full-disclosure - Re: Compliance Is Wasted Money, Study Finds

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Date: Wed, 07 Apr 2010 15:52:00 -0600
From: Digital X <digitalx00@...il.com>
To: Full-disclosure <full-disclosure@...ts.grok.org.uk>
Subject: Re: Compliance Is Wasted Money, Study Finds


>>> Whether said checkbox is actually the best solution *for the actual problem*
>>> is the issue.  I've seen cases where checkbox auditors insisted that a
>>> certain critical system "absolutely positively *HAD* to have a firewall".
>> 
>> This is where compensating controls come in with PCI. If there is an
>> even better solution you are free to implement it.
> 
> Yes, the PCI "compensating controls" are overall a Good Thing.  Unfortunately,
> a lot of regulatory regimes don't see things that way yet.  And it still
> requires a clued PCI auditor who actually understands the real world enough
> to deal with compensating controls.

Having just gone through a PCI audit I can safely say a few things:
 
A)  Approaching compliance from a risk management approach went out the
window
B)  Items the auditor didn't understand absolutely went back to a checkmark
mentality
C)  Items that were gray areas were treating VERY liberally in their
interpretation

Bleh


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