On Mon, Sep 26, 2016 at 12:01 PM, BITS Security < bitssecur...@fsroundtable.org> wrote:
> The PCI DSS is already requiring TLS 1.2 for financial institutions that > participate in the Payment Card Industry. .BANK (exclusive top level > banking domain) is also planning to require TLS 1.2. We're anticipating > that a regulatory body like these will require TLS 1.3 at some point in the > future. Financial institutions then have to comply if they want to > continue to do business with the companies represented by the regulatory > body (like large credit card companies in the case of PCI). Hello again, I work firsthand enforcing these requirements at a payments company. Again, I do not speak on behalf of my employer. It wasn't until last year that PCI decided to deprecate TLS 1.0, at the time a 16 year old standard. I think your sense of emergency is highly over-exaggerated. I find it highly unlikely that any group such as the PCI Council will begin mandating TLS 1.3 any time soon. I would go as far as to call your concerns "imaginary". If you are worried about such an eventuality, the IETF is the wrong place to complain. It is far, far too late in the TLS 1.3 process to be voicing these concerns. Where were you 2+ years ago when it was the appropriate time in the TLS development cycle to voice such concerns? I think the view of more "forward thinking" payments companies is TLS 1.3 has taken too long already, and they would like to start deploying it in its current form and would prefer unnecessary holdups/distractions which have already occurred throughout the process. That said, there is still plenty of time to ensure that groups like the PCI Council do not put in place requirements which would affect the centralized traffic-decrypting MitM-capability on your payments stack. Perhaps you should be voicing your concerns there? If you are worried about a TLS 1.3 mandate preventing your MitM capability, the onus is on you to convince the relevant payments standards bodies that mandating TLS 1.3 is a bad idea for the payments industry. I think those organizations are better poised to judge whether such an approach reflects on necessary requirements versus pervasive antipatterns among complacent companies unprepared for the future and ripe for a data breach. In the meantime, you have disclosed a veritable treasure map to a traffic-decrypting single point of failure which ostensibly exists at all of the companies you represent which attackers could leverage to recover all payment credentials. That sounds like a huge security threat. Would you mind disclosing which companies you represent, so I can ensure for the safety of my own money that I do not use them? -- Tony Arcieri
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