The recent public disclosures at Hannaford Bros of millions of credit card numbers lost to professional carder gangs again raises questions regarding the state of preparedness of retail security and other industries to protect customer data in the current cyber threat environment.  In the case of Hannaford, these gangs may have followed a pattern familiar to network forensics researchers with whom we work – a weak link in the security program is exploited as a foothold to open a command and control channel on the victim network.  After that, it is just a matter of time before critical POS servers or store terminals are Trojanized, and are automatically transmitting perfectly valid customer credit card numbers directly to carder gang members. 

The amount of ensuing punditry is astounding.  First, the horror and shock from some corners that PCI Standards did not prevent this debacle.  For good or bad, PCI was the credit card companies’ much needed attempt to enforce some level of basic information security on organizations with merchant accounts.  The security controls in PCI were designed years ago, and are focused on well-understood and documented threats and essential security practices.  But, PCI compliance, due to its very nature, is not going to provide adequate protection against a well-funded and committed professional adversary who can design specific malware to circumvent these basic security controls. 

There also have been calls to jettison PCI.  The premise in these statements is that if the card companies would simply take responsibility for the storage and security of credit card numbers from the moment of card-swiping forward, there would be no need for retailers to comply with some key aspects of PCI.  This position, while seemingly attractive at the surface from a security perspective, is untenable in a multi-trillion dollar consumer facing industry.  The reality is that the same architectural, procedural, technological, and financial constraints preventing retailers from adequately protecting their data in many cases will prevent the card companies from implementing the suggested changes. 

Having spent time with top retailers over the past several years, I can tell you that there are many very good security people working at these organizations, but with limited ability to get things done.  These I/T professionals would benefit greatly from two things:  1) A self-directed industry effort to develop voluntary, model security standards that would deal effectively with today’s actual threat environment, versus force them to follow check lists.  This process requires leadership, organization and resources; and 2) A greater focus on operational security efficacy.  PCI was only good in the sense that it jolted retailers to focus on “Security 101” but it is not the end – simply a catalyst.  Retailers and other industries that handle PII now must take matters in their own hands and move beyond PCI and other regulations to recognize that today’s threat environment requires a deeper degree of security monitoring and network visibility, especially at the application layer.   

You can’t get this visibility from once-a-quarter scanning, annual audits, or even from most of the perimeter sensors deployed today.  If you are not doing full packet capture and session analysis with NetWitness you will miss indications and warnings of these TJX and Hannafords-like problems, and also will lack the evidence to figure out the scope and damage of the incident.   – Eddie Schwartz