24 Most Common

PROBLEMS
IN IMPLEMENTING

Rajneesh Gupta
@rajneeshcyber
 INTRODUCTION TO
PCI DSS V4.0
PCI DSS (Payment Card Industry Data Security Standard) is
a global security standard designed to protect cardholder
data by enforcing strict controls and security measures. It
helps organizations prevent data breaches and maintain
trust in payment systems.

Purpose
To secure cardholder data globally and reduce fraud

Key Changes from PCI DSS v3.2.1

Greater flexibility for security controls
Enhanced focus on risk management
Support for evolving payment technologies

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 KEY GOALS OF
PCI DSS V4.0

1. Build and Maintain a 4. Implement Strong

Secure Network Access Control Measures

Implement strong firewall and Restrict access to cardholder

network security controls data based on need-to-know
principles.

2. Protect Cardholder 5. Monitor and Test

Data Networks
Ensure encryption of Continuously monitor network
cardholder data during activity and conduct regular
transmission and storage. security testing.

3. Maintain a Vulnerability 6. Maintain an Information

Management Program Security Policy
Regularly update systems and Establish and maintain a
implement security patches. security policy that addresses
information protection.

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WHO SHOULD COMPLY
WITH PCI DSS?
Merchants
Any business that accepts, processes, or stores payment
card information.

Payment Processors
Entities that facilitate transactions between merchants and
financial institutions.

Service Providers
Organizations that store, process, or transmit cardholder
data on behalf of merchants or other service providers.

Note: Different levels based on transaction volume (e.g.,

Level 1 for large businesses, Level 4 for small merchants).

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 12 PCI DSS V4.0
REQUIREMENTS
1. Install and maintain a firewall configuration to protect
cardholder data.
2. Do not use vendor-supplied defaults for system passwords
and security settings.
3. Protect stored cardholder data.
4. Encrypt transmission of cardholder data across open,
public networks.
5. Protect all systems against malware and regularly update
anti-virus software.
6. Develop and maintain secure systems and applications,
applying timely security patches.
7. Restrict access to cardholder data based on business need-
to-know.
8. Identify and authenticate access to system components.
9. Restrict physical access to cardholder data.
10. Track and monitor all access to network resources and
cardholder data.
11. Regularly test security systems and processes.
12. Maintain a policy that addresses information security for
all personnel.

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24 Most Common
PROBLEMS
IN IMPLEMENTING
PCI DSS

Rajneesh Gupta
@rajneeshcyber
 1
INCOMPLETE SCOPE
DEFINITION
Problem
Many businesses fail to define all systems that store,
process, or transmit cardholder data accurately.

Solution
Regularly review systems, perform scoping assessments,
and update inventory frequently.

PCI DSS Clause:

1.2.2

Example
Use Nmap for network discovery.
SolarWinds for asset management.

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 2
WEAK ACCESS
CONTROL
Problem
Insufficient restriction on access to sensitive cardholder
data, leading to unauthorized access.

Solution
Implement role-based access controls and regularly audit
user privileges.

PCI DSS Clause:

7.1.1

Example
Microsoft Active Directory for RBAC.
Okta for IAM audits.

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 3
POOR ENCRYPTION
PRACTICES
Problem
Data transmission across open, public networks without
strong encryption increases the risk of breaches.

Solution
Use strong encryption protocols (e.g., TLS 1.2 or above) for
all data transmissions.

PCI DSS Clause:

4.1

Example
Let’s Encrypt for TLS certificates.
OpenSSL for encryption.

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 4
INCONSISTENT
PATCH MANAGEMENT
Problem
Delays or inconsistencies in applying security patches leave
vulnerabilities exposed.

Solution
Automate patch management and perform regular
vulnerability scans.

PCI DSS Clause:

6.2

Example
WSUS or SCCM for patch management.
Nessus for vulnerability scans.

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 5
INADEQUATE LOGGING
AND MONITORING
Problem
Failure to log and monitor critical systems prevents timely
detection of suspicious activities.

Solution
Centralize logging and implement real-time monitoring.

PCI DSS Clause:

10.1

Example
SIEM tools like Splunk or ELK Stack.
Alerts via SolarWinds or Datadog.

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 6
NON-COMPLIANT
THIRD-PARTY VENDORS
Problem
Vendors accessing cardholder data may not comply with
PCI DSS, increasing risk for the organization.

Solution
Enforce strict vendor compliance policies and regular audits.

PCI DSS Clause:

12.8

Example
Vendor risk assessment using BitSight.
Monitor compliance with OneTrust.

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 7
LACK OF SECURITY
AWARENESS TRAINING
Problem
Employees not adequately trained on PCI DSS requirements
may mishandle sensitive data.

Solution
Implement ongoing security awareness training programs.

PCI DSS Clause:

12.6

Example
Use KnowBe4 for training.
Phishing simulations with Cofense.

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 8
INSUFFICIENT DATA
RETENTION POLICIES
Problem
Storing cardholder data longer than necessary can increase
breach risks.

Solution
Implement strict data retention and deletion policies.

PCI DSS Clause:

3.1

Example
Automate data deletion with Varonis.
Use Symantec DLP for data loss prevention.

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 9
LACK OF NETWORK
SEGMENTATION
Problem
Failing to segment cardholder data environment (CDE) from
other systems increases the risk of data exposure.

Solution
Segment networks and isolate sensitive environments.

PCI DSS Clause:

1.3

Example
VLANs for network segmentation.
Firewalls like Palo Alto for isolation.

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 10
LACK OF REGULAR
VULNERABILITY SCANNING

Problem
Not scanning systems for vulnerabilities regularly leaves the
network exposed to potential attacks.

Solution
Schedule regular internal and external vulnerability scans.

PCI DSS Clause:

11.2

Example
Qualys or Nessus for scanning.
Rapid7 for monitoring patch status.

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 11
INSECURE REMOTE
ACCESS
Problem
Weak controls on remote access create a risk for
unauthorized entry into the cardholder data environment.

Solution
Enforce multi-factor authentication and VPN usage.

PCI DSS Clause:

8.3.2

Example
Use Duo Security for MFA.
Deploy VPNs like OpenVPN.

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 12
UNENCRYPTED
CARDHOLDER DATA AT REST

Problem
Failure to encrypt stored cardholder data increases risk if
systems are breached.

Solution
Apply strong encryption to stored cardholder data.

PCI DSS Clause:

3.4

Example
AES-256 encryption for data at rest.
Encrypt using tools like VeraCrypt.

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 13
INCONSISTENT FIREWALL
CONFIGURATION
Problem
Misconfigured firewalls can allow unauthorized traffic into
the cardholder data environment.

Solution
Regularly review and update firewall rules.

PCI DSS Clause:

1.1.7

Example
Cisco ASA for firewall management.
Perform audits using FireMon.

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 14
WEAK PASSWORD
MANAGEMENT
Problem
Using weak passwords or failing to update default
passwords leads to increased risk of attacks.

Solution
Enforce strong password policies and regular updates.

PCI DSS Clause:

8.3.6

Example
LastPass or Dashlane for password management.
Enforce policies with Active Director

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 15
FAILURE TO MONITOR
PHYSICAL ACCESS
Problem
Physical access to systems with cardholder data is not
monitored, creating a risk of data theft.

Solution
Implement physical access controls and logging.

PCI DSS Clause:

9.1

Example
Use CCTV systems.
Implement access logs via badge readers.

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 16
WEAK ANTI-MALWARE
CONTROLS
Problem
Failing to deploy or update anti-malware solutions exposes
systems to harmful software.

Solution
Use up-to-date anti-malware software with automatic
updates.

PCI DSS Clause:

5.1

Example
Deploy solutions like McAfee or Symantec.
Schedule regular updates and scans.

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 17
FAILURE TO CONDUCT
RISK ASSESSMENTS
Problem
Organizations may not regularly assess risks to cardholder
data, increasing vulnerability.

Solution
Conduct regular risk assessments and threat modeling.

PCI DSS Clause:

12.1.2

Example
Use RiskWatch for automated assessments.
Perform threat modeling with OWASP tools.

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 18
POOR CHANGE
MANAGEMENT
Problem
Uncontrolled system changes can create vulnerabilities that
lead to non-compliance.

Solution
Implement strict change management processes.

PCI DSS Clause:

6.4

Example
Use Jira or ServiceNow for change tracking.
Implement change approval workflows.

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 19
FAILURE TO CONDUCT
PENETRATION TESTING
Problem
Lack of regular penetration tests leaves security
vulnerabilities unexposed.

Solution
Perform annual internal and external penetration testing.

PCI DSS Clause:

11.3

Example
Use tools like Metasploit for internal testing.
Hire external vendors for penetration testing.

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 20
WEAK INCIDENT
RESPONSE PLANS
Problem
Without an incident response plan, organizations are
unprepared for breaches or attacks.

Solution
Develop and regularly test incident response plans.

PCI DSS Clause:

12.10

Example
Use TheHive for incident response management.
Test plans with simulated attacks.

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 21
LACK OF BACKUP AND
RECOVERY SOLUTIONS
Problem
Without robust backup strategies, organizations risk losing
data in case of breaches.

Solution
Implement encrypted backup and recovery solutions.

PCI DSS Clause:

9.5

Example
Use Veeam or Acronis for backups.
Ensure backups are encrypted.

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 22
INADEQUATE DATA
MASKING
Problem
Failing to mask cardholder data during storage or
transmission increases exposure risk.

Solution
Implement tokenization or data masking solutions.

PCI DSS Clause:

3.3

Example
Use tokenization tools like CipherCloud.
Data masking with IBM InfoSphere.

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 23
FAILURE TO TRACK
SYSTEM CHANGES
Problem
Without tracking changes, unauthorized alterations to
systems can go undetected.

Solution
Implement configuration management tools.

PCI DSS Clause:

6.4.5

Example
Puppet or Chef for change tracking.
Git for version control.

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 24
INSUFFICIENT SECURITY
POLICY DOCUMENTATION

Problem
Not maintaining up-to-date security policies leaves
organizations unprepared.

Solution
Regularly review and update all security policies.

PCI DSS Clause:

12.1

Example
Use Confluence or SharePoint for policy management.
Implement annual policy reviews.

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 25
POOR KEY MANAGEMENT
PRACTICES

Problem
Weak key management leads to compromised encryption
practices.

Solution
Implement strict key management procedures and tools.

PCI DSS Clause:

3.5

Example
Use AWS KMS or Thales for key management.
Perform regular key rotation.

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 CONCLUSION
To achieve PCI DSS compliance, businesses must tackle
several common issues. Here are six key challenges and
solutions:
Regularly review and update systems for accurate
PCI DSS scoping.
Implement role-based access controls and frequent
audits to prevent unauthorized access.
Use strong encryption protocols for secure data
transmission and storage.
Automate patch updates and conduct regular
vulnerability scans.
Centralize logs and implement real-time monitoring
for quick detection.
Enforce strict vendor compliance through regular
audits.

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