How+Do+I+Transfer+Files+From+My+Old+Computer+To+My+New+Computer+Windows+10 File Integrity Monitoring – PCI DSS Requirements 10, 10.5.5 and 11.5

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File Integrity Monitoring – PCI DSS Requirements 10, 10.5.5 and 11.5

Although FIM or File Integrity Monitoring is specifically mentioned in only two subrequirements of PCI DSS (10.5.5 and 11.5), it is actually one of the more important measures to protect business systems from card data theft.

What is it and why is it important?

The file integrity monitoring system is designed to protect card data from theft. The main purpose of FIM is to detect changes to files and their associated attributes. However, this paper provides background on three different dimensions of file integrity monitoring, namely:

– Hash-based secure FIM, mainly used for system file integrity monitoring

– File content integrity monitoring, useful for configuration files from firewalls, routers and web servers

– File and/or folder access monitoring, essential for protecting sensitive data

Secure Hash Based FIM

In the context of PCI DSS, documents of primary interest include:

– System files, such as anything located in the Windows/System32 or SysWOW64 folders, program files, or Linux/Unix critical kernel files

The goal of any hash-based file integrity monitoring system as a security measure is to ensure that only intended, desired, and planned changes are made to in-scope devices. The reason for this is to prevent theft of card data through malware or program modification.

Imagine a Trojan installed on a card transaction server – this Trojan could be used to transfer card details from the server. Similarly, a packet sniffer program can sit on the EPoS device to capture card data – if it masquerades as a normal Windows or Unix process with the same program and process name, it will be very difficult to detect. For more sophisticated hacking, how do you plant a “backdoor” into key program files to allow access to card data?

These are all examples of security incidents where file integrity monitoring is critical to identifying threats.

Keep in mind that antivirus defenses typically only identify 70% of the world’s malware and organizations that experience zero-day attacks (a zero-day marks the point in time when a new form of malware is first identified – only then can a remediation or mitigation strategy be developed, But it may take days or weeks to update all devices to protect them.

How far should the FIM step be taken?

As a starting point, the Windows/System32 or SysWOW64 folder must be monitored, along with the main card data processing application folder. For these locations, run a daily inventory of all system files in those folders and identify all additions, deletions, and changes. Additions and deletions are relatively easy to identify and evaluate, but how should changes be handled, and how do you evaluate the significance of subtle changes such as file attributes? The answer is that any file changes in these critical locations must be given equal weight. Most high-profile PCI DSS security breaches were instigated by “insiders”—often trusted employees with privileged administrative rights. When it comes to cybercrime today, there are no rules.

The industry-accepted approach to FIM is to track all file attributes and record secure hashes. Any change to the hash value when the file integrity check is re-run is a red-alert situation – using SHA1 or MD5, even a small change to a system file will represent a noticeable change to the hash value. When using FIM to manage the security of critical system files, there should never be any unplanned or accidental changes – if there is, it could be a Trojan horse or a backdoor-enabled version of a system file.

This is why it is also important to use FIM in conjunction with a “closed loop” change management system – planned changes should be scheduled and related changes for document integrity documented and attached to the planned change record.

File Content/Configuration File Integrity Monitoring

While secure hash checksums are a reliable way to identify changes to any system files, this only tells us that changes have been made to the file, not what was changed. Of course, for executables in binary format, this is the only meaningful way to communicate that changes have been made, but a far more valuable way of doing file integrity monitoring on “readable” files is to keep a record of the file’s contents. This way, if changes are made to the file, the exact changes made to the readable content can be reported.

For example, a FIM system can capture web configuration files (php, aspnet, js or javascript, XML configuration) and log as readable text; changes will then be detected and reported directly.

Likewise, if firewall access control lists are edited to allow access to critical servers, or Cisco router startup configurations are altered, this could allow hackers to break into card data servers at any time.

One last note on file content integrity monitoring – in the security policy/compliance world, Windows Registry keys and values ​​are often covered under the FIM heading. Since many hacks involve modifying registry settings, these changes need to be monitored. Likewise, many common vulnerabilities can be identified by analyzing registry settings.

File and/or folder access monitoring

A final consideration for file integrity monitoring is how to handle other file types that are not suitable for secure hashing or content tracking. For example, since log files, database files, etc. are always changing, the contents and hashes are also constantly changing. Good file integrity monitoring techniques will allow these files to be excluded from any FIM template.

However, card data can still be stolen undetected unless other measures are taken. As an example scenario, in an EPoS retail system, a card transaction or reconciliation file is created and forwarded to a central payment server on a schedule throughout the transaction day. The file will always be changing – perhaps a new file will be created each time with a timestamped name, so everything about the file is always changing.

This file will be stored in a secure folder on the EPoS device to prevent users from accessing the content. However, “insiders” with administrative rights to the folder can view transaction files and copy data without having to change the files or their properties. Therefore, the final dimension of file integrity monitoring is to generate alerts when any access to those files or folders is detected and provide a full audit trail based on the account names that have access to the data.

Much of PCI DSS Requirement 10 is concerned with recording an audit trail to enable forensic analysis of any breaches after an incident and to identify the vector and perpetrator of any attack.

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