Unfortunately the DSS requires 2 things. 1) that PAN data be encrypted during 
transmission. 2) That credentials are not sent in clear as these can be then 
used to access the platform and then attempt to access the data.

As both FTP and Telnet send credentials in clear their protocols have to be 
encrypted to satisfy 2) thereby requiring ALL FTP and Telnet to be encrypted. 
(Or at least that has been how our varying QSA's have explained it to me).

> -----Original Message-----
> From: IBM Mainframe Discussion List 
> [mailto:[email protected]] On Behalf Of Scott
> Sent: Tuesday, January 05, 2010 9:48 AM
> To: [email protected]
> Subject: Re: PCI and Auditors perceptions thereof
> 
> Well, it makes sense to me that it specifies PAN data (and 
> probably CVV2, pins, yadda).  I should really take the time 
> to read the PCI-DSS, but I have the attention span of a 
> newborn puppy.  The only requirement is really for "strong 
> cryptography" which, in the context of PKI, is 1024 bit or greater.
> 
> Mostly I think these standards are written in a way that is 
> just vague enough to make my life a living hell.  I really 
> wish "when in doubt, encrypt" would be codified in everything 
> so I could recover a measurable portion of my lifespan from 
> all the meetings.
> 
> Generally, I really like TLS.  However, FTPS is (by far) the 
> worst mechanism to come out of the last decade.  If you don't 
> care about providing your own certificate, it's pretty 
> simple.  But when you depend on FTP+TLS, life becomes 
> miserable because it's neither trivial nor commonplace.
> 
> </Rant>
> 
> Yours,
> Scott

"Email Firewall" made the following annotations.
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