Maybe i've missed something. Email is valid to shift around in plain text. TLS 1.0 might not be acceptable if you're talking minimum encryption standards, but I agree with the posters that point out that the Payment Card environment should have no dependencies on any email exchange with third parties.  This sounds to me like a box-ticking exercise where the right action on the public internet is to generally support the lowest common denominator unless it's insecure to do so - and in the case of email, you have to assume all transactions are insecure anyway unless you have end-to-end controls in place (which clearly you don't in this case if TPG is one end!)

In the end you should be able to exchange email with TPG without any encryption at all and it shouldn't affect your compliance, surely?! As you can't be held responsible for a third party system and shouldn't be dependent on its status for your compliance as a result.

Disclaimer: Have never tried to seek PCI compliance in any system i've operated.

Mark.


On 23/07/2018 7:03 PM, Paul Wilkins wrote:
PCI spec is pretty clear you're to have separation (virtual/physical) between PCI and other environments.

OTOH, TPG SLA's do not require TLS1.0+.

Someone is going to have to sling for an external MTA.

Kind regards

Paul Wilkins

On 23 July 2018 at 16:01, Michael Junek <[email protected] <mailto:[email protected]>> wrote:

    Just being the 'mean security consultant'  - the security level of
    each system could easily be argued - email would be considered low
    security for compatibility (which technically means that
    TLS1.0/SSL3 etc is acceptable) ; whereas the web servers are
    considered high security handling CHD, which means that they
    should covered under the full encrypted spec. It would also mean
    if that was considered, that 2.2.1 would apply, and seperation of
    function would be required.



    ------------------------------------------------------------------------
    *From:* Bradley Silverman <[email protected]
    <mailto:[email protected]>>
    *Sent:* Monday, 23 July 2018 15:56
    *To:* Michael Junek
    *Cc:* Mark Newton; [email protected]
    <mailto:[email protected]>

    *Subject:* Re: [AusNOG] Issues receiving from TPG Mail servers.
    @Michael - That's what we are looking at doing, though it will be
    a pain. Not sure how to go about doing it with Exim & cPanel but
    will start looking into it.

    Re 2.2.1, it won't fail if they have the same security level,
    which is what we are trying to accomplish by bringing TPG into
    spec. DNS is on separate servers, and the database connection
    isn't publicly accessible.

    Really appreciate the help with this gents. Hopefully TPG get back
    in touch with me else we will have to investigate ways of blocking
    TLS handshakes from TPG.

    Regards,

    Bradley Silverman | VentraIP Australia
    *Technical Operations*

    mobile. +61 418 641 103
    phone. +61 3 9013 8464

    On Mon, Jul 23, 2018 at 3:48 PM, Michael Junek
    <[email protected] <mailto:[email protected]>> wrote:

        On the PCI Audit side of things, however, I think the shared
        hosting such as CPanel servers will fail PCI based on
        requirement 2.2.1 regardless--


        "

        Implement only one primary function per server to prevent
        functions that require different security levels from
        co-existing on the same server. (For example, web servers,
        database servers, and DNS should be implemented on separate
        servers.)

        "





        ------------------------------------------------------------------------
        *From:* AusNOG <[email protected]
        <mailto:[email protected]>> on behalf of Bradley
        Silverman <[email protected]
        <mailto:[email protected]>>
        *Sent:* Monday, 23 July 2018 15:40
        *To:* Mark Newton
        *Cc:* [email protected] <mailto:[email protected]>
        *Subject:* Re: [AusNOG] Issues receiving from TPG Mail servers.
        @Michael - I agree that turning it off is the best way of
        solving it, the issue is we don't have the servers forcing
        TLS, that's TPG.

        @Mark - These are shared hosting servers, think cPanel &
        Plesk. The one server is both mail, and website. Which means
        that the server has websites that accept credit card payments,
        and therefore is subject to PCI. Any system that is on that
        server is required to comply with PCI.

        If the server was website only, then I'd agree 100% that it
        would be out of scope for PCI, but since the same server runs
        both email and websites for shared hosting customers, it is in
        scope.

        We have zero issue with any other MTA, it is only these TPG
        MTA's that are forcing both TLSv1.0 and an old cipher. If they
        either turned off TLS or upgraded to TLSv1.2 they would be up
        to spec.

        But we either have to make the decision to block TPG from
        being able to send to the 100,000s of email accounts we have,
        or make it so that none of our customers servers are PCI
        compliant. I'd rather speak to TPG and work with them to fix
        the underlying problem.

        Regards,

        Bradley Silverman | VentraIP Australia
        *Technical Operations*

        mobile. +61 418 641 103
        phone. +61 3 9013 8464

        On Mon, Jul 23, 2018 at 3:34 PM, Mark Newton
        <[email protected] <mailto:[email protected]>> wrote:

            But PCI Compliance only applies to the Cardholder Data
            Environment.

            Why on earth would you have a mail server in the
            Cardholder Data Environment?

            And if it isn’t in the CDE: You can run whatever version
            of TLS you want, and it’s none of PCI’s business.

              - mark



            On Jul 23, 2018, at 3:06 PM, Bradley Silverman
            <[email protected]
            <mailto:[email protected]>> wrote:

            Hi Matt,

            Really appreciate you sending me that email, I will
            definitely send an email through to there!

            @Mark Certainly not! PCI Compliance requires that TLSv1.0
            be disabled on the server. Postifx/Exim/Dovecot are not
            exception to the rule, if we disable TLSv1.0 on the
            server and remove the weak cipher, then TPG's MTAs aren't
            able to send mail to us.

            Regards,

            Bradley Silverman | VentraIP Australia
            *Technical Operations*

            mobile. +61 418 641 103
            phone. +61 3 9013 8464

            On Mon, Jul 23, 2018 at 2:48 PM, Mark Newton
            <[email protected] <mailto:[email protected]>>
            wrote:

                You’re trying to exchange payment card information
                over email?

                  - mark

                On Jul 23, 2018, at 1:30 PM, Bradley Silverman
                <[email protected]
                <mailto:[email protected]>> wrote:

                Does anyone have a contact at TPG regarding their
                mail servers?

                We are having issues with their mail servers using
                non-PCI compliant ciphers which is stopping our
                servers accepting mail from them.


                Regards,

                Bradley Silverman | VentraIP Australia
                *Technical Operations*

                mobile. +61 418 641 103
                phone. +61 3 9013 8464
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