Seriously, the webappsec community is abuzz with the new PCI requirements
that allow either code review or application firewalls, and there are people
out there debating the merits of both, as if it is a competition.  Are WAFs
a band-aid?  Of course they can be, to compensate for crappy input
validation, but even if one’s input validation is perfect and protects
against all known attacks today having an added layer of defense isn’t
likely going to hurt a great deal (though specific situations can cause
issues), and is quicker to update when new attacks are developed.  Also,
your input validation isn’t perfect.  Even your whitelist input validation
isn’t perfect.  It is probably “good enough”, but it isn’t perfect.

Are WAFs a replacement for code review- not ever.  A WAF sucks at finding
back doors or easter eggs, or finding pages that *should* have an
authorization check at the top but don’t, or a myriad of other issues that
can still be used right through the firewall.  Code review will find those
things, even if it is a very inefficient and ineffective way of tracking
down vulnerabilities in general. 

In truth, none of this is sufficient, but PCI isn’t really about securing
customer data, at least the way it is written, but rather a way to avoid
liability.  It is a minimum number of steps to say “look, we tried to do
something”.  The fact that “Private Networks” are considered secure and
data can be sent in the clear over them (even though less than 30% of
successful attacks actually come from external networks) shows that it isn’
t really concerned with really protecting payment card information.

For companies that want to meet the minimum requirements for PCI, the only
question is which solution is cheapest and easiest.  For companies that
actually care about protecting their customer’s sensitive information, the
question shouldn’t be which to do, but what additionally can be done.
Neither of these solutions are sufficient to ensure that data is protected
by themselves.  The first requirement to protect customer data is to get
upper management to care, then to put security standards in place, a secure
development lifecylce in place, and educate developers on the threats they
face and the protections they should employ.

An ideal solution shouldn’t just have a code review, but a feature review
when the feature is proposed (with security requirements included), a risk
analysis and mitigation strategy during the architecure planning, threat
modeling and detail design security review, code review, and both security
control testing and pentesting both with and without a WAF, so that if the
WAF fails the application is still strong.

That is what PCI should be.  Yes, it is a huge burden on development teams
and companies that don’t do those things already, but at the same time, ask
yourself if you would trust a company that did the current bare minimum to
meet PCI as it stands now with your card information.  I sure don’t, which
is why I am glad that my bank now offers onetime card numbers and more and
more sites accept paypal. 

~ Joshbw

 

 

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