Quote from your source:
> If your scan fails, you must schedule a rescan within 30 days to prove that the critical, high-risk or medium-risk vulnerabilities have been patched.
Scan in this sentence refers to "a PCI DSS external scan".
The list of approved vendors that can conduct PCI DSS external scans can be found here: https://www.pcisecuritystandards.org/assessors_and_solutions...
Please find cybernews' certificate number there and quote it for us, I have looked and can't find it.
I would guess that, contrary to your implication, they are not an approved scanning vendor. If this is the case then it really does not speak to the characteristics of PCI-DSS and your comment just seems wrong.
And even if they were an approved scanning vendor, from what little I know about PCI-DSS, these scans are part of larger process - so even if they were an approved scanning vendor the scan failure would still have had to be part of the larger process for this 30 day limit to apply.
I could go on and on about how much I hate PayPal and random other things, but just because I don't like something does not quite justify making false claims about it.
Actually this makes a pretty good case for this regulation being a joke. They clearly aren’t up to the responsibility of being a payment processor and are leaning on the law to sustain their business rather than simply demonstrating aptitude directly.
Because it's a scanner for PCI-DSS compliance, not a scan for security issues.
They do not fear that unapproved scanners will be more strict than approved scanners, they fear they will be less strict.
PCI-DSS is not government regulation, but an industry created and enforced standard. Compliance is not mandated by federal law and only a couple of states have laws that reference it. For example, Nevada requires compliance while Washington doesn't require compliance but does remove liability for breaches for compliant businesses.
Did you read downthread about the actual "2FA" feature this team "bypassed"?
It's not the size that matters, but how you use it that counts.
Regulations can be self-imposed on an industry, it does not have to be something the government imposes. Calling PCI-DSS a regulation is still accurate despite many people conflating the term "regulation" solely with government action. In this case, the authority creating the regulations is the PCI Security Standards Council who have their power because the big players in the industry give it to them.
Don't look behind the curtain.
All of HackerOne's information that you cite is about them being PCI-DSS-compliant or having undergone a SOC2 Type 2 audit. Nothing you link to identifies them as a PCI-DSS auditing company. They are not.
And the "scans" the PCI-DSS standards refers to are standard pen-test and external vulnerability scans, usually conducted by an accounting company who will certify the scan results. They are for known vulnerabilities, things like the version of Apache you are on, etc. None of the reports sent via HackerOne would qualify as a "scan" under PCI-DSS.
Please read the page again. They specifically say you can achieve compliance certification with HackerOne.
On top of that, there's not really any legal issues for being non-compliant, as has been pointed out elsewhere in this thread.
HackerOne offering PCI-DSS approved auditor approved challenges gets you nowhere towards the claims you made in your first comment.
To review:
1. HackerOne would have to be a PCI DSS Approved Scanning Vendor - they are not AFAICT, neither is the CyberNews research team that did the scan AFAICT.
2. HackerOne would have to have conducted the scan - they did not. The CyberNews research team did.
3. The scan that HackerOne did would have to qualify as a PCI-DSS external scan - which ... do you get the part that HackerOne did not do the scan here or not? And nowhere did the CyberNews research team claim they performed a PCI-DSS external scan.
Please at least try to make an argument for your claims
Meet pentest requirements for PCI DSS, SOC2 Type II, and HITRUST compliance certifications.” [1]
Further, that has absolutely nothing to do with anyone reporting vulnerabilities through HackerOne. That is not a scan by the definition of PCI-DSS, the SOC2 trust services criteria, or any other security framework you care to name.
Just give it up. You're wrong.
Not anywhere on the page you linked. And a "PCI-DSS auditor approved organization" is not a "PCI-DSS approved scanning vendor" which if they were you could just quote the certificate number instead of link to HackerOne.
----
EDIT: I guess you are referring to this:
> Meet penetration testing requirements for PCI DSS and SOC2 Type II compliance certifications with our auditor-approved penetration testing methodology and Security Assessment Report.
This in no way is the same as claiming "we are a PCI-DSS auditor approved organization". Which again, would be irrelevant if it was the case.
----
Further, if you read the article, it is clear the "We" does not refer to "HackerOne".
> When we pushed the HackerOne staff for clarification on these issues, they removed points from our Reputation scores, relegating our profiles to a suspicious, spammy level.
As far as I can tell "We" refers to cybernews.com
And again even if cybernews was a PCI-DSS approved scanning vendor it would still have to qualify as an official external scan within the PCI-DSS framework.
Read the page carefully - it specifically states they are an auditor approved org.
Quote from page: “Meet penetration testing requirements for PCI DSS and SOC2 Type II compliance certifications with our auditor-approved penetration testing methodology and Security Assessment Report.[1].”
Secondly, PayPal works with HackerOne officially [2] and within the CVSS standards as they clearly state on their HackerOne page, which is complying with PCI DSS.
[1] https://www.hackerone.com/product/challenge
[2] https://hackerone.com/paypal
Edit: Archived incase:
This comment chain has convinced me that PCI-DSS is a farce.
Emphasis mine.
"...satisfy the requirements for external penetration testing for audited PCI DSS and SOC2 Type II certifications."
"Final Report Delivered. Ready for Auditors."
Take a wild guess on what you think will happen.
The purpose of PCI is to shift liability
It just isn't reasonable that PayPal would be cut off. That was always a toothless threat, at least for larger players.
As an aside, PayPal is a marvel to me because it is effectively lost in time. Using their tools and interface is like stepping back to 1995, and it seems -- from an outsider perspective -- that it must be some duct-taped quagmire that is barely holding on.
No? They were created by the industry to avoid actually being regulated and are a way to shift liability.
That doesn't mean they aren't also beneficial, but that's more a side effect than the intention.
If we want to be cynical, of course there was a self-serving reason they created the standards -- because fraud, especially "internet" fraud, was on a massive upswing and it threatened this enormous new market of credit card spending. There is no question it's in their self-interest to improve the general condition of transactions.
It's not cynical, it is literally the reason PCI exists.
> Five different programs had been started by card companies... The intentions of each were roughly similar: to create an additional level of protection for card issuers
- https://en.wikipedia.org/wiki/Payment_Card_Industry_Data_Sec...
You said -
"avoid actually being regulated and are a way to shift liability"
This is like saying a store put razors in a locked case to avoid being regulated. Or they simply don't want their stuff stolen?
I was being facetious when I said if we want to be cynical, because of course everything any business does is in their own self-interest. Of course it is -- that goes without saying, unless one is just trying to be glum.
Equating credit card fraud to physical theft is silly. The intermediaries of the credit card industry earn revenue by charging fees to process transactions. When fraud occurs, they're only liable if they were some how responsible. PCI allows the network to shift liability to the periphery and to allow the central network to deny taking responsibility for systemic problems with the infrastructure.
To use your razors analogy, PCI is like Gillette shipping razors lose in a box to CVS and telling the store that it is liable if anyone gets cut or the razors get stolen AND Gillette can fine them if anyone gets cut or razors get stolen. But that's not how it works, in the real world razors come with safety covers in tamper evident sealed plastic clam shells.
In both cases someone is out money. It isn't a difficult step.
Fraud costs the credit card industry. It costs issuers (they shoulder 60% of the direct cost), merchants, and it costs the future of the industry because it is a nuisance for end-users.
They make a standard of best practices to reduce fraud. Following those best practices is good for every single participant, outside of criminals. Reducing fraud wholesale is the goal, obviously.
Spinning this in a nefarious fashion is not helpful to anyone, and does nothing but muddies the waters.
PCI identifies recommended mitigations and imposes penalties for failures, but it doesn't ensure or validate compliance. It simply shifts liability from one stakeholder to another.
No one is spinning this as nefarious, but rather information that should be taken into consideration.
Or is that one much like GDPR? Crazy fines that only big players can afford, in such a case, that was poorly designed.
> Up to €10 million, or 2% of the worldwide annual revenue of the prior financial year, whichever is higher
> (1) Each supervisory authority shall ensure that the imposition of administrative fines [shall] be effective, proportionate and dissuasive.
> (2) [...] When deciding whether to impose an administrative fine and deciding on the amount of the administrative fine in each individual case due regard shall be given to the following:
> the nature, gravity and duration of the infringement taking into account the nature scope or purpose of the processing concerned as well as the number of data subjects affected and the level of damage suffered by them;
> the intentional or negligent character of the infringement;
> any action taken by the controller or processor to mitigate the damage suffered by data subjects;
> the degree of responsibility of the controller or processor taking into account technical and organisational measures implemented by them pursuant to Articles 25 and 32;
> any relevant previous infringements by the controller or processor [and other specified criteria]
> (8) The exercise by the supervisory authority of its powers under this Article shall be subject to appropriate procedural safeguards in accordance with Union and Member State law, including effective judicial remedy and due process.
They can't just arbitrarily decide to fine you the maximum.
Fining a small mom and pop site 20 mill (20mil/4% is the highest fine depending on the case) is not proportionate, not effective because I would like to see them actually collect on that and I would say such a fine to a mom and pop would be dissuasive of doing business at all which is not that the ICO in the U.K. would want. Speaking of the ICO, their big fine (fucking auto correct) to BA for shockingly bad security earned them a 1.5% fine instead of the max 4% because they worked with the ICO (but the ICO still found they failing in a duty of care to protect data) and have been pushing the fine down the road ever since it was issued, atm the earliest ICO will actually fine BA is next month and it’s been almost a year since they filed their "intent to fine".
So while they can throw around heavy fines. It’s not like they run every mom and pop site out of the country.
Welcome to the EU. They've pulled these stunts before. When they introduced changes to digital VAT collection the lawmakers "forgot" that VAT has exemption thresholds. This effectively barred some small and micro businesses from selling their digital services/goods to other EU countries, because the business would not have been exempt from VAT afterwards. It took the lawmakers years to implement a minimum VAT threshold.
>It’s not like they run every mom and pop site out of the country.
Of course they won't, because people want to do business. There will always be more businesses that get started. The question is whether there will be fewer businesses started because of the regulation. So far analysis after GDPR points to yes.
The max(€10m, 2%) and max(€20m, 4%) are the most that supervisory authorities may issue as fines.
But supervisory authorities have a legal duty to issue fines that are proportional which means than unless you breach the GDPR in a wilful and egregious manner you're unlikely to be fined that much (and if you are you can appeal the fine to a court who would reduce it to a proportional amount).
Is the law as written somehow vulnerable to some legal hack where all my revenue goes through Company A but all my data goes through Company B, so that Company B has a small global revenue despite being extremely profitable to the controllers of the companies?
No. Who the data controllers are is a matter of fact, not assignment.
To quote the Court of Justice of the European Union in the Fashion ID case (C‑40/17) at paragraph 68:
"[A] natural or legal person who exerts influence over the processing of personal data, for his own purposes, and who participates, as a result, in the determination of the purposes and means of that processing, may be regarded as a controller".
Furthermore, as per that case, multiple data controllers may exist for some processing activities.
So both Company A and Company B may be considered to be Data Controllers and thus both liable.
> Up to €10 million, or 2% of the worldwide annual revenue of the prior financial year, whichever is higher
I'm no lawyer, but this doesn't sound like it's just for the bigger players, at the minimum you'd be looking at some fines. At minimum you'd be paying 10 million if you incur that amount of fines. I guess it could be argued the 2% is geared towards hurting the big players.
[0] https://gdpr-info.eu/art-83-gdpr/ Art. 83(4)
This really downplays the report or shows a complete lack of understanding.
Getting access to someone's Paypal account which could potentially mean all their credit cards and banks is definitely an issue that needs to be addressed. This in itself should not be reason to lose PCI certification.
However, as the article further indicates [1], failure to respond (or even closing the issue without resolving) is a completely different story.
[1] https://cybernews.com/security/we-found-6-critical-paypal-vu...
Getting access in this way to users' financial accounts is absolutely a vulnerability.
Ok, first, and foremost, don't you think it's a problem if there are stolen accounts? Wouldn't it make sense to visit the .onion site that the author refers to in the article and lock access to all accounts found there?
> Risk-based anti-ATO systems are heuristic.
This is Paypal practicing DID, which is great. What's not great is that the 2FA defense system could be defeated.
> Every bounty program I've ever paid attention to would close that report.
Getting access to a user's financial account and being able to move their money is something I would take serious 100/100 times. I hope you're not paying attention to bounty programs in the financial sector.
it's just there to make people that don't know anything about technology feel better
Their response is dogshit but not for this reason.
PCI Compliance is total bullshit and everybody knows it.[1]
According to this image [2], they did not respond or refute within 30 days.
If PayPal’s PCI-DSS compliance certification isn’t revoked then PCI-DSS is a farce.
[1] https://www.itgovernance.co.uk/blog/a-guide-to-the-pci-dsss-...
[2] https://cybernews.com/wp-content/uploads/2020/02/paypal-2fa-...