You’ve heard this story before. A major credit card company has experienced a massive breach. Tons and tons of data was stolen during the incident. They think they have it under control and are working with law enforcement. You should check your statements. Blah, blah, blah…

Once again, though, in this case, the company was certified as PCI compliant by their PCI auditors. If they were all compliant and filled to the brim with “fluffy, compliant goodness” then the attackers must have used some uber-hacking technique, right? Some bleeding edge tool or 0-day exploit that cut right through their defenses and rendered their compliant protections useless? Ummm…. NO…. The mighty technique that caused the damage? A sniffer!!!! (Some of the best technology that the late 80’s/early 90’s had to offer…)

How did I reach this conclusion? From their own press release:

“Last week, the investigation uncovered malicious software that compromised data that crossed Heartland’s network.” — sounds like a sniffer to me….(and a lot of other infosec folks…)

That’s right, the mighty sniffer strikes again. In the last couple of years, this same attack footprint has occurred over and over again. It has been largely successful. Why? Because companies don’t encrypt credit card data in transit across networks. Sure, many of them encrypt the database (not all, but many.) and some use various forms of endpoint protection, but many (way too many apparently) don’t encrypt the credit card data in transit across their networks.

Even worse, the PCI DSS DOES NOT REQUIRE THIS. That is how they can be compliant with PCI and still have this issue. What a cruel joke for consumers.

The DSS requires that organizations encrypt credit card data when it flows across “open, public” networks. Well, guess what, when your network gets compromised, even your “internal, private LAN”, it becomes “public” at least for the attackers. Misconfigure a firewall rule, get a workstation popped, allow a social engineer into the environment and that “private network” is not so private anymore, is it?

But, that never happens, right? Except when it does.

In my opinion, it is high time that organizations realize that compliance is not security. Compliance is a false goal set in sand. The real goal is risk management and data protection. In order to accomplish these goals, you have to make rational decisions and account for real threats, not just checklists compiled by some nebulous group of people in a “one size fits all fashion”. That is a fool’s errand.

As I have been saying for a while now, we have to start thinking differently about security. We have to forget the baselines and look at our risk from the view of a threat agent (a hacker, cyber-criminal, attacker, whatever!). We have to make rational choices that really do protect that which needs to be protected. We have to hope for the best and architect for abject failure. Anything less than that, and this is a story you we will just get to keep on telling….

Interested in learning more about “sniffing”? Click here for a great FAQ.

I also did an interview with Secure Computing Magazine about this. You can read that here.