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        cardholder data environments (CDEs), whereas in version 3.1 the requirement   years. TLS 1.3 is currently being test-
        applied to remote access only. It also enforces stricter controls for documenting,   ed in the market. The PCI SSC started
        tracking and managing changes to CDEs.                                     encouraging organizations to switch
                                                                                   protocols in 2015, shortly after the
        One  company  working  to  eliminate  system  vulnerabilities  is  Conformance   National Institute of Standards and
        Technologies LLC. The firm offers full-system penetration tests through its Cy-  Technology issued a warning that the
        ber Attack Readiness ToolKit. "Our numbers are, with our penetration test, that   SSL protocol was no longer reliable.
        in 100 percent of the tests we've done, we've been able to break into the mer-
        chant system," said Darrel Anderson, President of Conformance Technologies.   "The most notable vulnerability was
        "We find vulnerabilities that would allow a hacker to get in, 94 percent of the   called POODLE (Padding Oracle On
        time we find credit card numbers."                                         Downgraded Legacy Encryption),"
                                                                                   Leach said. "Not only was it able to
        To prevent system vulnerabilities down the road, Conformance Technologies   break down the protocol, you could
        automates compliance processes with its PCI ToolKit, which features online   not detect it, if successfully launched.
        calendaring system reminders for system checks and a policy generator mer-  You could think that you had a se-
        chants can use for training. Its InConRadar (Internet Content Radar) monitors   cure encrypted channel, and in the
        merchant websites in real time for suspected illegal activities, catching some   middle,  what  we  call  a  man-in-the-
        merchants unaware.                                                         middle attack, they could decrypt
                                                                                   that information, steal it, re-encrypt
        Another PCI compliance requirement mandates that as of July 1, 2018, orga-  it, and neither the sender nor the re-
        nizations must migrate from Secure Sockets Layer (SSL) and early Transport   ceiver would know that there was a
        Layer Security (TLS) data encryption and authentication protocols to the more   compromise."
        secure TLS version 1.2. Certain POI (Point of Interaction) terminals have been
        exempted from this requirement.                                            The protocol change for organiza-
                                                                                   tions with larger infrastructures and
        Many consider this security requirement long overdue, since SSL is based on a   older technology has proven chal-
        22-year-old technology and its replacement, TLS 1.2, has been available for 10   lenging for some, but for smaller mer-
                                                                                   chants with modern web-browsers
                                                                                   the transition has produced less fric-
                                                                                   tion, Leach noted. To assist with the
                                                                                   protocol migration, the PCI SSC  of-
                                                                                   fers several resources on its website,
                                                                                   including  a  webinar  and  the  seven-
                                                                                   page  Information Supplement: Migrat-
                                                                                   ing from SSL and Early TLS.
                                                                                   Cross-industry collaboration
                                                                                   In February 2018,  the  PCI SSC and
                                                                                   Accredited Standards Committee X9
                                                                                   Inc.  (ASC  X9),  an  ANSI-accredited
                                                                                   organization  that  manages  approxi-
                                                                                   mately 100 domestic and 58 interna-
                                                                                   tional standards for the financial ser-
                                                                                   vices industry, joined forces to create
                                                                                   a unified PIN Security Standard. The
                                                                                   organizations currently maintain
                                                                                   separate PIN security standards: the
                                                                                   PCI PIN Security Standard and X9
                                                                                   TR39 PIN Standard.

                                                                                   Consolidation of the two standards
                                                                                   will simplify efforts for organiza-
                                                                                   tions subject to both standards. "Both
                                                                                   standards  are  used  for  auditing  the
                                                                                   networks, and the auditors have to
                                                                                   be trained and certified to be able to
                                                                                   audit to one or both of the standards,"
                                                                                   said Steve Stevens, Executive Direc-
                                                                                   tor for the ASC X9.

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