PIN on Mobile

PCI: Software-Based PIN Entry on COTS (a.k.a. PIN-on-Mobile)

Almost four YEARS ago I wrote Software PIN, the Rosetta Stone of Future Payments, then just over a year later I wrote; Mobile Authentication: Exceeding Card Present Security?

Just this month the SSC finally came out with their Software-Based PIN Entry on COTS Security Requirements v1.0.

[Ed. While I don’t have to wonder why PIN was my primary focus, I can see how pointless it was …almost. It just makes the delay on this standard that much more inexcusable.]

On with the story… Software PIN is more commonly referred to as PIN-on-Mobile (or the catchier PIN-on-Glass), and is the ‘game-changing’ technology that will; “enable merchants to accept PIN-based payments with the PIN entered on a commercial off-the-shelf device, such as a consumer-grade mobile phone or tablet.”

What has taken them so long to make what – from my jaded perspective – is the only move that will delay their inevitable demise? It’s not like there was some miraculous innovation in mobile or encryption technology in the last couple of years! Every requirement in the standard was available/achievable long before I even wrote my blogs. As were viable solutions for that matter.

I suspect there’s lots of reasons of why they were so slow, but chief amongst these has to be their complete inability to adapt to the fast-paced innovation rampant in the FinTech industry. Especially given their hopelessly antiquated technology. It’s only their global adoption and sheer ubiquity that keeps them where they are. I blame the banks too, change for them means acceptance of liability.

Come to think of it, what an amazing coincidence that PSD2 – the biggest nail in the payment card’s coffin since …well ever, came out this month as well. Weird huh?

As far as I am concerned, PIN-on-Mobile was the card brand’s last hold-out, now they’re done. Hopefully between the XYZ-Pays (ApplePay, SamsungPay etc.) and now the entry of cardholder PIN on [almost] any CoTS device, big merchants / retail associations will finally have the balls to stand up for themselves.

How many millions have they spent in the US on EMV terminals just to find out a few years later that it was not only entirely unnecessary, but they’re now tied into an investment that will leave them lagging behind their competition who were slower of the EMV block?

I know that’s harsh, and we really have no right to judge. Have any of the following questions ever occurred to you?:

  1. If I can use my phone to pay for something, why do I have to tie that payment to a branded card?;
  2. With all of the security requirements required for the entry of a software PIN, why the Hell do I still have to use one? In other words, if it’s that bloody difficult to secure it, why not use something else?; and
  3. Isn’t there a better way!?

If you’re like the majority of the population, these questions are more like:

  1. Why doesn’t MY bank support this?! (looking at YOU Barclay Business!), or more commonly; why would I use this service when I have a piece of plastic?;
  2. What’s wrong with PIN?; and
  3. [nothing]

The fact is that the lion’s share of the cashless transactions globally are performed by those who have never known a time before payment cards. We simply can’t imagine anything else and we don’t even notice their inconvenience. We also don’t see the costs imposed by the middlemen.

But let me ask you this; Would you ever go back to using a feature phone? I’ll [almost] guarantee that you had no idea what features you wanted in a phone until you used a smartphone for the first time. And now you can’t live without it. Hell, most of us can’t even put the damned things down!

The same thing WILL happen to payments, but not until consumer indifference is overcome by something shiny and new.

Frankly this blog is boring even to me, and I really have nothing more to say about payment innovation that I have not already said a hundred times. But I simply can’t let anything so patently meaningless as PIN on Mobile to go unanswered.

Innovation my arse.

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If AI is the Answer, You’ve Asked ALL the Wrong Questions

For those reading this who are cybersecurity professionals (and who else would read this crap?); In your entire career, have you ever come out of the back-end of a risk assessment and said; “We need Artificial Intelligence.”


I seriously doubt it, unless you happen to sell artificial intelligence, or more likely, you’re trying to pass off your product as artificial intelligence.

But let me just clarify before I continue whining; AI is exciting as Hell, and I cannot WAIT to see what comes next. I am not in the ‘Skynet’ camp, and I even disagree with people a thousand times smarter than me. No, not my wife (this time), but the likes of Stephen Hawking, Bill Gates and Elon Musk, all of whom have issued their own warnings/predictions on the subject. I think AI is going to make our lives better in almost every way. Almost.

But not in cybersecurity at the organisation level. Not yet. Most businesses simply don’t have anywhere near the foundations in place to implement it appropriately, let alone effectively. Implementing any technology on top of broken processes and/or an indifferent security culture may only serve to make things worse.

I can see it in working the threat intelligence arena, where a behemoth like Alphabet – and their mind-boggling access to almost everything -, can fund something like Chronicle. But this is just one small part of a security program, feeding into the ages-old clichés of ‘defence in depth’ or ‘layered security’. AI is certainly not the panacea those with a vested interest would have you believe. Basically, if you don’t have the same access and deep pockets as Alphabet, you should be probably be focusing on the hundreds of other things you should have done long before now.

And even if there was an AI ‘appliance’ that you could just plug-and-play on your network, do you honestly think the bad guys won’t work out how to circumvent it with some AI tricks of their own? Regardless of the technology, the good guys always have to play by the rules and the bad guys will always do whatever it takes. This is not a fight we are EVER going to win, so stop trying. The only thing we can do, and the sole premise of my career, is to minimise the damage. Security folks are the definitive guys bringing a knife to a gunfight. But we will fight.

This is neither cynical, nor a cop-out, it’s reality, and spending money on a technology you’ll never understand, or maintain yourself, is not going to change that.

But none of this will stop organisations spending money on nonsense. On the one side you have product vendors, technology-centric consultants, hype in the press, and indifferent CEOs. On the other side, you have the ages-old security basics and a very limited number of stubborn practitioners. It’s not really that surprising that acronyms and the latest shiny-things get all the attention, just unfortunate.

In fact, it’s no different from ‘get rich quick schemes’ or ‘diet pills’, there are very few shortcuts to wealth and none to losing weight. Both involve getting off your lazy arse and doing something. So does security.

But most of all I simply can’t abide vendors who try to fit every single problem into the one thing they can do. From operationalising the whole of GDPR with ISO 27001, to solving every limitation of digital payments with biometrics, the attraction of the silver-bullet is just too much for some to resist. AI and machine learning are the latest purveyors in a long line of empty promises.

Perhaps I’m no better, all I can do is help you implement the basics. But I’ll guarantee what I’m selling is a damned sight cheaper and significantly more permanent! 🙂

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Top 10

Froud on Fraud’s Top 10 Cybersecurity Technologies to Implement in 2017

In direct response to a certain organisation’s ‘Top 10 Cyber Security Technologies to Watch in 2017’, [cough, Gartner, cough], I have come up my own list of bleeding edge security technologies that every organisation should spend millions of $/£/€/¥ on.

Yes, even if you don’t MAKE millions, you should borrow the money and buy them anyway.

Being honest, my fight to bring security ‘back to basics’ has failed – despite my enormous 210 person following – so I have decided to sell-out and promote nothing except buzz-phrases and acronyms. You know, like everyone else.

However, I am convinced that if you buy, implement, and actually take these technologies seriously, you can forget the security basics. The combination of these 10, never-seen-before, shiny new objects will provide the silver bullet you’re looking for:

  1. Directorate Approbation Paradigm (DAP) – Historically, achieving ‘management buy-in‘ was the ultimate goal for anyone attempting to implement a security program. Quite rightly, caring about the future of an organisation was considered naive, and proponents of this stone-aged technology were left begging for work on LinkedIn. Some of these poor souls even became CISOs. Now, with DAP technology, every single person in an organisation will take security seriously, even if their bosses don’t!
  2. Command & Control Commission (CCC) – While not strictly a technology the CCC is responsible taking the output from the EIC below, combining it with the DAP above and obtaining the budget to buy everything else on this list. This is the spider in the middle of the web, making sure that all technologies work together. Called ‘governance‘ in the old days, the new CCC is clearly superior given that you’ve never heard of it, and it’s an acronym.
  3. Protocol, Method, & Archetype Orchestrator (PMAO) – Much as leeches were seen as the go-to technology in medieval medicine, ‘policies, procedures and standards‘ were seen as a foundation for every security program. While clearly nothing more than a quaint superstition, they nevertheless laid the groundwork for the PMAO revolution. Imagine it; a series of artefacts designed to record not only an organisation’s entire security culture, but their process knowledge and system baselines as well! No way just policies, procedures and standards could do all of that!
  4. Exposure Investigation & Computation (EIC) – I almost feel sorry for the poor saps who only had the ‘risk assessment‘ process to measure their risk profile. Can you imagine basing you risk treatment and technology purchasing decisions only on expert opinion and business goals!? Instead, EIC, in combination with AI, big data, The Cloud, and fairy dust, can tell you exactly how many millions to spend on technology! No more embarrassing moments when you try to explain to your boss how you tried to save them money by fixing the actual problem! Like people and process could ever be the problem!
  5. Intelligence Preservation Administration Schema (IPAS) – Can you imagine the nerve of the International Standards Organisation when they came up with the Information Security Management System (ISMS)? A so-called ‘framework’ designed for “systematically managing an organization’s sensitive data” with – and you won’t believe this- “a set of policies and procedures”! How naive! Instead, with IPAS, you can basically ignore the hard work and common sense approach to doing security properly and hide behind an expensive appliance with flashing green lights! Blinking green, you know it’s working!
  6. Transformation Regulation Authority (TAR) – Before the advent of TAR technology, organisations across the globe relied on a ‘change control board’ to ensure that unmeasured risk was not introduced into an environment. As yes, once again, actual humans – apparently those with ‘expert’ knowledge – were allowed to determine what was right for the business. A clearer case could not be made to put this in the safe ‘hands’ of technology written by someone else.
  7. Episode Reply & Adversity Restoration (ERAR) – We’ve all seen those commercials from the 50’s where attractive actors extolled the virtues of smoking? Well, ‘incident response & disaster recovery‘ were just as misleading, and just as dangerous! Like anything involving people and process could possibly help you stay in business! ERAR on the other hand, will not only detect bad things happening, it will keep your business up and running! Surely THAT’S worth a few million all by itself!!
  8. Capital Durability Projection (CDP) – The future of any organisation should never be placed in the hands of those who care. The experiment called corporate social responsibility failed because it was assumed that it’s the people who are the most important aspect of a business. At least now we know it’s money that’s most important, so the old concept of ‘business continuity planning’ can be replaced by EDC and those making the world better with technology. Finally the people can be safely ignored.
  9. Asset Management (AM) – This is one aspect of security where technology is actually sadly lacking. Asset management is the centre of everything, and without it, no other aspect can be truly be done well. Spreadsheets just don’t cut it, and no GRC that I’ve seen gives asset management its due. This much change, even in The Cloud.
  10. Continuous Compliance Validation (CCV) – This is an idea whose time has come, it’s about time technology provides a REAL solution to overly manual processes.

All facetiousness aside, I am a huge fan of technology. Or more accurately, I am a huge fan of the appropriate application of technology. If you buy something based on anything other than 1) the results of your risk assessment, and 2) answers to the RIGHT questions, you have no business being in charge of a budget.

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Disruptive Innovation

Enough With the Disruptive Innovation. Collaborate or Fail.

[This is taken in large part from from an earlier blog, but I feel it needs updating to include more than just payments.]

‘Disruptive Innovation’ has become a common cry for anyone wanting to displace the existing players. It is defined as; “an innovation that helps create a new market and value network, and eventually disrupts an existing market and value network (over a few years or decades), displacing an earlier technology.

Unfortunately the original concept is now grossly misapplied. But like how ‘irony’ now has several meanings, I guess disruptive innovation will have different meaning based on its context.

However, I’ve never heard anyone using the phrase ‘Sustaining Innovation’, which; “does not create new markets or value networks but rather only evolves existing ones with better value, allowing the firms within to compete against each other’s sustaining improvements.

So why is everyone so interesting in disrupting the existing ecosystems? And by “everyone” I of course mean those who are trying to either break into market, or those trying to wrest even more control for themselves. In payments – as my example -, non-cash payments work [mostly], and you have a large degree of faith in your bank’s ability to protect your monetary assets. Do you really want the whole thing to change? Do you even know what it is that you want that’s different?

But do things even need to change? Well yes actually, they do. And are there innovations available NOW that make the payments process easier, cheaper, and more secure for the consumer? Yes, there are. However, can we expect the entire payment industry to throw out everything they have spent billions on over the last few decades, are used BY billions, just to make room for every start-up with a good idea? No, we can’t, and that’s the real issue here.

In the last 10 years there have only been 2 true [potential] disruptors in the payments industry; the mobile phone, and block chains (Bitcoin et al), neither of which has achieved anywhere near its full potential. Yet. Not because the technologies are flawed [necessarily], but because the introduction OF the technologies was done poorly. For mobile devices, the payments challenges included the ‘fight’ between NFC and BlueTooth, the numerous options for security on the device (Secure Elements, Trusted Execution Environments and so on), and the presumed insecurity of the technology overall. For block chains is was, and still is, the almost complete lack of understanding of how they even work in the first place. I’ve looked into them and I still find the concept nearly incomprehensible.

But even these disruptors need current context, and they represent a fundamental shift from our overly complicated view of payments back to its basics; I go to work to earn value (money), the value gets stored somewhere (a bank), and I access the value when I want it regardless of time or location (mobile payment). This would suggest that the only disruption we really need is the disintermediation of some of the players. There are simply too many middle-men whose only input to the new world of payments will be value erosion. Thank God the Mobile Network Operators (MNOs) are too busy bickering amongst themselves or this would be even more complicated!

As a consumer who has a very good idea of what he want to see change, I know that only those who help the payments industry evolve will have a lasting positive impact, and this will only be through collaboration and fair competition.

I’ve used payments as an example, because that’s what I know the best, but the same can be said for almost every other industry sector. The drive to take away what others have, instead of providing a better service for the common good, is capitalism at its worst. And no, I’m not proposing some sort of socialism, it’s just logic; What’s easier? Completely replacing something, or improving what we have in collaboration with multiple players?

It’s not like there isn’t enough to go around.

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PCI L1 Service Provider

From FinTech Concept to PCI Compliant in 6 Months?

Anyone wanting to start a new business in FinTech/payments – digital wallets for example – has to address PCI. Like it not, payment cards are still the dominant form of non-cash payment on the planet. By far.

So what if you have a great idea in this amazing world of opportunity, but your skill-set is in payments and innovation, and not IT or cybersecurity. How do you get your service to market, AND play by the rules? Can you do this in time to be ahead of game given the incredibly short timeframe of today’s competitive advantage?

Well, you could just self assess, but you are restricting yourself to a maximum of 300,000 transaction annually.  But more importantly, would you trust your money to a service provider who self assesses? No, neither would I.

However, I’m talking about full Level 1 Service Provider compliance through a reputable QSA (yes, there are some out there). How can you set up the infrastructure, get all the documentation in place, AND get all the way through a PCI DSS Level 1 assessment in 6 months? And if you do, have you really done it properly?

The answer is yes, you can, but there are MANY caveats, and if you deviate from these steps you will not get there. I am only interested in helping organisations get compliant properly, I have no interest in adding more crap service providers to the ecosystem.

First, you have to completely ignore the PCI DSS. Any plans you make to design both your physical infrastructure and your security program from scratch must be with real security in mind. Never compliance alone. For that, many organisations turn to the ISO 27001 standard. There are others, but try finding affordable consultants who can help you implement them. As long as you realise they are all just frameworks, not step-by-step instructions, then you’re ready to start asking questions.

So What Are the Steps to Compliance?


  1. Get Help – This should be no surprise. I don’t perform emergency appendectomies, I’m not remotely qualified, why would you try to achieve compliance when that’s not your experience or skill-set. Yes, is can be expensive, but nowhere near as expensive as any of the alternatives. There are some very good consultants out there, do your homework and find the best one for you.
  2. Outsource the Infrastructure – Unless you’re an expert in everything from hardened operating systems, to logging and monitoring, to firewall management, you will want to outsource as much of the platform as you possibly can. Unfortunately, finding a single provider who can take on anything more than physical hosting and some networking stuff is still ridiculously difficult. Amazon Web Services (AWS) for example is about as bad as you can get. Unless of course you want a dozen or so independent service providers to manage along with Amazon.
    You MUST ask the right questions, and this is where your  consultant comes into play. S/he will write your RFP, interview providers, and eventually produce a responsibility mapping of services against the PCI DSS. This will match their Attestation of Compliance, as YOU should only do business with L1 PCI compliant service providers.
    You are welcome to use my mapping if you don’t have one: PCI DSS v3.2 SP Responsibility Mapping
  3. Policies, Standards & Procedures – You have to start somewhere, so you will likely want to buy a Policy Set. Once again, you have to be very careful as there are dozens of options but few will be fit for purpose. In this case, ‘fit for purpose’ means the service must 1) get you through compliance, 2) provide a platform for your unique culture, and 3) be self-sustainable for the long-term.
    If you buy a Policy Set with ‘PCI’ in the title, you have already failed. Buy one that your consultant can customise on your behalf, and then teach you to manage yourself. Get one that; 1) Is already mapped to both the PCI DSS and your chosen framework (usually ISO 27001), 2) has document management built in (numbering, content standards, assigned coordination etc.), and 3) is easily distributed to the subject matter experts best placed to maintain them.
    I have written a quasi-white paper on how to choose the right the right service, you use the questions as an RFP: ‘Selecting the Right Policy Set
  4. Hire a Completely Independent QSA – While it may be very tempting to have your consultant take care of all the ‘PCI stuff’, bite the bullet and keep these separate. No, you don’t have to be an expert in this stuff, but if you are relying completely on your consultant you are building in a single source of failure. By all means have your consultant run with the assessment, but be involved. If you don’t, you’ll have no idea what you paid for in the first place. In fact, you may even want to build in some SLAs regarding how much remediation is required from by QSA. There will always be some, but if it involves significant scope creep or capital cost, your consultant has failed you. Remember, you have outsourced almost the entire function of PCI to your platform provider, validation of compliance should be a formality.

Of course this is oversimplified, but I’m already way over my self-imposed word limit. However, while I haven’t included any of the inevitable challenges, the process is a simple as security itself, it’s up to you to find someone who can make it simple.

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