Post Heartland Breach Analysis and PCI Compliance Limitations

Eric Ogren, writing for and Evan Schuman and Fred Aun, from, have some insightful commentary regarding the tactics used by hackers to breach Heartland and how they relate to the limitations of the current PCI Compliance standard. 

I think the key take away here is that compliance does not necessarily equal security. Here are a few highlights from their articles:

Eric Ogren
1. The hackers ran their malware through 20 AV products to test detection avoidance.  AV is very good at stopping known attacks of mass destruction, but is quite a bit less good about catching low profile designer attacks. Effective security should augment AV filters with technology that reflects control over the unique aspects of the organization's server and endpoint configurations. IT has choices here – application whitelisting on locked-down servers will prevent execution of unauthorized software, thin clients prevent attacks from persisting at endpoints, virtual desktops and servers give IT control over endpoint configurations and automated patching systems close windows of vulnerabilities. PCI should be more assertive in recognizing that signature-based schemes and reputation services will not catch low volume activity that is the trademark of malware designed to steal information.

2. It would be nice if PCI could have protected 7-Eleven and others from the same attack technique that befell TJX years earlier.

Evan Schuman and Fred Aun
1. One retail security expert, who has firsthand knowledge of defending against these defendants and who agreed to discuss the indictment if neither her name nor employer was identified, said much in the indictment points out inherent weaknesses in PCI. The back door approach used, a time-honored hacking technique for decades, is a red flag. “Being on the inside, these probably would have passed right through firewalls as the data would be travelling in the ’safe’ direction. Also note that any gains a company would have from a password rotation scheme would be negated by the installation of a back door. My main point there is that password rotation schemes are not an effective defense, and shouldn’t be elevated to such by PCI or corporate ’security policies.’ In any case, Hackers 2, PCI 0.”

2. The SQL injection tactic points out an especially significant PCI flaw, the expert said. “PCI doesn’t say boo about SQL injection attacks. It only says you must maintain secure systems and applications and review the applications annually. But reviews are ineffective on unknown bugs – they can only help recognize bugs the reviewer actually knows about.”

3. Another concern that she listed involved Heartland details. “The attackers installed sniffers to capture the traffic, they did not harvest data intentionally stored by Heartland on hard drives. PCI doesn’t say anything about encrypting data on private networks, only that you must protect stored cardholder data or encrypt data traveling over open, public networks. And the networks obviously have the business need-to-know, that’s what they do: carry data. That’s a three-point shot for the Hackers; Hackers 6, PCI 0.”

4.  Yes, PCI compliance may have successfully defended Heartland against lesser attackers. But the bottom line is that Heartland could have been (and probably was) breached while being 100 percent PCI 1.1 compliant on all their points. The real observation here is that PCI DSS compliance was completely ineffective against these guys, no matter how the PCI guys spin it.

“PCI says that you must regularly test security systems. These hackers dodged every bullet point of PCI. A test would (and probably did) prove nothing more than PCI-test-detectable breaches would have been detected. And finally, the hackers apparently didn’t feel compelled to comply with corporate security policies. Game, set, and match: Hackers 12, PCI 0,”

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