PCI QSA_New_V4 Exam Questions

Compensating Controls Definition and Purpose

A compensating control is an alternate measure that satisfies the intent of a specific PCI DSS requirement and provides an equivalent level of security.

The rationale and risk mitigation must be explicitly documented using the Compensating Control Worksheet (CCW).

Mandatory Documentation

PCI DSS v4.0 mandates the use of a CCW when implementing compensating controls. This applies regardless of acquirer approvals.

The CCW requires detailed documentation including:

Constraints preventing the original requirement from being implemented.

Justification for the compensating control.

Description of the control and evidence of its effectiveness.

Using Existing Requirements

If an existing PCI DSS requirement (e.g., Requirement 5 for antivirus) is already implemented and can mitigate the risks of not meeting another requirement, it may qualify as a compensating control.

Approval and Review Process

QSAs must validate the implementation, effectiveness, and appropriateness of compensating controls during the assessment process

Requirement for Secure Transmission:

PCI DSS Requirement 4.1 mandates that cardholder data sent over open public networks must be protected with strong cryptographic protocols. Accepting only trusted keys ensures data integrity and prevents unauthorized access.

Key Validation Practices:

Trusted keys and certificates are verified to ensure authenticity. Using untrusted keys compromises the security of the encrypted communication.

Prohibited Practices:

A/D: Configuring protocols to accept all certificates or lower encryption strength violates PCI DSS encryption guidelines.

B: Proprietary protocols are not inherently compliant unless they meet strong cryptographic standards.

Testing and Verification:

Assessors verify the implementation of trusted keys by examining encryption settings, reviewing certificate chains, and conducting tests to confirm only trusted connections are accepted.

Requirement Context:

PCI DSS Requirement 12.5 mandates that security policies and operational procedures are not only documented but also distributed to relevant parties to ensure clarity and compliance.

Importance of Distribution and Awareness:

All affected parties, including employees, contractors, and third parties with access to the cardholder data environment (CDE), must receive and understand the policies. This ensures they adhere to the security measures.

Review and Updates:

Security policies must be kept up to date and reviewed at least annually or after significant changes in the environment. While other options such as encryption or restricted access are important for security, the critical focus is on distribution and awareness to ensure operational effectiveness.

Testing and Validation:

During assessments, QSAs validate the implementation by examining training records, communication logs, and acknowledgment forms signed by affected parties.

Relevant PCI DSS v4.0 Guidance:

Section 12.5.1 of PCI DSS v4.0 outlines that the dissemination of policies must ensure that all personnel understand their roles in securing the environment.

Intent of Risk Ranking

PCI DSS Requirement 6.3.2 requires that entities assign a risk ranking to vulnerabilities to prioritize remediation efforts.

This ensures that the most critical vulnerabilities are addressed in a timely manner, reducing the risk to the CDE.

Practical Implementation

Vulnerabilities are assessed based on potential impact and likelihood of exploitation, typically using industry-standard frameworks like CVSS.

High-risk vulnerabilities may require immediate attention, while lower-priority issues are remediated per schedule.

Incorrect Options

Option A: PCI DSS does not mandate a 30-day remediation window for all vulnerabilities; remediation timelines depend on risk.

Option B: Quarterly ASV scans are still required even with risk ranking.

Option D: Installing patches quarterly does not align with the dynamic prioritization of risks.

Software Security Framework Overview

PCI SSC's Software Security Framework (SSF) encompasses Secure Software Standard and Secure Software Lifecycle (Secure SLC) Standard.

Software developed under the Secure SLC Standard adheres to security-by-design principles and can leverage the SSF during PCI DSS assessments.

Applicability

The framework is primarily for software developed by entities or third parties adhering to PCI SSC standards.

It does not apply to legacy payment software listed under PA-DSS unless migrated to SSF.

Incorrect Options

Option A: Not all payment software qualifies; it must align with SSF requirements.

Option B: PCI PTS devices are subject to different security requirements.

Option C: PA-DSS-listed software does not automatically meet SSF standards without reassessment.