In my current $employer$ (we are a level 2 merchant) we did the whole "just
pay the fine" thing, because the business case for actually getting
compliant wasn't there. The fines did escalate for a couple of years, but
the costs for the PCI implementation were way more than the escalated fines,
so we kept putting it off. Just recently our clearing house and one of the
big three CC companies informed us that we *will* be fully compliant by
01/01/2010, or we get to go the level 1 audit route, which we have
investigated and no one wants to go through if we can avoid it.

Now we are in the midst of lots of planning and implementation work for PCI
that would normally be done over a year or so that is now going to be
completed start to finish in six months. I would very highly suggest
starting down the compliance path now, even if the decision is made to pay
the fines in the short term.
---------------------------------------------------
Alan S. Epps
[email protected]
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