Gary, may I suggest an alternative response to application firewalls and the 
notion that it is hair-brained? Of course this is true but this list is missing 
a major opportunity to finally calculate an ROI model. If you ask yourself, 
what types of firewalls are pervasively deployed, you would find that 
application-firewalls aren't. This would then mean that folks would either need 
to replace their existing firewall (very risky that no one would ever 
consider), add multiple firewalls which introduce operational complexity, etc. 

You are probably aware that Cisco Pix, Checkpoint, etc aren't app-level which 
says that incumbent vendors aren't the solution. Likewise, you are probably 
aware that for other than common protocols, you probably will have to pay big 
bucks to vendors to develop custom plugins to their closed source offerings and 
the procurement cycle times around this are lengthy at best.

For many shops, having another type of firewall could cost millions whereas 
putting tools in the hands of developers may actually be cheaper. We as a 
community may be better served by encouraging application firewalls and letting 
the financial model for complying work in our favor...

-----Original Message-----
From: Gary McGraw [mailto:[EMAIL PROTECTED]
Sent: Wednesday, April 04, 2007 10:01 AM
To: McGovern, James F (HTSC, IT); SC-L@securecoding.org
Subject: RE: [SC-L] Darkreading: compliance


Hi all,

Another big momentum machine for software security (and data security) is PCI 
compliance.   There is a challenge, though, and that is figuring out where the 
credit card data that you want to protect are.   We've found in our practice at 
cigital that the data are literally scattered all over the enterprise.   
Because of this, hair-brained solutions like application firewalls (something 
called out in the PCI standards) often don't help.

I think PCI compliance is doing for data security and data risk what SOX did 
for software security and sofware risk.   They both help with problem awareness.

To answer your question directly, we see lots of large enterprises working hard 
on PCI these days.

gem

company www.cigital.com
podcast www.cigital.com/silverbullet
blog www.cigital.com/justiceleague
book www.swsec.com.


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