by Avivah Litan | September 9, 2014 | 6 Comments
Apple has finally gotten into the payments business with its Apple Pay announcement. While details on Apple Pay security features are still scarce, it sounds like they are working with Visa, MasterCard, the other card brands and the major issuing banks behind them to use a payment card tokenization scheme that these financial services companies endorse and recognize.
That means that consumers don’t have to store their payment card data in their mobile wallets. Instead, they would set up their Apple Pay system with a credit card (either one linked to their iTunes account or a separate one). When the consumer is ready to pay, their financial service provider would issue them a one-time token number that would initiate the payment process. The token would have policies governing its use, i.e. how long a time period it can be used in, where it can be used, how much it can be used for etc.
Token numbers are not considered credit card numbers and there are lots of security benefits to merchants when they DO NOT accept, store or transmit actual credit card numbers; i.e.
a) The scope of their PCI compliance audit is greatly reduced
b) They will avoid payment card data breaches and their systems will be more secure since criminals can’t reuse token numbers so they are not going to bother stealing them.
I firmly believe that merchant acceptance is what drives adoption of new payment systems, much more so than consumer acceptance does. For Apple Pay to succeed, merchants are going to have to want to accept it. So are the security features enough to incent merchants to adopt Apple Pay?
a) Probably not for most of the 30 some million merchants that accept credit cards. Unless ALL their shoppers use Apple Pay, merchants still have to spend money on all the onerous security functions required to be PCI compliant.
b) Merchants are already spending money on upgrading to EMV terminals (chip) and have to get ready for that upgrade and liability shift in October 2015 when they will start eating more fraud if they can’t accept an EMV chip card payment.
Granted, EMV-ready terminals come with NFC acceptance capability and merchants have to be able to accept contactless NFC based EMV payments as well. But Apple didn’t say anything I heard about support for the EMV standard, at least not yet. (They likely will support it).
c) Many large merchants Gartner talks with are upgrading their point-of-sale terminals to manage point to point encryption (P2PE) of the card data because they are sick and tired of hearing about the data breaches and don’t want to be the next retailer victim. P2PE affords the quickest and strongest protection to payment card data used at brick and mortar stores –hence there is strong interest in the technology that the card companies have yet to standardize on.
Chip (EMV) cards will take at least 5-7 years to become more or less ubiquitous in the U.S. and merchants can’t wait that long to protect themselves and their card data. P2PE is effective as soon as the merchants implement it. They don’t have to wait for card issuers and consumers to start using chip cards.
So what does Apple need to do to foster wider acceptance of Apple Pay?
a) Lower merchant fees, just like Square and other payment aggregators do. Apple already has experience and expertise with payment aggregation for iTunes payments which it needs to do to keep iTunes transaction costs down. If they did the same payment aggregation for merchants, they could conceivably offer lower rates then the existing payment processors and banks do today, assuming Visa and MasterCard don’t stop them from doing so.
b) Build in revenue generating and loyalty features into the Apple Pay Wallet to foster merchant sales. Apple could conceivably do this as well but this is less important than lowering the fees when it comes to building merchant acceptance.
Bottom Line – This is very exciting news and has the potential to change the payment landscape, at least in the U.S. where merchants are being breached every other day and are up to their eyeballs in security issues and expenses. Apple can certainly ride the security wave and offer merchants and consumers more secure payments. But they are still just a fraction of the shopper base and the other fraction still has to be protected. So Apple will need to offer more than just security features to gain all-important acceptance. IMHO, lower fees are key to Apple Pay success.
Google is likely to copy Apple on the security features and then will have to enlist their handset manufacturer partners to link NFC chips to the Google Wallet. Apple has it easier in this regard since they have a closed system – i.e. they manufacture the handsets and the software that runs on them. But once Google gets in the game and Android phones are enabled with more secure payments, we may actually see mobile NFC payments catch on. Better yet, we may actually see the criminals and payment card data breaches start to go away – or at least migrate to something else.
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by Avivah Litan | August 28, 2014 | 2 Comments
Today’s headlines report that big banks have been hit by cyberattacks, according to the FBI. While this news is alarming, it certainly is not surprising.
Hackers are always probing bank systems and even a year ago or so, law enforcement authorities and regulators put out an advisory to banks about criminals hacking into bank employee accounts to infiltrate their computer networks, and in some selected cases to steal funds.
Frankly, this isn’t new news – it’s just the culmination of old news. I imagine that the authorities and security staff never were able to eliminate the hackers from their systems. They have probably been in there for years, and there have probably been multiple actors, ranging from financial hackers to state sponsored cyberspies.
Wake Up Call
But this should serve as a loud wakeup call for bank Boards to elevate security to the top of their agenda, and to make sure their security staff (e.g. the CISO) are doing everything they can to secure the business. They also need to make sure the CISO and IT staff have the business support they need to make it all happen.
Organizational issues – as opposed to the technology issues — are generally the main impediments to successful defense of the bank’s assets. Organizations need to be aligned in order to properly defend themselves from cyber-attacks. Senior and board level management need to support security initiatives directly by getting involved, and not just leaving it to the CIO or CISO to figure out. These IT and IS executives can’t do their jobs without business support. And that has to come from the board level, given the siloed nature of these large bank organizations.
What’s the Damage?
While this is cause for alarm, in a sense we should all be prepared for this. When it comes to financial assets being stolen, the banks have strong safeguards in place and can shut down wire and money transfer systems if they need to before too much damage is done. So, for example, some unauthorized money transfers could certainly take place, but they would be limited in number if the criminals attempted a mass attack against the money transfer systems. (Of course the stock market would have an extreme negative reaction if this occurred – hopefully that would be short lived).
As far as the data – it’s safe to say we must assume all our financial information is subject to theft, as are simple credentials such as passwords. That certainly is not a good situation and banks, intel agencies and other enterprises must do a better job at protecting sensitive data. But I see a lot more money spent on preventing the USE of stolen data than I do on preventing the theft of the data itself – for simple economic reasons, i.e. the use of stolen data directly affects the company’s bottom line. The theft of data generally doesn’t have that impact unless it’s disclosed to the public since the stolen data is generally used at another enterprise.
Most large financial institutions have spent considerable sums on fraud detection systems that prevent the use of stolen data. They are certainly not perfect, but they do catch the majority of fraud attempts. It’s the small financial institutions and their third party processors that we should be worried about because they are not securing their systems as well as they should be.
So while it makes me nervous that this is happening, I do believe the large financial services companies can protect their and our financial assets such that a massive robbery cannot take place. And as noted it’s safe to assume information is no longer confidential and we just have to compensate for that by preventing the use of stolen information for illicit purposes. It’s just the new world order.
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by Avivah Litan | August 6, 2014 | 3 Comments
I’m finally going to change my passwords. Frankly, I haven’t been motivated until now – even after Heartbleed and all the other heists – since I just do a quick mental calculation of my risk vs. my inconvenience. And I decided against the inconvenience.
But now the threat to me and you as consumers is real and strong. We’ve all been speaking about these phenomena for years, i.e. the criminals amassing millions of records on users, including credentials/passwords, bank account numbers, personal data and more. And it’s finally a reality – not just conjecture anymore.
The interesting thing is that most consumers think the Target breach was more serious than this one. The Target breach pales compared to this revelation. With Target and stolen cards, consumers are protected financially and the banks can stop the stolen cards from being used relatively quickly. All the card payment systems around the world interconnect virtually in real time so fixes can be applied immediately.
With the theft of passwords and other sensitive data, the criminals have access to many of our accounts where our protections are much less and where systems are much more fragmented. For example, if someone steals money from my online retirement account, I have to go through a lot of very time-consuming hoops to get my money back and may not get it back in the end if my retirement company doesn’t want to give it back to me. They can tell me it’s my fault my password was stolen. The same rules apply to many other types of bank and investment accounts.
In the meantime, there’s a lot of chatter about the motivations of the company who told the NY Times about this story. Frankly, no matter what the motivations were or are, the story is still true and it’s still ominous.
Bottom Line – change your passwords and monitor your accounts closely. And try to put your money with providers that don’t just rely on passwords for security.
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by Avivah Litan | May 15, 2014 | 4 Comments
A man convicted of a $200 Million credit card bust out scheme pleaded guilty Monday in one of the largest credit card fraud schemes ever charged by the Justice Department. (See: http://www.fbi.gov/newark/press-releases/2014/new-york-man-admits-role-in-international-200-million-credit-card-fraud-conspiracy).
The scam was executed by using fake identities to take credit cards out, and incur expenses that were never paid back to the banks.
In fact this scam probably inflicted more than four times the direct fraud damage on the financial services industry than Target did. Consumers were not damaged directly, but losses for banks eventually translate into costlier financial services.
It should also remind us how overrated our Social Security Numbers are. Criminals like the ones arrested in this scam have little problem making up fictitious identities often using unassigned SSNs, or they may choose to use an existing SSN but tie it to a new identity. There are plenty of SSNs with different names attached to them in the U.S. credit bureaus, for example. A few years ago I was told that around 20 million SSNs were in this latter category. I’m not sure it’s all because of identity theft but it’s most assuredly not a good thing.
In some sense, it’s easier for the crooks to make up an identity than it is to steal one when it comes to defrauding bank lending and credit systems. (There’s no individual that’s going to report being harmed in the case of a fictitious identity). Some estimates are that almost half of new credit account fraud is incurred by extending credit to fictitious identities but there are no good official records on it.
Bottom line- I personally don’t get that worked up about my SSN. Sure I’d hate to have my identity stolen and the criminal would need my SSN to hijack my identity. But I also look at the odds of that happening and factor in the point that the bad guys can just as easily fabricate an identity. They know the SSN numbering scheme and how to make one up that works for a particular Date of Birth and State – so why would they bother stealing mine? (Famous last words…)
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by Avivah Litan | April 9, 2014 | 6 Comments
As we all know by now, this is mega-serious and affects all users of Open SSL 1.0.1 through 1.01.f – so those who kept their Open SSL code up to date were in effect penalized.
For information on the vulnerability, see kb.cert.org
I’m just trying to understand why all the news reports are focused on individual communications with websites. SSL protocols, including Open SSL, are used in most ‘trusted’ machine to machine communications. This bug affects routers, switches, operating systems and other applications that support the protocol in order to authenticate senders and receivers and to encrypt their communications.
See list of affected companies here kb.cert.com
What this means is any trusted communications traffic using this protocol is ultimately not trustworthy – it goes way beyond individuals’ ‘handshakes’ and communications with websites. Forget having to plant back doors in encryption libraries, as the NSA allegedly did. The backdoors are already built in. So criminals and other naysayers can essentially eavesdrop on any sensitive communications using Open SSL 1.0.1 such as payment processing, file sharing and more, (although as my colleague Erik Heidt pointed out – this would require a compound attack since Heartbleed enables an attacker to recover anything being processed in memory on the server – rather than a direct attack against in-transit communications).
We’ve all been acclimated to the fact that our sensitive data is no longer well protected while it is at rest. We’ve also learned over the years that retailers, financial services companies, ecommerce providers and others who accept our sensitive transactions can’t always stay ahead of criminal exploits that steal the information.
Now we need to get used to the fact that we can’t trust some of the implementations of the protocols that secure data in transit over public and private internet networks. Until now that was the one area that looked relatively safe, at least to me.
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by Avivah Litan | March 26, 2014 | 15 Comments
Two U.S. banks are suing Target’s Qualified Security Assessor, Trustwave, for damages incurred during the holiday season breach at Target, accusing the company of failing to identity security issues. The suit also claims that Trustwave’s round the clock monitoring services for Target failed to detect the intrusion into Target’s network for a full three weeks. See computerworld.com
Trustwave was just let off the hook from a similar class action suit filed by a former state senator against the South Carolina Department of Revenue, Trustwave and other parties for a database breach at the revenue department which was using Trustwave to monitor its systems. See postandcourier.com for more information.
Many headline breaches have occurred at companies certified as PCI compliant, but this is the first time that the fingers are pointing to the assessor. Gartner has long argued that PCI qualified security assessors like Trustwave should not be allowed to sell remediation and ongoing security services as Trustwave did for Target, according to the lawsuit. This has the effect of potentially destroying the integrity and independence of the assessment process.
Indeed as we wrote in a November 20, 2008 research note titled “PCI Quality Assurance Program Does Not Go Far Enough” – “The most significant enterprise complaint about PCI compliance practices is that many assessors also offer products and services that can be used to meet DSS requirements and ensure compliance to the audit. The PCI takes the same self-regulating approach to this issue that is widely regarded as having failed in the financial auditing industry and having led to the separation of consulting and accounting audit services. Gartner believes that the only truly effective approach is for the PCI to prohibit QSAs from performing remediation services for enterprises they are assessing.”
Nothing has changed on this front since 2008. In fact the situation has been exacerbated. It’s extremely difficult to find independent assessors who are not selling security services. (In fact I only know of two among the hundreds out there– I would appreciate referrals if you know of more). And the QSAs keep adding to the litany of security services that they offer.
Points to consider:
a) PCI compliance has become a big money making enterprise for the QSAs selling remediation and security services and their customers have been lulled into a false sense of security – at least in the C-level suite.
b) PCI assessor contracts generally state that the assessors have no liability if their customers are breached. But shouldn’t they be responsible for their assessments, at least for that point in time?
c) The PCI Council’s typical response to a PCI compliant entity that has been breached has been that the entity may have been compliant at the time of the ROC (report of compliance) but since became non-compliant after the report was filed. Therefore you can’t blame the assessor.
1. This argument loses validity when the assessor provides continual security monitoring services after the PCI audit.
2. Further, when the assessors offer security services, they are auditing themselves. You don’t have to be a security specialist to see that is a conflict of interest!
So what exactly is the point of PCI compliance? Sure no one can argue with good solid security standards and a lot of smart people have put some good thoughts into the PCI standard.
Personally, I think the standard is very good and thorough. It’s the enforcement process I have issues with. It’s a process rife with conflict of interests between assessors and payment processors, assessors with themselves, and even assessors with at least one card brand.
Unfortunately, I imagine that this particular lawsuit will be settled out of court, with all the documents sealed from public view. The last thing the PCI industry wants to do is have all these conflicts aired and scrutinized in court.
But maybe – and this is highly doubtful– the PCI machine will take its queue from the financial services auditing industry and voluntarily end the conflict of interests. Just as the big accounting firms had to split their auditing and consulting practices, so should the PCI assessment firms split their auditing and security services.
If nothing else changes, at least companies who have to comply with PCI will likely spend more time looking for independent security assessors. That’s just basic common sense.
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by Avivah Litan | March 4, 2014 | 3 Comments
Just got back from the 2014 RSA Security conference where I had lots of stimulating conversations with colleagues in the security industry. What stood out the most to me was the dearth of information sharing in the retail payment card industry. You’d think that the PCI Security Council would promote information sharing on threats and POS malware to help retailers prevent breaches against their systems. But instead that task has fallen largely to well-known security blogger Brian Krebs who has to sleuth his way around the underworld and the opaque payments industry to uncover the truth about breaches against retailers. See krebsonsecurity.com
Big buzz at the RSA conference – Who will be or already is the next Target? Which retailer got hacked this time? And what solutions can prevent this madness?
Information sharing is not easy in Retail Payments. I have colleagues who would like to share specific information on the behavior of malware attacking retailers but are shut down by lawyers for retailers, POS software vendors, insurance companies and more. This makes no sense to me when information sharing that provides safe harbor for those who disclose and confidentiality for the victims is exactly what is needed to help stop future attacks.
The legal issues are thorny and complex.
But at least there is progress being made on structuring threat intelligence information so that information that is shared can be read by machines as well as humans. At least one threat intel firm, Fox IT, is working with the Mitre Corporation on structuring the presentation and dissemination of threat intelligence to commercial entities using standard protocols. Mitre has been a major player in developing the STIX and TAXII standard protocols for threat intel in the government.
But what good are these standards if the lawyers stop the information from getting out? What ever happened to Obama’s Executive Order to promote threat intelligence and give safe harbor to those who provide it? Progress is slow in the government although things are moving. See
I’m not optimistic that the situation will substantially change in the near future so until then, the only ones who win are the criminals. And the only ones who disseminate the threat information are journalists like Brian Krebs who have to go to extraordinary lengths to get the information in the first place. And they do so without any safe harbor. In fact if I were Brian I’d be more worried about the lawyers than the criminals.
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by Avivah Litan | February 11, 2014 | 4 Comments
Target boldly told Congress and the world that it was escalating its $100 million EMV upgrade program and would implement it before the October 2015 deadline. Target is absolutely correct when it says that payment system security is a responsibility that needs to be shared across all players in the payment ecosystem – i.e. issuing and acquiring banks, card networks, processors, retailers and other card acceptors.
EMV will definitely help secure the card present payment systems, although estimates are it will take about 6 years to roll out across the U.S. to the point where U.S. card issuers can stop producing cards with magnetic stripes on them. In the interim we can expect card-present in-country fraud rates to decline commensurate with the pace of EMV adoption. Eventually (but not before 6 or more years), the criminals will be unable to use mag stripe data that they steal so they will be dis-incented from breaching companies like Target who accept payment card transactions.
That’s a very long time to wait and now that POS malware is rampant in the underground, it’s safe to assume the card data breaches and the arms race to secure vulnerable payment systems will continue.
So where does that leave merchants like Target:
a) They still have to secure their cardholder data environment and comply with PCI
b) They have to spend money upgrading their POS terminals to accept contact and contactless EMV chip payments.
c) As of October 2015, if they don’t upgrade their terminals and a physical chip card is presented to them, they have to eat any fraud that occurs as a result of that transaction (even though I’d expect the fraudulent transactions from chip cards to be minimal).
d) Significantly, merchants don’t get the liability shift if it’s a mobile contactless EMV payment.
e) That means that merchants may encourage consumers to use Mobile contactless EMV payments, the Visa and MasterCard standard for mobile payments.
f) Card issuers will also likely be inclined to issue EMV payment functionality by provisioning it to consumer mobile devices rather than issue a physical chip card (although they may do both). This way they keep their card production costs down and start ingratiating themselves with consumers and their mobile digital wallets.
g) Merchants again become ‘hostage’ to the large market grip of Visa and MasterCard when it comes to mobile payments – and lose one of their last holdout hopes of a channel they can control and so that they can avoid paying relatively high Visa and MasterCard merchant fees.
h) As EMV takes hold in the U.S. the fraud will shift to Card Not Present fraud as has happened in other countries. Merchants are already responsible for CNP fraud and will have to spend more money beefing up their CNP fraud detection systems in the future, in anticipation of this fraud migration.
i) And finally rates – I know there is a debate underway in the U.S. on whether or not the EMV Chip program here will be PIN or Signature based. Merchants prefer PIN; banks prefer Signatures. I’m guessing banks prefer signatures because it is advantageous to them – and disadvantageous to the merchants – economically. My guess is that the banks will win this debate even though PIN with Chip is more secure than just signature Chip.
So all in all – the banks come out ‘ahead’ and the retailers come out ‘behind’.
a) The U.S. gets a more secure in-store payment system, i.e. EMV
b) The retailers pay more money in fraud costs, mobile payment fees, and EMV related fees.
c) Visa and MasterCard and their card issuing banks dominate mobile NFC payments, lessening the chances for competitors with competitive rates to succeed.
I suppose that – other than squelching mobile payment competition which is a bad thing for the economy – this is a wash for U.S. consumers. What consumers lose in terms of having to pay higher prices from retailers (who have to cover their costs) – is equal to what they likely gain in terms of loyalty programs and other financial and customer service benefits from payment card issuers.
Would you rather pay more for laundry detergent if you got double frequent flyer points for buying it?
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by Avivah Litan | January 30, 2014 | 3 Comments
I’m just finishing a trip overseas, now in Holland where I’ve been meeting with banks and other Gartner clients. The verdict is in – Chip cards are in fact working to substantially reduce losses from counterfeit cards. Some of the banks I met also instituted geo-blocking to stop the cards’ magnetic stripe from being accepted in certain countries. One major bank told me EMV chip combined with geo-blocking has brought their card present fraud down as low as possible.
I think most of us know this already but it’s always good to hear it again. Yes, the fraud shifts to ecommerce channels when chip cards are implemented, but thankfully there’s plenty of good technology out there to stop ecommerce fraud as well.
By the way, I understand that the financial institutions and the retailers in the U.S. are now debating whether the U.S. should implement Chip and Signature or Chip and PIN. Supposedly, the rates will be the same on each (I’m not sure but that’s what I hear), but I imagine it comes down to who eats the fraud if it occurs. With PIN, banks will likely eat the fraud – with Signature the retailers are more likely to because the issuer can always claim the retailer didn’t check the signature properly.
The rest of the world has implemented Chip and PIN. Handicapped people who can’t enter their PIN are accommodated with special cards that don’t require one.
Frankly, I prefer entering my PIN over signing my name. It’s much faster.
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by Avivah Litan | January 20, 2014 | 17 Comments
The PCI (Payment Card Industry) security standard has largely been a failure when you consider its initial purpose and history. Target and other breached entities before it, such as Heartland Payment Systems, were all PCI compliant at the time of their breach. These companies spent untold sums of money annually certifying compliance to the payment card networks and their acquiring banks but it didn’t stop their breaches.
The payment card industry failed to face up to major security problems when there was still time to do something back in 2005 after the first major card breach at Card Systems International, when 40 million cards were compromised. At that time, the card issuing banks and the card networks (Visa, Mastercard) came up with the PCI security standard as their answer for stronger card security, when Congress took them to the mat during congressional hearings.
Visa, MasterCard and the banks they represent thought that with PCI they could enforce adequate security at retailers and payment processors, while letting them bear major security burdens and costs. This was much easier and less costly for the U.S. banks, who are the last major holdouts in the world to upgrade to much more secure EMV Chip cards. None of them wanted to pay for those costly chip upgrades unitl now, when it’s almost too late.
If anyone was looking at the situation clearly back in 2005, they would have been able to forecast the trajectory we are now on – which is more and more devastating card breaches (ala TJX, Heartland Payment Systems) executed by more organized crime rings who know how to cash out the cards very quickly. A happy ending to this trajectory is far from sight. Indeed, why should the criminals stop when arrests are so far and few between, and when they typically enjoy immunity in their Eastern European countries of residence?
Clearly, PCI compliance is not working very well – despite billions of dollars spent by merchants and card processors in efforts to achieve it. For example, the standard hasn’t kept up with the latest attack vectors and retailers can’t be expected to know more than the security vendors do about detecting new forms of malware that evades conventional measures prescribed by PCI.
My understanding of the malware used in the latest round of breaches against Target and other retailers (allegedly there are many more that have not been announced) is that it attached itself in memory to the POS software (as opposed to being a memory scraping program as reported by others) and just captured the data as it went through the POS application. Like a worm, it had propogated itself to all the POS terminals throughout Target before attaching to the POS application. It aggregated the stolen data on a central Target server, and then double encrypted the data on the way out of the company so that the retailer IDS systems couldn’t detect it.
None of the conventional anti-malware applications on the market today look for this sort of program. And one question still not answered is how did it get inside the retailer network in the first place? Some security folks I spoke with said it got past POS whitelisting techniques used at retailers they work with – meaning perhaps somehow the supply chain was corrupted and the malware was attached to a routine POS software update.
Nothing I know of in the PCI standard could have caught this stuff. So I think it’s flat out wrong to blame this all on Target or on any of the other breached entities. The card issuing banks and the card networks (Visa. MasterCard, Amex, Discover) share responsibility for not doing more to prevent the debacles that have predictably occurred over the past nine years, when the big breaches first began.
At the least, they should have upgraded the payment systems infrastructure to support end (retailer) to end (issuer) encryption for card data much like PINs are managed today. They should have also started migrating to stronger cardholder authentication (ala EMV Chip cards) so that the magnetic stripe on the back of our cards can finally be eliminated.
While not perfect, these standardized measures would have gone a long way to preventing card data breaches. Instead the industry just keeps expecting retailers to patch a faulty and antiquated payment system via PCI compliance.
Of course, Visa, MasterCard and the qualified security assessors who perform the PCI audits have all covered themselves legally. That’s one area where they’ve been proactive. The assessor contracts that retailers and processors sign state that the assessor has no liability in the case of a breach. Further, when PCI first came out, Visa and MasterCard used to give merchants “safe harbor” from penalties in the case of breaches when the breached merchant was PCI compliant. But they eliminated that safe harbor right after the first big breach. When I asked Visa to explain, they told me “well the merchant must not have really been PCI compliant if they got breached. And perhaps they didn’t give their assessor all the information they needed to properly audit their systems.”
The banks and the card networks incorrectly assumed they could keep relying on the retailers and payment processors to lock down the payment system. That was shortsighted thinking that has unfortunately caught up with them as customer service costs mount and consumer confidence is shaken.
As for the merchants – they are still basically toast and not in an enviable position.
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