to entity bank/acquirer

• Remote access connection by third-party

service providers or internal staff Third-Party Connectivity

Does the entity send transactions to a processor(s)?

If so, who is the processor(s)?

Name of payment application vendor

Name of reseller, if applicable

Is the entity hosted? If so, who is the hosting

provider?

List of Payment Applications and PIN Entry Device (PED) in Use

Payment application and version information Is this a corporate-mandated payment application

and version?

PIN Entry Device (PED) information, if applicable.

Include the name of the PED firm ware version. Visit www.pcisecuritystandards.org/pin for a list of PCI-

approved PIN entry devices.

Shopping cart and version information Are the payment applications in use PCI PA-DSS compliant? Visit

www.pcisecuritystandards.org/security_standards/vpa for a list of PA-DSS compliant payment applications.

Is entity using a compliant PED? Visit www.pcisecuritystandards.org/pin for a list of

compliant PEDs.

Potential Skimming/PED Tampering

Can entity trace legitimate transactions to a single

employee, device, or lane(s)?

Did entity have any employees who were employed

for a short period of time?

Did other employees notice suspicious behaviour of the new employee (e.g., eager to handle all credit

card transactions)?

Is there any video surveillance and has it been

reviewed?

Can all PEDs be accounted for at all times?

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Are any of the POS PEDs in use listed on the November 2007 Security Alert available at

www.visa.com/cisp?

Steps taken to contain the compromise

Provide full details of remediation steps taken to date

What date did the e-commerce merchant pass a remote vulnerability scan?

Which ASV or QSA company conducted the vulnerability scan?

Other Information

Has entity received complaints regarding fraudulent transactions from their customers?

Has entity been contacted by law enforcement

regarding fraudulent transactions?

Can law enforcement provide intelligence that

skimming groups are active in the area?

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Appendix C: Forensic Investigation Guidelines

A Visa Europe member or compromised entity must ensure that only a Visa Europe approved Qualified Forensic Investigator (PFI) is engaged to perform a forensic investigation. All PFIs are required to adhere to the following forensic investigation guidelines. Visa Europe members can also use these guidelines to monitor the work by the PFI. Visa Europe will NOT accept forensic reports from non-approved forensic companies. PFIs are required to release forensic reports and findings to Visa Europe.

Note:List of PCI Forensic Investigators:-

https://www.pcisecuritystandards.org/approved_companies_providers/pfi_companies.

php

Forensic investigations must be conducted using the following scope and methodology:

1. PFI will assess compromised entity’s computing environment to determine the scope of the forensic investigation and relevant sources of electronic evidence. This includes, but is not limited to:

o Assessment of all external and internal connectivity points within each location involved.

o Assessment of network access controls between compromised system(s) and adjacent and surrounding networks.

Visa Europe reserves the right to engage a PFI directly if an investigation is not carried out expediently.

2. PFI will acquire electronic evidence from the compromised entity’s host and network-based systems.

o Forensic evidence acquisition must be conducted onsite at the compromised entity’s premises.

o If circumstances do not permit onsite evidence acquisition, PFI must notify Visa Europe.

o Preservation of all potential electronic evidence on a platform suitable for review and analysis by a court of law, if applicable.

3. Forensically examine electronic evidence to find cardholder data and establish an understanding of how a compromise may have occurred.

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4. Verify that cardholder data is no longer at risk and/or has been removed from the environment.

5. Verify that the compromised entity has contained the incident.

6. Within five (5) business days from the onset of the onsite forensic investigation, the PFI must use Visa Europe’s Preliminary Incident Report Template (see appendix D, page 27) and provide a preliminary forensic report to all parties involved in the incident.

7. Perform external and internal vulnerability scans, including network and application scans.

8. The following actions must be included as part of the forensic investigation:

o Determine and describe the type of processing environment:

- Organisation description (check all that apply):

- VisaNet processor - Issuer only

- Acquirer only

- Both issuer and acquirer - Pre-paid issuer - Third-party processor - Merchant

- Other: _____________

o Estimated annual number of credit and or debit transactions for Visa- branded products (based on interview; exact numbers are not required):

- Visa credit

- Visa debit (Visa Signature only) - Visa with PIN (ATM with PIN) - Interlink (POS with PIN) - Plus (ATM with PIN)

- Visa Prepaid (include list of Prepaid products) - Other: ______________

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9. Check and determine cardholder information that is at risk. This includes:

o Number of and types of Visa/Plus/Interlink/Prepaid accounts at risk.

Identity those stored and captured by malware (e.g., packet sniffer, key logger).

o List of associated account information at risk:

- Full magnetic-stripe data (e.g., Track 1 and 2)

- PIN blocks and clear-text PINs. To identify potential presence of PIN blocks, also look for the PIN block format code field.

- CVV2

- Account number - Expiration date

- Other sensitive data elements (e.g., SSN, DOB) - Cardholder name

- Cardholder address - Cardholder e-mail address

o PFI to examine all potential locations, including payment applications, to determine if full magnetic-stripe data, CVV2, and/or PIN blocks are stored (whether encrypted or unencrypted) on production, backups, tables, development, test, software engineer, and administrator’s machines.

o PFI should also check volatile memory for cardholder data.

o If malware was used to capture cardholder data, PFI must review any malware output logs and validate whether cardholder data was captured and stored.

o Other logs that must be reviewed include the following:

- Server - Application - Transaction - Troubleshooting - Debug

- Exception or error files

o PFI must provide account information to Visa Europe (see Requirements for Account Data Request, page 15).

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10. Determine time frame of accounts at risk. For example:

o Determine how long accounts were stored on the system(s).

o Determine the transaction date(s) of accounts stored on the system(s).

11. Perform incident validation and assessment. This includes:

o Establishing how a compromise occurred.

o Identifying the source of the compromise.

o Window of system vulnerability. This is defined as the frame of time in which a weakness(s) in an operating system, application or network could be exploited by a threat to the time that weakness(s) is properly remediated.

o Determining if any cryptographic keys have been exposed or compromised.

o Reviewing the entire debit and/or credit processing environment to identify all compromised or affected systems; considering the e- commerce, corporate, test, development, production systems, VPN, modem, DSL, cable modem connections, and any third-party connections.

o If applicable, review VisaNet endpoint security and determine risk.

o Identifying the date(s) that account data was transferred out of the network by the intruder or malware.

o Date(s) when the entity began using the payment application and version number. Determine if the payment application is PA-DSS compliant.

o If available, identify the date(s) when the entity installed a patch or an upgrade to no longer retain prohibited data.

o The date(s) that malware was installed on the system, if applicable.

o Date(s) when malicious code, such as packet sniffer and/or key logger, was activated to capture payment card data on the network and system.

PFI must include date(s) of when malware was de-activated.

o Determine the window of intrusion. This is the first confirmed date that the intruder or malware entered the system to the date of containment 12. Determine what applicable PCI security requirements apply:

o PCI DSS

o PCI PIN Security Requirements

o PCI POS PIN Entry Device Security Requirements o PCI Encrypting PIN PAD (EPP) Security Requirements o PCI PA-DSS

13. If malware and bad IPs are identified in the compromise, the PFI must submit the malware code and bad IPs via a secure distribution to the secure email address datacomp@visaonline.com.

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14. Within ten (10) business days from the completion of the forensic investigation, PFIs must utilize Visa Europe’s Final Incident Report template (see Appendix: E), and provide a forensic report to all parties involved in the incident.

Table of Entities and Requirements Applicability

REQUIREMENTS TYPES OF ENTITIES

Issuer Processo r

Acquirer Processor

Credit Only Merchan t

Debit Acceptin g Merchant

Issuer and Acquirer Processo r

ATM Processo r

Third- Party Servicer

PCI DSS Applies Applies Applies Applies Applies Applies Applies

PCI PIN Security Requirements

Applies if driving their own ATMs

Applies if processin g debit

N/A Applies Applies Applies Applies if processin

g debit

PCI POS and PCI EPP PIN Entry Device Security Requirements

N/A Applies if

processin g debit

N/A Applies Applies Applies Applies if processin

g debit

PCI PA-DSS Applies Applies Applies Applies Applies Applies Applies

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Appendix D: PCI SSC Preliminary Incident Response Report Template

Report Templates and Aids for PFI Investigations

Preliminary Incident Response Report

Question Response

Name of Compromised Entity Date arrived onsite

Evidence of a breach? Yes No

First confirmed date that the intruder or malware entered the network:

Scope of forensic investigation (e.g., single vs.

numerous locations; how systems/network were determined for acquisition)

Type of data impacted (e.g., full track, CID, CAV2, CVC2, CVV2, encrypted or clear-text PINs)

Window of system vulnerability Initial thoughts on attack vector

Is the security breach ongoing or has it been contained?

If contained, how has it been contained?

Estimated date of investigation completion:

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Other comments

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Appendix E: PCI SSC Final Incident Report Template

Report Templates and Aids for PFI Investigations

Final Incident Report

Guidance Notes included in the body of template below are informational only and aimed at providing direction to the PFI on how to complete the Final Incident Report. As such, the Guidance Notes are not required to be included in the submitted report.

Definitions for certain terms in this template are provided below in Appendix B

I. Executive Summary (include the following information)

Date of PFI engagement Date forensic investigation began Locations(s) visited or forensically

reviewed

Summary of environment reviewed Details must be documented under

“Findings” section.

Conclusive evidence of a breach (Y/N) If no, please provide reasons why inconclusive.

Yes No

Date(s) of intrusion Cause of the intrusion (List applicable

attack vectors as per Appendix A.)

Breach: Not contained

Contained (specify how):

II. Background

Type of business entity

Merchant (brick and mortar, e-commerce, or both) Prepaid issuer Issuer

Acquirer

Acquirer processor Issuer processor

ATM processor

Third-party service provider (web hosting; co-location) Encryption Support

Organization (ESO)

Payment application vendor

Payment application reseller

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Number of locations Parent company (if applicable) Other information

Franchise or corporate-owned

III. Incident Dashboard

Date when entity identified compromise

Method of identification Self-detection

Common point of purchase Other (describe below)

Window of system vulnerability

Window of intrusion

Malware installation date(s), if applicable

Date(s) of real time capture, if applicable

Date(s) that data was transferred out of the network, if applicable

Window of payment card data storage

Transaction date(s) of stored accounts

Payment application information:

1. Name, version, and install date of

application at the time of the breach

2. Name, version, and install date of

current application

3. Reseller/IT support that manages

payment application/network

4. Payment application vendor

Name of software:

Version number:

Name, version, and vendor of software that stored the CID, CAV2, CVC2, CVV2, or track data

This information must be supplied if CID, CAV2, CVC2, CVV2, or track data has been stored.

Vendor name

(or state “in-house”):

Type of data exposed

Check applicable data elements.

Cardholder name Cardholder address PAN

Expiry date

CID, CAV2, CVC2, CVV2 Track data (track 1, 2, or both) Encrypted or clear-text PINs or

PIN Blocks

Brand exposure

^Visa

MasterCard Discover

American Express JCB

Other:

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Number of cards exposed (both live

system space and unallocated space)

American Express

Discover

JCB

MasterCard

a.

Breakdown by Payment Card Brand:

Visa

Signature

PIN-based transactions

Issuer-only data

Non-issuer data

b.

Breakdown of the following:

Prepaid data

Firewall logs File-integrity monitoring output Transaction logs Intrusion-detection systems Database queries Remote-access logs FTP server logs Wireless connection logs System login records Anti-virus logs Web server logs Security event logs

Logs that provided evidence:

Hardware Security Module (HSM) logs

File creation/access date

Suspected cause summary and list of attack vectors (See attached List of Attack Vectors.)

Insert (or attach) brief case summary. Detailed findings should be included in the “Findings” section of the report.

Assessment of residual risk Is card data still at risk? Yes No If yes, please describe the residual risk:

Date and case number from law

enforcement report:

If the case has not been reported to law enforcement,

please explain why.

If applicable, document the type of cryptographic keys at risk.

Issuer Side Cryptographic Keys Acquirer Side Cryptographic Keys

Issuer working keys (IWK) Acquirer working keys (AWK)

PIN verification keys (PVK) POS, ATM, EPP PIN encryption keys PIN generation keys POS, ATM, EPP key-encrypting keys

(KEKs)

Master derivation keys (MDK) Remote initialization keys

Host-to-host working keys Host-to-host working keys

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Issuer Side Cryptographic Keys Acquirer Side Cryptographic Keys

Key-encrypting keys (KEKs) Key-encrypting keys (KEKs)

Switch working keys Switch working keys

Other (describe)

If applicable, document the type of Card Validation Codes or Values at risk.

Magnetic Stripe-Based Security Features Printed Security Features

CAV – Card Authentication Value

(JCB payment cards)

CVC – Card Validation Code (MasterCard payment cards) CVV – Card Verification Value

(Visa and Discover payment cards) CSC – Card Security Code

(American Express)

CID – Card Identification Number

(American Express and Discover payment cards)

CAV2 – Card Authentication Value 2 (JCB payment cards)

CVC2 – Card Validation Code 2 (MasterCard payment cards) CVV2 – Card Verification Value 2

(Visa payment cards)

IV. Network Infrastructure Overview Guidance Note

When completing this section:

1. Provide a diagram of the network that includes the following:

Cardholder data sent to central corporate server or data center

Upstream connections to third-party processors

Connections to acquiring payment card brand networks

Remote access connections by third-party vendors or internal staff

Include remote access application(s) and version number

Inbound/outbound network connectivity

Network security controls and components (network security zones, firewalls, hardware security modules, etc.)

2. Clearly identify all infrastructure components implemented or modified after the timeframe

of the compromise.

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V. Findings Guidance Note

When completing this section:

Provide specifics on firewall, infrastructure, host, and personnel findings.

Identify any and all changes made to the Compromised Entity’s computing environment after the identification of a compromise.

Provide specific dates of network, system, or payment application changes.

Include any and all forensic evidence supporting changes made to networks, systems, and POS components.

Identify any data accessed by unauthorized user(s).

Identify any data transferred out of the network by unauthorized user(s).

Identify any evidence of data-deletion from systems involved in a compromise.

If applicable, identify any deleted data recovered through forensic file recovery methods.

Identify any third-party payment applications, including version number.

Identify remote access application(s) and version(s) used.

Identify third-party service provider (i.e., web-hosting, reseller/integrator, POS vendor).

Identify any upgrades/patches to the payment application that address removal of magnetic-stripe data, Card Validation Codes or Values, and/or encrypted PIN blocks.

Provide an attack timeline of events. Include relevant date(s) and activities (e.g., date/time created, system/file evidence, description of evidence).

Include a list of compromised systems/hosts (e.g., operating system, service pack/hotfix, application), and their functionality.

Include a list of malicious IPs. Include any information related to malicious IPs (e.g., part of hacker group, TOR, or anonymous relay addresses).

Include a list of all malware identified. Include the following information on malware:

• Name of malware

• MD5/SHA/Fuzzy Hash

• Registry settings

• File size

• System path

Provide description of malware based on PFI’s malware analysis.

Provide detailed analysis and feedback regarding all inconclusive cases and the PFI’s opinion as to the reason for the forensic investigation being inconclusive.

VI. Compromised Entity Containment Plan Guidance Note

When completing this section, document what the entity has done to contain the incident. Include

date(s) of containment.

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VII. Recommendation(s) Guidance Note

When completing this section, list recommendations by priority level.

VIII. PCI DSS Compliance Status

Based on findings identified in the forensic investigation, indicate the compliance status for each of the 12 basic requirements under the PCI DSS.

Document the specific PCI DSS requirements and sub-requirements that contributed to the security breach.

PCI DSS Requirement In

Place

Cause of breach

?

Include specific forensic findings

Build and Maintain a Secure Network

Requirement 1: Install and maintain a firewall

configuration to protect cardholder data Yes/No Yes/No Requirement 2: Do not use vendor-supplied

defaults for system passwords and other security parameters

Yes/No Yes/No

Protect Cardholder Data

Requirement 3: Protect stored cardholder data Yes/No Yes/No Requirement 4: Encrypt transmission of

cardholder data across open, public networks Yes/No Yes/No

Maintain a Vulnerability Management

Program

Requirement 5: Use and regularly update anti-

virus software Yes/No Yes/No

Requirement 6: Develop and maintain secure

systems and applications Yes/No Yes/No

Implement Strong Access Control Measures

Requirement 7: Restrict access to cardholder

data by business need-to-know Yes/No Yes/No Requirement 8: Assign a unique ID to each

person with computer access Yes/No Yes/No Requirement 9: Restrict physical access to

cardholder data Yes/No Yes/No

Regularly Monitor and Test Networks

Requirement 10: Track and monitor all access to

network resources and cardholder data Yes/No Yes/No Requirement 11: Regularly test security systems

and processes Yes/No Yes/No

Maintain an Information Security Policy

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PCI DSS Requirement In Place

Cause of breach

?

Include specific forensic findings

Build and Maintain a Secure Network

Requirement 12: Maintain a policy that

addresses information security Yes/No Yes/No

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List of Attack Vectors

This appendix is informational, and it need not be included with the submitted report.

One or more of the attack vector types listed below are to be used in completing the “Cause of the intrusion” item in Section I above.

Vector

Type Specifics

Host – Auto login enabled

Host – Local accounts are default/unsecured Host – Local accounts have weak passwords Host – No/limited system hardening Host – No/limited system logging

Host – System allows insecure remote access Host – System contains PAI/track data

Host – System has unrestricted network/Internet access Host – System interfaces with POS environment Host – System lacks anti-virus/anti-malware/HIPS Host – System not inventoried/accounted Host – System not patched/maintained

Host – System runs high-risk/insecure applications Host – System runs non-standard/proprietary software

Host

Host – System used for personal reasons Network – Default configurations in use Network – Default passwords in use

Network – Default/common ports allowed or in use Network – Network accounts have weak passwords Network – No ACLS present/in use

Network – No anti-virus/anti-malware Network – No encryption

Network – No firewall present Network – No ingress/egress filtering Network – No network segmentation Network – No secured remote access Network – No security monitoring Network – No separate POS environment Network – No/insufficient logging

Network

Network – Use of insecure protocols

Remote Access – No monitoring/logging of remote access

Remote Access – Out-dated/known vulnerable hardware/software in use Remote Access – Remote access forwarding allowed

Remote Access – Remote access left permanently enabled Remote Access – Unrestricted remote access allowed

Remote Access – Use of blackbox/proprietary hardware/software

Remote Access

Remote Access – Use of default passwords/accounts

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Vector

Type Specifics

Remote Access – Use of default/out-of-box configuration Remote Access – Use of insecure remote software (e.g., VNC) Remote Access – Use of known POS vendor defaults

Remote Access – Use of weak passwords

Web Attack – Allocation of Resources Without Limits or Throttling Web Attack – Buffer Access with Incorrect Length Value

Web Attack – Buffer Copy without Checking Size of Input (Classic Buffer Overflow) Web Attack – Cross-Site Request Forgery (CSRF)

Web Attack – Download of Code Without Integrity Check Web Attack – Improper Access Control (Authorization)

Web Attack – Improper Check for Unusual or Exceptional Conditions

Web Attack – Improper Control of Filename for Include/Require Statement in PHP Program (PHP File Inclusion)

Web Attack – Improper Limitation of a Pathname to a Restricted Directory (Path Traversal)

Web Attack – Improper Sanitization of Special Elements used in an OS Command (OS Command Injection) Web Attack – Improper Sanitization of Special Elements used in an SQL Command (SQL Injection) Web Attack – Improper Validation of Array Index

Web Attack – Incorrect Calculation of Buffer Size

Web Attack – Incorrect Permission Assignment for Critical Resource Web Attack – Information Exposure Through an Error Message Web Attack – Integer Overflow or Wraparound

Web Attack – Missing Authentication for Critical Function Web Attack – Missing Encryption of Sensitive Data Web Attack – Race Condition

Web Attack – Reliance on Untrusted Inputs in a Security Decision Web Attack – Unrestricted Upload of File with Dangerous Type Web Attack – URL Redirection to Untrusted Site (Open Redirect) Web Attack – Use of a Broken or Risky Cryptographic Algorithm Web Attack – Use of Hard-coded Credentials

Web Attack

Web Attack – Failure to Preserve Web Page Structure (Cross-site Scripting)

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List of Investigation Definitions for Final Incident Reports This appendix is informational and it need not be included with the submitted report.

Terminology Description

Date(s) that data was

transferred out of the network

The confirmed date(s) that data was transferred out of the network by the intruder or malware.

Date and version of POS installation(s)

Date(s) when the entity began using the POS application and version number.

If available, include date(s) when entity installed a patch or an upgrade to no longer retain prohibited data.

Malware installation date(s)

The date(s) that malware was installed on the system, if applicable.

Date(s) of real-time capture

Date(s) that malicious code/malware, such as packet sniffer and/or key logger, was activated to capture payment card data on the network and system. Should also include date(s) that malware was de-activated.

Window of intrusion First confirmed date that intruder or malware entered the system to the date of containment. Examples of containment include, but are not limited to:

Removal of malware or rebuilt of compromised systems

Compromised system removed from the network

Blocking of malicious IPs on the firewall

Rotation of compromised passwords Transaction date(s) of

stored accounts

The date(s) of the transactions stored on the system.

Window of system vulnerability

a) The timeframe in which a weakness in an operating system, application, or network could be exploited by a threat to the time that weakness is properly remediated. It answers the question,

"How long was the system at risk to a given compromise?"

b) Overall time period that a system was vulnerable to attack due to

system weaknesses—for example, lack of or poorly configured

firewall, missing security patches, insecure remote access

configuration, default passwords to POS systems, insecure

wireless configuration.

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Appendix F: Request for Information --- External Compromise

The below assumes the external entity in question has a confirmed connection to Visa.

Please validate the type of connection from your organisation to Visa. (e.g., Visanet connection, Visa Debit connection, EA/Edge connection, etc.)

Please verify the current state of your connection to Visa. (e.g., active, disconnected, stand-in, etc.)

Please confirm if your organisation has initiated any plans to disconnect your network(s) from Visa while pursuing this incident.

Please furnish a detailed network diagram depicting connectivity to Visa. Please include all relevant internal addressing, inclusive of any NAT/PAT, for directly connected systems or devices. Please clearly delineate those portions of the network that have been directly affected or impacted, particularly if your organisation maintains network operations and/or access in multiple locales through logical or physical segmentation.

Please describe your organisation’s “post-breach” security monitoring and alerting activities with particular regard to those systems and devices connected to Visa.

Please supply a list of known compromised systems by hostname, IP address, function and OS type.

Please supply a list of known compromised technologies by function, type and system declaration.

Please supply a list of known compromised user id and system id accounts.

Please indicate which accounts were utilized on which compromised systems.

Please deliver a detailed accounting of all confirmed attack vectors and patterns utilized by the intruder. Wherever possible, please provide exact log detail.

When providing log detail, please be sure to note current time zone settings if not readily deduced from the detail.

Please declare all ingress and egress points for your network(s) if not already identified in the requested network diagram detail. Please note if any connections are shared.

Please furnish a list of suspect/malicious IP addresses and corresponding port numbers utilized by the intruder/attacker by source and destination.

Please provide a list of malware installed on compromised systems by name, system declaration, malware description, hash value and installation date (where known). Please furnish the malware binaries where possible.

Please supply a copy of your organisation’s current breach containment procedures. Please be sure to outline any pending or partial containment measures.

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Appendix G: List of Supporting Documents

The following document can be downloaded from:

https://www.pcisecuritystandards.org/approved_companies_providers/pfi_companies.php

• PCI Forensic Investigator (PFI) List --- List of forensic companies qualified to perform a PCI forensic investigation on compromised entities.

The following documents can be downloaded from:

www.pcisecuritystandards.org

• Qualified PCI Assessor (QSA) - List of assessors qualified to perform PCI assessments for those entities requiring onsite validation of PCI compliance.

• PCI Data Security Standard (PCI DSS) --- Detailed security requirements to which Visa Europe members, merchants, and service providers must adhere to ensure the protection of cardholder data.

• PCI Security Audit Procedures --- Detailed security requirements, guidelines, and testing procedures to assist a PCI QSA in verifying that an entity is in compliance with the PCI DSS.

• PCI Self-Assessment Questionnaire (SAQ) - The PCI SAQ is an important validation tool primarily used by smaller merchants and service providers to demonstrate compliance to the PCI DSS. Responses must address any system(s) or system component(s) involved in processing, storing, or transmitting Visa cardholder data. Note: For any answers where N/A is marked, a brief explanation should be attached.

• PCI Security Scanning Procedures - Procedures and guidelines for conducting network security scans for entities and third-party service providers who are scanning their infrastructures to demonstrate compliance to the PCI DSS.

What To Do If Compromised