Document Diff - PCI Watch

Added p. 2

• New table 3.10 to capture truncation information relative to requirement 4B-1.8.

Added p. 6

Solution assessments that have not satisfied the entirety of their Encryption Management Services (Domain 1 with Domain 5) via the use of applicable Validated P2PE Component Providers must complete the EMS P-ROV in addition to the Solution P-ROV.

Solution assessments that have not satisfied the entirety of their Decryption Management Services (Domain 4 with Domain 5) with applicable Validated P2PE Component Providers must complete the DMS P-ROV in addition to the Solution P-ROV.

Added p. 20

Flows and locations of encrypted account data Flows and locations of clear-text account data Flows and locations of truncated account data Location of critical system components (e.g., HSMs, Host Systems) All entities to which the Decryption Management Services connects for payment transmission or processing, including processors/acquirers

Note: The diagram should identify where merchant entities fit into the data flow without attempting to identify individual merchants. For example, encrypted account data could be illustrated as flowing between an icon that represents all merchant customers and an icon that represents the decryption environment. Document if any intermediate proxies exist between merchant customers and the decryption environment.

Provide any additional information below that is not adequately captured within the diagram(s). Otherwise, check No Additional Details. No Additional Details <Additional Details, as needed> <Insert Decryption Management Services Data Flow diagram(s) here>

Added p. 24

Note: All HSMs (or Host Systems used in hybrid decryption) used for account-data decryption in the decryption environment must be reviewed to verify their secure configuration and therefore cannot be sampled. Refer to the P2PE Standard for additional information.

Added p. 27

Decryption Management Services: P2PE Validation Requirements Summary of Findings (check one) In Place N/A Not in 4A Use approved decryption devices.

4A-1 Use approved decryption devices.

4B Secure the decryption environment.

4B-1 Maintain processes for securely managing the decryption environment.

4C Monitor the decryption environment and respond to incidents.

4C-1 Perform logging and monitor the decryption environment for suspicious activity and implement notification processes.

4D Implement secure, hybrid decryption processes. (Applicable to Hybrid Decryption Environments ONLY) 4D-1 Configure the Host System securely.

4D-2 Access controls for the Host System are configured securely.

4D-3 Non-console access to the Host System is configured securely.

4D-4 The physical environment of the Host System is secured.

Added p. 28

Keys are conveyed or transmitted in a secure manner 8 Secret or private keys must be transferred by: a. Physically forwarding the key as at least two separate key shares or full-length components (hard copy, smart card, SCD) using different communication channels, or b. Transmitting the key in ciphertext form.

It is the responsibility of both the sending and receiving parties to ensure these keys are managed securely during transport.

Sending and receiving locations/entities are equally responsible for the physical protection of the materials involved.

These requirements also apply to keys moved between locations of the same organization.

Added p. 29

Key loading to HSMs and POI devices is handled in a secure manner 12 Secret and private keys must be input into hardware (host) security modules (HSMs) and Point of Interaction (POI) devices in a secure manner: a. Unencrypted secret or private keys must be entered into cryptographic devices using the principles of dual control and split knowledge. b. Key-establishment techniques using public-key cryptography must be implemented securely.

Added p. 29

Keys are used in a manner that prevents or detects their unauthorized usage 17 Unique, secret cryptographic keys must be in use for each identifiable link between host computer systems of two organizations or logically separate systems within the same organization.

Added p. 31

Equipment used to process account data and keys is managed in a secure manner 29 Equipment used to protect account data (e.g., POI devices and HSMs) must be placed into service only if there is assurance that the equipment has not been substituted or subjected to unauthorized modifications or tampering prior to the deployment of the device

•both prior to and subsequent to the loading of cryptographic keys

•and that precautions are taken to minimize the threat of compromise once deployed.

Requirements 30-1 and 30-2 are not used in P2PE Requirement 30-3 is not used in DMS 31 Procedures must be in place and implemented to protect any SCDs

•and ensure the destruction of any cryptographic keys or key material within such devices

•when removed from service, retired at the end of the deployment lifecycle, or returned for repair.

Requirements 32-1

• 32-9 are not used in DMS.

Added p. 31

5A-1 Account data is processed using algorithms and methodologies that ensure they are kept secure 5A-1 Account data is protected with appropriate cryptographic algorithms, key sizes and strengths, and key-management processes.

5H For hybrid decryption solutions: Implement secure hybrid-key management. (Applicable to Hybrid Decryption Environments ONLY)

5I-1 For component providers performing key management in conjunction with device-management or decryption- management services, maintain and monitor critical P2PE controls and provide reporting to the responsible solution provider.

• FIPS140-2 or 140-3 Level 3 (overall) or higher certified, or

• PCI PTS HSM approved.

4A-1.1.a For all HSMs used in the decryption environment, examine approval documentation (e.g., FIPS certification or PTS approval) and review the list of approved devices to verify that all HSMs used in the solution are either:

• Listed on the NIST Cryptographic Module Validation Program (CMVP) list, with a valid listing number, and approved to FIPS 140-2 or 140-3 Level 3 (overall), or higher. Refer …

Added p. 35

• For PCI-approved HSMs, any applications, including application version number, resident within the device which were included in the PTS assessment Note: If the solution provider has applied a vendor security patch resulting in an

• updated HSM firmware version, and the PCI SSC or NIST validation of that

• updated firmware version has not yet been completed (resulting in a mismatch between the HSM firmware version in use and the listed, validated one), the solution provider must obtain documentation from the vendor regarding the update that includes confirmation the update has been submitted for evaluation per the process specified by either PCI SSC or NIST (as applicable to the HSM).

4A-1.1.1.a For all PCI-approved HSMs used in the solution, examine HSM devices and review the PCI SSC list of Approved PTS Devices to verify that all of the following device characteristics match the PCI PTS listing for each HSM:

• Any applications, including …

Added p. 37

Note: PCI HSMs require that the decryption-device manufacturer make available a security policy document to end users, providing information on how the device must be installed, maintained, and configured to meet the compliance requirements under which it was approved.

4A-1.1.3 Examine HSM configurations for all P2PE solution functions to verify that HSMs are configured to operate according to the security policy that was included as part of the PTS approval.

Describe how HSM configurations for all P2PE security functions verified that HSMs are configured to operate according to the security policy that was included as part of the PTS approval:

<Report Findings Here> 4B-1.1 Current documentation must be maintained that describes or illustrates the configuration of the decryption environment, including the flow of data and interconnectivity between incoming transaction data from POI devices, all systems within the decryption environment, and any outbound connections.

4B-1.1.a Review documentation to verify that a procedure exists to maintain …

Added p. 38

• Assigning administrative roles and responsibilities only to specific, authorized personnel

• Assigning administrative roles and responsibilities only to specific, authorized personnel

Added p. 38

• Console and non-console administration

Added p. 38

• Use of HSM commands 4B-1.2.a Examine documented procedures to verify secure administration by authorized personnel is defined for decryption devices including:

Added p. 38

• Use of HSM commands Documented procedures reviewed: <Report Findings Here> 4B-1.2.b Observe authorized personnel performing device-administration operations to verify secure administration procedures are implemented for the following:

• Use of HSM commands Describe how the observation verified that secure administration procedures are implemented for the following:

• Use of HSM commands <Report Findings Here> 4B-1.2.c Observe personnel performing decryption-device administration and examine files/records that assign administrative roles and responsibilities to verify that only authorized and assigned personnel perform decryption-device administration operations.

Files/records examined: <Report Findings Here> Describe how the observation verified that only authorized and assigned personnel perform decryption-device administration operations:

Added p. 39

For example, require authentication for use of the HSMs APIs and secure all authentication credentials from unauthorized access. Where an HSM is unable to authenticate use of the API, limit the exposure of the HSM to a trusted host via a dedicated physical link that authorizes access on behalf of the HSM over the trusted channel (e.g., high-speed serial or dedicated Ethernet).

4B-1.3.a Examine documented procedures and processes to verify that only authorized users/processes have the ability to make functions calls to the HSM•e.g., via the HSM’s application program interfaces (APIs).

Documented procedures and processes reviewed:

<Report Findings Here> 4B-1.3.b Interview responsible personnel and observe HSM system configurations and processes to verify that only authorized users/processes have the ability to make function calls to the HSM (e.g., via the HSM’s application program interfaces (APIs)).

Responsible personnel interviewed: <Report Findings Here> Describe how the observed HSM configurations and processes verified that only authorized users/processes have …

Added p. 41

• Physically connected devices 4B-1.5.a Examine documented procedure to verify that inspection of devices is required at least quarterly to detect signs of tampering or modification, and that inspection procedures include:

• Physically connected devices Documented procedures reviewed: <Report Findings Here> 4B-1.5.b Interview personnel performing inspections and observe inspection processes to verify that inspections include:

• Physically connected devices Personnel interviewed: <Report Findings Here> Describe how the inspection processes observed verified that inspections include the device itself, cabling/connection points, and physically connected devices:

<Report Findings Here> 4B-1.5.c Interview personnel performing inspections and review supporting documentation to verify that inspections are performed at least quarterly.

Personnel performing inspections interviewed:

<Report Findings Here> Supporting documentation reviewed: <Report Findings Here>

Note: For merchant-managed solutions, PCI DSS validation of the decryption environment is managed by the merchant in accordance with their acquirer and/or payment brand. This requirement is therefore not applicable to P2PE assessments where merchants are the P2PE solution …

Added p. 44

- Confirmation that it was reviewed prior to release to only output non-PCI payment brand account/card data 4B-1.9 Any whitelisting functionality implemented in the decryption environment that transmits data to the encryption environment must ensure that the ONLY allowed output of clear-text account data is for non-PCI payment brand account/card data.

Indicate whether any whitelisting functionality has been implemented within the decryption environment (yes/no).

<Report Findings Here> If “no”, describe how it was verified that no whitelisting functionality has been implemented within the decryption environment. (Leave 4B-1.9.1a to 4B-1.9.3 blank) <Report Findings Here> If “yes”, complete 4B-1.9.1.a to 4B-1.9.3:

Added p. 45

PCI payment brand account/card data Documented policies and procedures reviewed:

<Report Findings Here> 4B-1.9.1 Any whitelisting functionality implemented in the decryption environment that transmits data to the encryption environment must allow ONLY the output of clear-text account data for non-PCI payment brand account/card data.

4B-1.9.1.a Observe application and system configurations and interview personnel to verify that whitelisting functionality implemented in the decryption environment that transmits data to the encryption environment only allows the output of clear-text account data for non-PCI payment brand account/card data.

Personnel interviewed <Report Findings Here> Describe how application and system configurations observed verified that whitelisting functionality implemented in the decryption environment that transmits data to the encryption environment only allows the output of clear-text account data for non-PCI payment brand account/card data:

Describe how test transactions verified that any whitelisting functionality implemented in the decryption environment that transmits data to the encryption environment only allows output clear-text account for non-PCI …

Added p. 48

• Unauthorized logical alterations (e.g., configurations, access controls)

• Unauthorized logical alterations (e.g., configurations, access controls)

• Unauthorized use of sensitive functions (e.g., key-management functions)

• Unauthorized use of sensitive functions (e.g., key-management functions)

Added p. 48

• Unauthorized use of the HSM API 4C-1.2.a Examine documented procedures to verify mechanisms are defined to detect and respond to potential security incidents, including:

• Unauthorized use of the HSM API Documented procedures reviewed: <Report Findings Here>

Added p. 49

• Unauthorized logical alterations (configuration, access controls)

• Unauthorized use of sensitive functions (e.g., key management functions)

• Unauthorized use of the HSM API Personnel interviewed: <Report Findings Here> Describe the implemented mechanisms that were observed to be implemented to detect and respond to suspicious activity:

<Report Findings Here> 4C-1.3 Mechanisms must be implemented to detect encryption failures, including at least the following:

Note: Although Domain 4 is concerned with the decryption environment, not the encryption environment, all traffic received into the decryption environment must be actively monitored to confirm that the POI devices in the merchant’s encryption environment is not outputting clear-text account data through some error or misconfiguration.

4C-1.3 Examine documented procedures to verify controls are defined for the following:

• Procedures are defined to detect encryption failures, and include 4C- 1.3.1 through 4C-1.3.4 below.

• Procedures include immediate notification upon detection of a cryptographic failure, for each 4C-1.3.1 through 4C-1.3.4 below.

4C-1.3.1.a Observe implemented processes …

Added p. 51

For example, transaction data received without an expected authentication data block (such as a MAC or signature, or a malformed message).

4C-1.3.3.a Observe implemented processes to verify controls are in place to detect and review any unexpected transaction data received.

Describe how the implemented processes observed verified that controls are in place to detect and review any unexpected transaction data received:

<Report Findings Here> 4C-1.3.3.b Observe implemented controls and notification mechanisms to verify that mechanisms detect and provide immediate notification for any unexpected transaction data received.

Describe the implemented controls and notification mechanisms observed that detect and provide immediate notification for any unexpected transaction data received:

<Report Findings Here> 4C-1.3.3.c Interview personnel to verify that designated personnel are immediately notified upon detection of any unexpected transaction data received.

Personnel interviewed: <Report Findings Here> 4C-1.3.4 Reviewing data sent by any POI devices that are causing an unusually high rate of transaction authorization rejections.

4C-1.3.4.a Observe implemented processes to …

Added p. 52

• Identification of affected merchant, including specific sites/locations if applicable

• Identification of affected merchant, including specific sites/locations if applicable

Added p. 52

• Details of whether any account data was transmitted from the POI device during any identified time that encryption was malfunctioning or disabled 4C-1.4.a Examine documented procedures to verify they include procedures for identifying the source and maintaining a record, of all suspicious activity, to include at least the following:

• Details of whether any account data was transmitted from the POI device during the time that encryption was malfunctioning or disabled Documented procedures reviewed: <Report Findings Here>

Added p. 53

• Identification of affected merchant, and specific sites/locations if applicable

• Identification of affected merchant, and specific sites/locations if applicable

• Details of whether any account data was transmitted from the POI device during the time that encryption was malfunctioning or disabled Responsible personnel interviewed: <Report Findings Here> Describe how the implemented controls verified that the source of any suspicious activity is identified, and records are maintained to include the following:

• Details of whether any account data was transmitted from the POI device during the time that encryption was malfunctioning or disabled <Report Findings Here>

Added p. 54

4C-1.5.a Examine documented procedures to verify mechanisms are defined to provide immediate notification of suspicious activity to applicable parties, including merchants, processors, acquirers, and any P2PE solution providers (if decryption services are being performed on behalf of other P2PE solution providers).

Documented procedures reviewed: <Report Findings Here> 4C-1.5.b Interview personnel and observe implemented mechanisms to verify that immediate notification of suspicious activity is provided to applicable parties, including merchants, processors, acquirers, and any P2PE solution providers (if decryption services are being performed on behalf of other P2PE solution providers).

Personnel interviewed: <Report Findings Here> Describe how the implemented mechanisms observed verified that immediate notification of suspicious activity is provided to applicable parties, including merchants, processors, acquirers, and any P2PE solution providers (if decryption services are being performed on behalf of other P2PE solution providers):

<Report Findings Here> Hybrid Decryption Environments (where HSMs are required for cryptographic key-management functions but allow for non-SCD “Host …

Added p. 56

• The necessary services, protocols, daemons etc. must be documented and justified, including description of the enabled security features for these services etc.

• Functions not related to transaction processing must be disabled, or isolated (e.g., using logical partitions), from transaction processing.

Note: “Isolated” means that the Host System must not be accessed, modified or intercepted by other processes.

4D-1.2.a Inspect network and system configuration settings to verify the host processing system is isolated, or dedicated, to processing payment transactions, with only necessary services, protocols, daemons, etc. enabled.

Describe how network and system configuration settings verified that the host processing system is isolated, or dedicated, to processing payment transactions, with only necessary services, protocols, daemons, etc. enabled:

<Report Findings Here> 4D-1.2.b Review the documented record of services, protocols, daemons etc. that are required by the Host System and verify that each service includes justification and a description of the enabled security feature.

Documented record of services, …

Added p. 57

4D-1.4.a Examine documented policies and procedures to verify that all application software installed on the Host System must have a business justification and be duly authorized.

<Report Findings Here> 4D-1.4.b Examine change control and system configuration records to verify that all application software installed on the Host System is authorized.

Change control and system configuration records reviewed:

<Report Findings Here> 4D-1.4.c Inspect Host System and compare with system configuration standards to verify that all software installed on the Host System has a defined business justification.

Describe how the Host System and system configuration standards verified that all software installed on the Host System has a defined business justification:

<Report Findings Here> 4D-1.5 A process, either automated or manual, must be in place to prevent and/or detect and alert, any unauthorized changes to applications/software on the Host System.

4D-1.5.a Examine documented policies and procedures to verify that a process is defined to prevent and/or detect and alert, …

Added p. 58

• Testing integrity of cryptographic functions.

• Testing integrity of firmware.

• Testing integrity of any security functions critical to the secure operation of the Host System.

4D-1.6.a Inspect Host System configuration settings, and examine vendor/solution provider documentation to verify that the Host System performs a self-test when it is powered up to ensure its integrity before use. Verify the self-test includes the following:

• Testing integrity of cryptographic functions

• Testing integrity of cryptographic functions

• Testing integrity of software/firmware

• Testing integrity of software/firmware

• Testing integrity of any security functions critical to the secure operation of the Host System Vendor/solution provider documentation reviewed:

<Report Findings Here> Describe how Host System configuration settings and vendor/solution provider documentation verified that the Host System performs a self-test when it is powered up to ensure its integrity before use, and that the self-test includes the following:

• Testing integrity of any security functions critical to the secure operation of the Host …

Added p. 59

4D-1.7.a Inspect Host System configuration settings and examine vendor/solution provider documentation to verify that the Host system performs a self-test when a security-impacting function or operation is modified.

<Report Findings Here> Describe how Host System configuration settings and vendor/solution provider documentation verified that the Host system performs a self-test when a security- impacting function or operation is modified:

<Report Findings Here> 4D-1.7.b Interview personnel and examine logs/records for when a security- impacting function, or operation, has been modified to verify that the Host System performs a self-test.

Added p. 60

• Failure of a security function or mechanism

Note: An “error state” identifies the Host System has encountered an issue that requires a response action. To prevent potential damage or compromise, the system must cease cryptographic operations until the issue is resolved and the host is returned to a normal processing state.

4D-1.8.a Inspect Host System configuration settings and examine vendor/solution provider documentation to verify that the host enters an error state and generates an alert in the event of the following:

• Failure of a security function or mechanism Vendor/solution provider documentation reviewed:

<Report Findings Here> Describe how Host System configuration settings and vendor/solution provider documentation verified that the host enters an error state and generates an alert in the event of the following:

• Failure of a security function or mechanism <Report Findings Here> 4D-1.8.b Interview personnel and examine logs/records of actual or test alerts to verify that alerts are generated and received …

Added p. 61

4D-1.9.a Review documented procedures to verify alerts generated from the Host System must be documented and result in notification to authorized personnel and initiate a response procedure.

Documented procedures reviewed: <Report Findings Here> 4D-1.9.b Examine system configurations and records of documented alert events to verify alerts generated from the Host System are documented.

Records of documented alert events reviewed:

<Report Findings Here> Describe how system configurations and records of documented alert events verified that alerts generated from the Host System are documented:

<Report Findings Here> 4D-1.9.c Examine a sample of documented alert events and interview personnel assigned with security-response duties to verify alerts initiate a response procedure.

Sample of documented alert events examined:

<Report Findings Here> Personnel assigned with security-response duties interviewed:

Added p. 62

• During diagnostics of cryptographic operations 4D-1.10.a Examine documented procedures to verify that controls/processes are in place to ensure that the Host System does not perform any cryptographic operations:

• During diagnostics of cryptographic operations Documented procedures reviewed: <Report Findings Here> 4D-1.10.b Inspect Host System configuration settings and interview personnel to verify that controls and/or procedures are in place to ensure that the Host System does not perform any cryptographic operations:

• During diagnostics of cryptographic operations Personnel interviewed: <Report Findings Here> Describe how Host System configuration settings verified that controls and/or procedures are in place to ensure that the Host System does not perform any cryptographic operations:

• During diagnostics of cryptographic operations <Report Findings Here>

Added p. 63

4D-1.11.a Inspect configuration documentation to verify that access controls are defined to ensure all source code and executable code for cryptographic software and firmware is protected from unauthorized disclosure and unauthorized modification.

Configuration documentation inspected: <Report Findings Here> 4D-1.11.b Observe access controls for cryptographic software and firmware to verify that all source code and executable code is protected from unauthorized disclosure and unauthorized modification.

Describe how the access controls for cryptographic software and firmware observed verified that all source code and executable code is protected from unauthorized disclosure and unauthorized modification:

<Report Findings Here> 4D-1.12 The clear-text data-decryption keys must not be accessible to any processes or functions not directly required for decryption operations.

4D-1.12.a Review solution provider documentation, including data-flow diagrams, to verify that clear-text decryption keys are not accessible to any processes or functions not directly required for decryption operations.

<Report Findings Here> 4D-1.12.b Inspect Host System configurations and access controls and to …

Added p. 64

<Report Findings Here> 4D-1.13.b Inspect Host System configuration settings and verify that clear- text data-decryption keys are only accessible to authorized personnel with a defined job-related need to access the keys.

Describe how the Host System configuration settings inspected verified that clear-text data-decryption keys are only accessible to authorized personnel with a defined job- related need to access the keys:

<Report Findings Here> 4D-1.14 The Host System must not write clear-text cryptographic keys to persistent storage (e.g., hard drives, removable storage, flash drives etc.) except for the following:

• Memory “swap/page” file purposes

• “Core dumps” of memory required for troubleshooting In the above circumstances, the following conditions apply:

4D-1.14.a Examine documented configuration procedures to verify that the Host System must not write clear-text cryptographic keys to persistent storage (e.g., hard drives, removable storage, flash drives etc.) except for the following:

• Memory swap/page file purposes

• Core dumps of memory required for trouble-shooting Documented configuration procedures …

Added p. 65

4D-1.14.1 The locations must be predefined and documented.

4D-1.14.1.a Review Host System configuration standards to verify that storage locations of any swap/page files and core dumps are defined.

Host System configuration standards reviewed:

<Report Findings Here> 4D-1.14.1.b Examine Host System configuration settings to verify that the Host System only outputs swap/page files and core dumps to the documented storage locations.

Describe how the Host System configuration settings examined verified that the Host System only outputs swap/page files and core dumps to the documented storage locations:

<Report Findings Here> 4D-1.14.2 Storage can only be made to a dedicated hard drive (on its own bus) within the host.

4D-1.14.2 Examine Host System configuration settings and storage locations to verify that swap/page files and core dumps are written to a dedicated hard drive on its own bus on the Host System.

Describe how the Host System configuration settings and storage locations examined verified that swap/page files and core dumps are …

Added p. 66

4D-1.14.4.a Examine documented procedures to verify that controls are defined to ensure that the access to, and use of, any tools used for trouble- shooting or forensics, are controlled and authorized by management.

Documented procedures reviewed: <Report Findings Here> 4D-1.14.4.b Observe the process for accessing the tools used for trouble- shooting or forensics, and verify that they are controlled and authorized by management in accordance with the documented procedure.

Describe how the process for accessing the tools used for trouble-shooting or forensics verified that they are controlled and authorized by management in accordance with the documented procedure:

<Report Findings Here> 4D-1.14.4.c Observe the process for using the tools used for trouble- shooting or forensics, and verify that they are controlled and authorized by management in accordance with the documented procedure.

Describe how the process for using the tools used for trouble-shooting or forensics verified that they are controlled and authorized by management in accordance …

Added p. 67

Core dumps must be securely deleted immediately after analysis.

Memory swap/page files must be securely deleted upon system shut down or reset.

4D-1.14.5.a Review documented procedures to verify that it defines a process for securely deleting swap/page files and core dumps at the required times:

• Core dumps must be securely

• deleted immediately after analysis.

• Memory swap/page files must be securely

• deleted upon system shut down or reset.

Documented procedures reviewed: <Report Findings Here> 4D-1.14.5.b Verify, through the use of forensic tools and/or methods, that the secure procedure removes swap/page files and core dumps, in accordance with industry-accepted standards for secure deletion of data.

Describe the forensic tools and/or methods used to verify that the secure procedure removes swap/page files and core dumps, in accordance with industry-accepted standards for secure deletion of data:

<Report Findings Here> 4D-2.1 Host user passwords must be changed at least every 30 days.

Note: This requirement applies to all user roles associated …

Added p. 68

• Consist of a combination of numeric, alphabetic, and special characters, or Have equivalent strength/complexity.

4D-2.2.a Examine documented policies and procedures to verify that user passwords must:

Added p. 68

<Report Findings Here> 4D-2.2.b Inspect Host System (s) configuration settings to verify that user passwords:

Describe how the Host System configuration settings inspected verified that user passwords:

Added p. 69

4D-2.3.a If log-on security tokens are used, observe the security tokens in use to verify that they have an associated usage-authentication mechanism, such as a biometric or associated PIN or password/passphrase to enable their usage.

Log-on security tokens in use: <Report Findings Here> Describe how log-on security tokens in use verified that an associated usage- authentication mechanism is in place to enable their usage:

<Report Findings Here> 4D-2.3.b Examine token-configuration settings to verify parameters are set to require that PINs or password/passphrases be at least ten alphanumeric characters in length, or equivalent.

Describe how the token-configuration settings examined verified that parameters are set to require that PINs or password/passphrases be at least ten alphanumeric characters in length, or equivalent:

<Report Findings Here> 4D-2.4 User accounts must be locked out of the Host System after not more than five failed attempts.

4D-2.4.a Examine documented policies and procedures to verify that authentication parameters on the Host System …

Added p. 70

• auditing of host functions 4D-2.5.a Examine documented access-control procedures to verify they define, at a minimum, the following roles:

• auditing of host functions Documented access-control procedures reviewed:

<Report Findings Here> 4D-2.5.b Inspect the Host System configuration settings to verify that role- based access control is enforced and, at a minimum, the following roles are defined:

• auditing of host functions Describe how the Host System configuration settings inspected verified that role-based access control is enforced and, at a minimum, the following roles are defined:

• auditing of host functions <Report Findings Here> 4D-2.5.c Interview a sample of users for each role to verify the assigned role is appropriate for their job function.

Sample of users for each role interviewed: <Report Findings Here>

Added p. 71

The following conditions must be applied:

4D-2.6.1 A Host System user must not be permitted to audit their own activity on the Host System.

4D-2.6.1.a Examine documented procedures to verify that a Host System user is not permitted to audit their own activity on the Host System.

Documented procedures reviewed: <Report Findings Here> 4D-2.6.1.b Interview audit personnel to verify that a Host System user is not permitted to audit their own activity on the Host System.

Audit personnel interviewed: <Report Findings Here> 4D-2.6.2 A Host System administrator must use their operator-level account when performing non-administrative functions.

4D-2.6.2.a Review documented policies and procedures to verify a Host System administrator is not permitted to use their administrative-level account when performing non-administrative functions.

<Report Findings Here> 4D-2.6.2.b Interview and observe a Host System administrator to verify they use their operator-level account when performing non-administrative functions.

Host System administrator interviewed: <Report Findings Here> Describe how the observation of the Host System …

Added p. 72

4D-2.7.a Examine documented policies and procedures to verify that changes to a user’s access privileges are managed:

<Report Findings Here> 4D-2.7.b Observe the process required to change a user’s access privileges and verify that it is managed:

Describe how the observed process to change a user’s access privileges verified that it is managed:

<Report Findings Here> 4D-2.7.c Inspect the Host System configuration settings and, for a sample of user accounts, verify that any changes to their access privileges have been formally documented in the audit log.

Sample of user accounts: <Report Findings Here> Describe how the Host System configuration settings inspected verified that for the sample of user accounts, any changes to their access privileges have been formally documented in the audit log:

Added p. 73

4D-2.8.a Examine documented policies and procedures to verify that access privileges are reviewed, at a minimum, on a quarterly basis to ensure that the access privileges for personnel authorized to access the decryption environment, the Host System, and Host System software required by their position and job function, are correctly assigned.

<Report Findings Here> 4D-2.8.b Examine records and interview personnel to verify that access privileges are reviewed, at a minimum, on a quarterly basis.

Personnel interviewed: <Report Findings Here> Records reviewed: <Report Findings Here> 4D-2.9 Tamper-detection mechanisms must be implemented on the host, to include an alert generation upon opening of the Host System case, covers and/or doors.

4D-2.9.a Review Host System documentation to verify that tamper- detection mechanisms are defined for the Host System, including the generation of an alert upon opening of the Host System case, covers and/or doors.

Host System documentation reviewed: <Report Findings Here> 4D-2.9.b Observe tamper-detection mechanisms on the …

Added p. 74

4D-3.1.a For a sample of systems that are authorized to connect to the Host System via a non-console connection, inspect configuration settings to verify that access to the Host System is provided through the use of strong cryptography and security protocols.

Sample of systems reviewed: <Report Findings Here> Describe how the configuration settings inspected verified that access to the Host System is provided through the use of strong cryptography and security protocols:

<Report Findings Here> 4D-3.1.b Inspect the configuration settings of system components to verify that all traffic transmitted over the secure channel uses strong cryptography.

Describe how the configuration settings of system components verified that all traffic transmitted over the secure channel uses strong cryptography:

<Report Findings Here> 4D-3.2 Non-console access to the Host System must not provide access to any other service, or channel, outside of that used to connect to the Host, e.g., “split tunneling.” 4D-3.2.a Inspect the configuration settings of …

Added p. 75

4D-3.3.a Inspect the configuration settings of the Host System and/or the device permitted to connect to the Host System, to verify that multi-factor authentication is required for non-console access to the Host System.

Describe how the configuration settings of the Host System and/or the device permitted to connect to the Host System verified that multi-factor authentication is required for non- console access to the Host System:

<Report Findings Here> 4D-3.3.b Observe a Host System administrator log on to the device that provides non-console access to the Host System to verify that multi-factor authentication is required.

Describe how the Host System administrator’s log on to the device that provides non- console access to the Host System verified that multi-factor authentication is required:

<Report Findings Here> 4D-3.4 Non-console connections to the Host System must only be permitted from authorized systems.

4D-3.4.a Examine documented policies and procedures to verify that a process is defined to authorize systems for …

Added p. 76

4D-3.5.1 Review solution provider documentation, including PCI DSS ROC and/or Attestation of Compliance (AOC), data-flow diagrams, policies and, system configuration standards, to verify that the system authorized for non- console access meets all applicable PCI DSS requirements.

Solution provider documentation reviewed (including PCI DSS ROC and/or AOC):

Solution provider documentation reviewed (including PCI DSS ROC and/or AOC):

<Report Findings Here> 4D-3.5.2 The network/system that facilitates non-console access to the Host System must:

• Originate from and be managed by the solution provider.

• Originate from and be managed by the solution provider.

• Meet all applicable PCI DSS requirements.

• Meet all applicable PCI DSS requirements.

4D-3.5.2 Review solution provider documentation, including PCI DSS ROC and/or Attestation of Compliance (AOC), data-flow diagrams, policies and, system configuration standards, to verify that the network/system that facilitates non-console access to the Host System must:

<Report Findings Here> 4D-3.6 Users with access to non-console connections to the Host System must be authorized to …

Added p. 77

4D-3.7.a Review documented policies and procedures to verify that the system parameters are set to terminate non-console sessions after 15 minutes of inactivity.

<Report Findings Here> 4D-3.7.b Inspect the system configuration settings to verify that the system parameters are set to terminate non-console sessions after 15 minutes of inactivity.

Describe how system configuration settings verified that the system parameters are set to terminate non-console sessions after 15 minutes of inactivity:

<Report Findings Here> 4D-4.1 The Host System must be located within a physically secure room that is dedicated to decryption operations and transaction processing.

Note: Where “secure room” is referred to in this section, these controls can be met at room level, rack level, or a combination of both. Whichever way the requirements are applied, they should ensure that access the Host System is appropriately secured, whether in a secure room or a secure rack. For example, access to systems in a rack should …

Added p. 78

4D-4.2.a Examine documented policies and procedures to verify that all individuals must be identified and authenticated before being granted access to the secure room.

<Report Findings Here> 4D-4.2.b Examine physical access controls to verify that all individuals are identified and authenticated before being granted access to the secure room.

Physical access controls examined: <Report Findings Here> 4D-4.2.c Observe authorized personnel entering the secure room to verify that all individuals are identified and authenticated before being granted access.

Describe how observation of authorized personnel entering the secure room verified that all individuals are identified and authenticated before being granted access:

Added p. 79

• Logs must be retained for a minimum of three years.

• Logs must be regularly reviewed by an authorized person who does not have access to the secure room or to the systems therein.

• Log reviews must be documented.

• Logs must include but not be limited to:

• Logs of access to the room from a badge access system

• Logs of access to the room from a manual sign-in sheet 4D-4.3.a Examine documented policies and procedures to verify all physical access to the secure room must be monitored and logs must be maintained. Policies and procedures must require the following:

• Logs are retained for a minimum of three years.

• Logs are regularly reviewed by an authorized person who does not have access to the secure room or to the systems therein.

• Log reviews are documented.

• Log reviews are documented.

• Logs include at a minimum:

• Logs include at a minimum:

• Access to …

Added p. 80

4D-4.4.a Inspect physical access controls to verify that dual access is enforced.

Physical access controls inspected: <Report Findings Here> 4D-4.4.b Observe authorized personnel entering the secure room to verify that dual access is enforced.

Describe how observation of authorized personnel entering the secure room verified that dual control is enforced:

<Report Findings Here> 4D-4.5 Physical access must be only permitted to designated personnel with defined business needs and duties.

4D-4.5.a Examine documented policies and procedures to verify that physical access to the secure room is only permitted to designated personnel with defined business needs and duties.

<Report Findings Here> 4D-4.5.b Examine the list of designated personnel and interview responsible personnel to verify that only personnel with defined business needs and duties are permitted access to the secure room.

Documented list of designated personnel: <Report Findings Here> Responsible personnel interviewed: <Report Findings Here> 4D-4.5.c Examine physical access controls to verify that physical access to the secure room …

Added p. 81

• Access to the Host System and HSM(s)

Note: Motion-activated systems that are separate from the intrusion-detection system may be used.

4D-4.6.a Inspect CCTV configuration and review a sample of recordings to verify that CCTV monitoring is in place on a 24 hour basis, and covers, at a minimum, the following areas:

• Access to the Host System and HSM(s) Sample of CCTV recordings reviewed: <Report Findings Here> Describe how CCTV configurations observed verified that CCTV monitoring is in place on a 24 hour basis, and covers, at a minimum, the following areas:

• Access to the Host System and HSM(s) <Report Findings Here> 4D-4.6.b If CCTV is motion-activated, observe system configurations for the motion-activated systems to verify they are separate from the intrusion- detection system.

Describe how system configurations for the motion-activated systems verified that they are separate from the intrusion-detection systems:

<Report Findings Here> 4D-4.7 Surveillance cameras must not be configured to allow the …

Added p. 83

Note: Visible spectrum lighting may not be necessary if the cameras do not require such lighting to capture images (e.g., when infrared cameras are used).

4D-4.10.a Observe the secure room to verify that continuous or motion- activated lighting is provided for the cameras monitoring the secure room.

Describe how the observed secure room verified that continuous or motion-activated lighting is provided for the cameras monitoring the secure room:

<Report Findings Here> 4D-4.10.b Examine a sample of recorded CCTV images to verify that appropriate lighting is provided when persons are present in the secure room.

Sample of recorded CCTV images examined:

<Report Findings Here> 4D-4.11 A 24/7 physical intrusion-detection system must be in place for the secure room (e.g., motion detectors when unoccupied). This must be connected to the alarm system and automatically activated whenever all authorized personnel have exited the secure room.

4D-4.11.a Examine security policies and procedures to verify they require:

• Continuous (24/7) physical intrusion-detection …

Added p. 83

<Report Findings Here> 4D-4.11.b Observe the physical intrusion-detection system to verify that it:

• Provides continuous (24/7) monitoring of the secure room.

• Provides continuous (24/7) monitoring of the secure room.

• It is connected to the alarm system and automatically activated whenever all authorized personnel have exited the secure room.

• It is connected to the alarm system and automatically activated whenever all authorized personnel have exited the secure room.

Describe how the physical intrusion-detection system verified that it:

Added p. 84

4D-4.12.a Observe all windows in the secure room to verify they are locked and protected by alarmed sensors.

Identify the P2PE Assessor who confirms all windows in the observed secure room are locked and protected by alarmed sensors:

<Report Findings Here> 4D-4.12.b Examine configuration of window sensors to verify that the alarm mechanism is active.

Describe how configuration of window sensors verified that the alarm mechanism is active:

<Report Findings Here> 4D-4.13 Any windows must be covered, rendered opaque, or positioned to prevent unauthorized observation of the secure room.

4D-4.13 Observe all windows in the secure areas to verify they are covered, rendered opaque, or positioned to prevent unauthorized observation of the secure room.

Identify the P2PE Assessor who confirms all windows in the observed secure room are covered, rendered opaque, or positioned to prevent unauthorized observation of the secure room:

<Report Findings Here> 4D-4.14 Access-control and monitoring systems must be connected to an uninterruptible power source …

Added p. 86

Note: This may be done by either automated or manual mechanisms.

4D-4.19.a Examine documented procedures to verify that mechanisms are defined for synchronizing the time and date stamps of the access, intrusion- detection, and monitoring (camera) systems.

Documented procedures reviewed: <Report Findings Here> 4D-4.19.b Examine system configurations for access, intrusion-detection, and monitoring (camera) systems to verify that time and date stamps are synchronized.

Describe how system configurations for access, intrusion-detection, and monitoring (camera) systems verified that time and date stamps are synchronized:

<Report Findings Here> 4D-4.19.c Examine a sample of logs from the access, intrusion-detection, and monitoring (camera) systems to verify log time and date stamps are synchronized.

Sample of logs from the access, intrusion- detection, and monitoring (camera) systems:

<Report Findings Here> 4D-4.19.1 If a manual synchronization process is used, synchronization must occur at least quarterly, and documentation of the synchronization must be retained for at least a one-year period.

4D-4.19.1.a If a manual synchronization process …

Added p. 87

• A door that is contact monitored and fitted with automatic closing or locking devices.

• A door that is contact monitored and fitted with automatic closing or locking devices.

• An airlock entrance system.

• An airlock entrance system.

4D-4.20 Observe authorized personnel entering the secure room to verify that a mechanism is in place to ensure the door is not left open.

Describe how the observation of authorized personnel entering the secure room verified that a mechanism is in place to ensure the door is not left open:

<Report Findings Here> 4D-4.21 An audible alarm must sound if the entrance to the secure room remains open for more than 30 seconds.

4D-4.21.a Examine secure room entry mechanisms to verify that an audible alarm is configured to sound if the entrance remains open for more than 30 seconds.

Identify the secure room entry mechanisms examined:

<Report Findings Here> 4D-4.21.b Observe authorized personnel entering the secure room and request …

Added p. 88

• Providing reports annually and upon significant changes

• Details of any suspicious activity that occurred, per 4C-1.2 Component provider’s documented procedures reviewed:

<Report Findings Here> 4E-1.1.b Observe reports provided to applicable solution providers annually and upon significant changes to the solution, and confirm they include at least the following:

• Types/models of HSMs

• Number of HSMs deployed and description of any changes since last report

• Details of any suspicious activity that occurred, per 4C-1.2 Identify reports reviewed: <Report Findings Here>

Added p. 89

Note: Adding or removing HSM types may require adherence to PCI SSC’s process for P2PE Designated Changes to Solutions. Please refer to the P2PE Program Guide for details about obligations when adding, changing, or removing elements of a P2PE solution.

4E-1.2.a Review component provider’s documented procedures and interview responsible component-provider personnel, and confirm that processes include notifying the solution provider upon occurrence of the following:

• Additions and/or removal of HSM types Component provider’s documented procedures reviewed:

<Report Findings Here> Responsible component provider personnel interviewed:

<Report Findings Here> 4E-1.2.b Observe reports provided to applicable solution providers, and confirm at least the following are reported upon occurrence:

• Additions and/or removal of HSM types Identify reports reviewed: <Report Findings Here>

For each PCI-approved HSM used in the solution, describe how the HSM device configurations observed verified that all of the device characteristics at 1-4.a match the PTS listing:

<Report Findings Here> 1-5 Not used in DMS Requirements 2, …

Added p. 95

• Each custodian’s access to clear-text output is limited to the individual component(s)/share(s) assigned to that custodian and not the entire key.

<Report Findings Here> Describe how the key-generations processes observed verified that there is no mechanism (including connectivity) that might disclose a clear-text key or key component between the key-generation device and the device or medium receiving the key or key component:

<Report Findings Here> 6-1.2 There must be no point in the key-generation process where a single individual has the ability to determine, obtain, or ascertain any part of a clear-text key or all the components for a key.

Describe how the end-to-end process verified that there is no point in the process where a single person has the ability to determine, obtain, or ascertain any part of a clear-text key or all the components for a key:

Added p. 103

<Report Findings Here> 6-3.7 The CCTV cameras must be positioned to monitor:

• Other types of displaying or recording (e.g., printer memory, printer drum).

Added p. 112

- They define how the details of the package serial number are to be transmitted. - There is a requirement that the package serial number is to be sent separately from the package itself. - Each component is to be sent to/from only the custodian(s) authorized for the component.

Added p. 113

• The details of the serial number of the package were transmitted separately from the package itself. - At least two communication channels were used to send the components of a given key (not just separation by sending on different days). - Each component was sent to/from only the custodian(s) authorized for the component

- Prior to the use of the component, the serial number was confirmed.

Added p. 116

• Only designated custodians can send/receive the component or share.

Records of key conveyances examined:

Added p. 119

<Report Findings Here> Responsible personnel interviewed: <Report Findings Here> 9-1 During the process to convey it, any single clear-text secret or private key component/share must at all times be either:

<Report Findings Here> 9-2.b Interview responsible personnel and observe processes to verify that all packaging or mailers containing clear-text key components are examined for evidence of tampering before being opened.

• Any keys encrypted under this (combined) key Responsible personnel interviewed:

• Upon receipt, check the tamper-evident packaging for signs of tamper prior to opening the tamper-evident packaging containing the key component.

• The components are repackaged at receipt into separate tamper- evident and authenticable packages for storage at the receiving location.

• Records reflect the receipt of the shipped bag and association with subsequent individual bags Identify the P2PE Assessor who determined that if components or shares of multiple are being sent simultaneously between the same sending and receiving custodians, the component/shares for a …

Added p. 129

<Report Findings Here> 12-1.e Ensure key-loading devices can only be accessed and used under dual control.

12-3.a Identify instances where a key-loading device is used to load clear- text keys. Examine documented procedures for loading of clear-text cryptographic keys to verify:

• Dual control is necessary to authorize the key-loading session.

• Expected techniques are used.

• Default passwords/authentications codes are reset.

• Any passwords/authentication codes used are a minimum of five characters.

• Any passwords/authentication codes or tokens are maintained separately.

<Report Findings Here> 12-3.c Examine documented records of key-loading to verify the presence of two authorized persons during each type of key-loading activity.

• in a key-loading device) have been disabled or changed.

<Report Findings Here> 12-5 Hardware security module (HSM) Master File Keys, including those generated internal to the HSM and never exported, must use AES with a key size of at least 128 bits.

<Report Findings Here> 12-7 The initial terminal master key (TMK) or initial …

Added p. 141

<Report Findings Here> 13-7 Written or printed key component documents must not be opened until immediately prior to use.

Added p. 144

<Report Findings Here> 14-4.d Verify that access-control logs exist and are in use including notation of tamper-evident, authenticable bag numbers.

Added p. 148

<Report Findings Here> Personnel interviewed: <Report Findings Here> 17-1.b For all keys shared between two organizations or logically separate systems for encrypting account data (including key-encryption keys used to encrypt a data-encryption key) perform the following:

Documented procedures reviewed: <Report Findings Here> 18-2 To prevent or detect usage of a compromised key, key-component packaging or containers that show signs of tampering must result in the discarding and invalidation of the component and the associated key at all locations where they exist.

18-2.a Verify documented procedures require that key-component packaging/containers showing signs of tampering must result in the discarding and invalidation of all associated key components and the resultant cryptographic key(s) at all locations where they exist.

Documented procedures reviewed: <Report Findings Here> 18-2.b Interview personnel and observe processes to verify procedures are implemented to require that key-component packaging/containers showing signs of tampering result in the discarding and invalidation of all associated key components …

Added p. 153

• Key used for production keys must never be present or used in a test system, and

Added p. 156

20-2 Determine whether POI devices are intended to interface with multiple entities for decryption.

Indicate whether POI devices are intended to interface with multiple entities for decryption (yes/no) <Report Findings Here> If “no,” describe how it was verified that POI devices are not intended to interface with multiple entities for decryption.

(Leave 20-2.a to 20-2.c blank) <Report Findings Here> If “yes”, complete 20-2.a to 20-2.c:

Personnel interviewed: <Report Findings Here> 20-2.c Observe processes for generation and injection of keys into a single POI device for more than one acquiring organization, to verify:

• The POI device has a completely different and unique key, or set of keys, for each acquiring organization.

• These different keys, or sets of keys, are totally independent and not variants of one another.

Note: The same BDK with the same KSN installed in multiple injection systems or installed multiple times within the same injection system will not meet uniqueness requirements.

• Unique …

Added p. 162

Responsible personnel interviewed: <Report Findings Here> 21-3.1.d Confirm that start-up instructions and other notes used by service technicians do not contain initialization-key values written in the clear (e.g., at the point in the checklist where the keys are entered).

Added p. 165

22-1.3 Interview responsible personnel and observe implemented processes to verify that if compromise of the cryptographic key is suspected, an assessment and analysis is performed. If compromise is confirmed, all the following are performed:

Added p. 171

• Variants used as KEKs must only be calculated from other key- encrypting keys

Documented procedures reviewed: <Report Findings Here> Describe how the implemented processes observed verified that reversible key transformations are not used across different levels of the key hierarchy, as follows:

Documented procedures reviewed: <Report Findings Here> 24-2.b Observe key-destruction processes to verify that no part of the key or component can be recovered.

Added p. 180

• Tamper-evident and authenticable package number (if applicable) <Report Findings Here> 27-1 If backup copies of secret and/or private keys exist, they must be maintained in accordance with the same requirements as are followed for the primary keys.

Added p. 184

<Report Findings Here> 29-1.1.1.c Examine implemented access controls to verify that unauthorized individuals cannot access, modify, or substitute any POI device or other SCD.

Identify the P2PE Assessor who verified the access controls ensure only personnel documented and authorized in an auditable manner have access to devices.

Personnel interviewed: <Report Findings Here> Identify the P2PE Assessor who verified the access controls ensure only personnel documented and authorized in an auditable manner have access to devices.

29-3.a Examine documented procedures to confirm that they require physical protection of devices from the manufacturer’s facility up to the point of key-insertion and deployment, through one or more of the defined methods.

Documented procedures reviewed: <Report Findings Here> 29-3.b Interview responsible personnel to verify that one or more of the defined methods are in place to provide physical device protection for devices, from the manufacturer’s facility up to the point of key-insertion and deployment.

Documented procedures reviewed: <Report Findings …

Added p. 192

Documented procedures reviewed: <Report Findings Here> 31-1.1 HSMs require dual control (e.g., to invoke the system menu) to implement for all critical decommissioning processes.

<Report Findings Here> 31-1.3 SCDs being decommissioned are tested and inspected to ensure keys have been rendered irrecoverable.

Personnel interviewed: <Report Findings Here> Records of testing examined: <Report Findings Here> 32-1 Not used in DMS 32-2 Not used in DMS 32-3 Not used in DMS 32-4 Not used in DMS 32-5 Not used in DMS 32-6 Not used in DMS 32-7 Not used in DMS 32-8 Not used in DMS 32-9 Not used in DMS

Added p. 200

• Each DDK must have a defined usage period (cryptoperiod) based on a formal risk assessment and industry guidance as provided in NIST SP800-57, ISO TR 14742 and NIST SP800-131. The cryptoperiod defines the duration of time that the DDK may be used to decrypt account data, defined either as a maximum threshold of transactions, or hours, or both (e.g., 1024 transactions or 24 hours, whichever is reached first).

• Each DDK must have a defined usage period (cryptoperiod) based on a formal risk assessment and industry guidance as provided in NIST SP800-57, ISO TR 14742 and NIST SP800-131. The cryptoperiod defines the duration of time that the DDK may be used to decrypt account data, defined either as a maximum threshold of transactions, or hours, or both (e.g., 1024 transactions or 24 hours, whichever is reached first).

• Upon reaching the defined usage threshold, the DDK must not be used for …

Added p. 201

5H-1.2.a Examine documented key-management policies and procedures to verify that the mechanism used to erase a DDK from the Host System volatile memory is sufficient to ensure the key cannot be recovered or reconstructed.

<Report Findings Here> 5H-1.2.b Verify, through the use of forensic tools and/or methods, that the mechanism used to erase the DDK from the host volatile memory, is sufficient to ensure the key cannot be recovered or reconstructed.

Describe the forensic tools and/or other methods used that verified that the mechanism used to erase the DDK from the host volatile memory, is sufficient to ensure the key cannot be recovered or reconstructed:

<Report Findings Here> 5H-1.3 If the DDK is generated from a master key, the following conditions apply:

• A one-way derivation process must be used.

• A one-way derivation process must be used.

• The DDK must never be generated as a variant of the HSM master file key.

• The DDK …

Added p. 202

5H-1.4.a Examine key-management policies and procedures to verify that DDKs must be encrypted between the HSM and the Host System.

<Report Findings Here> 5H-1.4.b Examine HSM and Host System configurations to verify that DDKs are encrypted between the HSM and the Host System.

Describe how the HSM and Host System configurations examined verified that DDKs are encrypted between the HSM and the Host System:

<Report Findings Here> 5H-1.4.c Examine the HSM security policies and observe HSM implementations to verify that the method of encryption used maintains the security policy to which the HSM was approved.

Describe how the HSM security policies and HSM implementations examined verified that the method of encryption used maintains the security policy to which the HSM was approved:

<Report Findings Here> 5H-1.5 The encryption mechanism used to protect the DDK between the HSM and the Host System:

5H-1.5 Verify the encryption mechanism used to protect the DDK between the HSM and the …

Added p. 203

5H-1.5.2.a Examine documented key-management policies and procedures to verify that the encryption mechanism uses an encryption key that is unique for each Host System.

<Report Findings Here> 5H-1.5.2.b Observe key-management processes to verify that the encryption mechanism uses an encryption key that is unique for each Host System.

Describe how the key-management processes observed verified that the encryption mechanism uses an encryption key that is unique for each Host System:

<Report Findings Here> 5H-1.5.3 The encryption key must only be used to encrypt the DDK during transmission between the HSM and the Host System, and not used to encrypt/transmit any other cryptographic key, or for any other purpose.

5H-1.5.3.a Examine documented key-management policies and procedures to verify that the encryption mechanism uses an encryption key that is only used to encrypt the DDK during transmission between the HSM and the Host System, and not used to encrypt/transmit any other cryptographic key, or for any …

Added p. 204

5H-1.5.4.a Examine documented key-management policies and procedures to verify that the encryption mechanism uses an encryption key that has a defined cryptoperiod based on the volume of keys it transports and industry recommendations/best practices.

<Report Findings Here> 5H-1.5.4.b Observe key-management processes to verify that the encryption mechanism uses an encryption key that has a defined cryptoperiod based on the volume of keys it transports and industry recommendations/best practices.

Describe how the key-management processes observed verified that the encryption mechanism uses an encryption key that has a defined cryptoperiod based on the volume of keys it transports and industry recommendations/best practices:

Modified p. 1

Payment Card Industry (PCI) Point-to-Point Encryption ~~Encryption~~ Management Services Template for Report on Validation for use with P2PE v3.1 for P2PE ~~Encryption~~ Management Services Assessments

Payment Card Industry (PCI) Point-to-Point Encryption Decryption Management Services Template for Report on Validation for use with P2PE v3.1 for P2PE Decryption Management Services Assessments

Modified p. 2

• added where applicable regarding the use of this template for ~~EMS~~ Component assessments vs. Solution assessments.

• added where applicable regarding the use of this template for DMS Component assessments vs. Solution assessments.

Modified p. 5

~~EMS~~ Component Assessments: Use of this Reporting Template is mandatory for all P2PE v3.1 ~~Encryption~~ Management Services Component Provider ~~assessments.~~

DMS Component Assessments: Use of this Reporting Template is mandatory for all P2PE v3.1 Decryption Management Services Component Provider assessments (i.e., for a DMCP assessment).

Modified p. 5

Solution Assessments: Use of this Reporting Template is mandatory for all P2PE v3.1 Solution (and Merchant-managed Solution) assessments, where the Solution Provider is directly responsible for all or part of the ~~Encryption~~ Management Services requirements (i.e., when they have not completely satisfied the full scope of their ~~encryption~~ management services via the use of Validated ~~Encryption~~ Management Services P2PE Component Providers).

Solution Assessments: Use of this Reporting Template is mandatory for all P2PE v3.1 Solution (and Merchant-managed Solution) assessments, where the Solution Provider is directly responsible for all or part of the Decryption Management Services requirements (i.e., when they have not completely satisfied the full scope of their decryption management services via the use of Validated Decryption Management Services P2PE Component Providers).

Modified p. 5

A P2PE compliance assessment involves thorough testing and assessment activities, from which the assessor will generate detailed work papers. These work papers contain comprehensive records of the assessment activities, including observations, results of system testing, configuration data, file lists, interview notes, documentation excerpts, references, screenshots, and other evidence collected during the course of the assessment. The P-ROV is effectively a summary of evidence derived from the assessor’s work papers to describe how the assessor performed the validation activities and how …

Modified p. 6

Encryption Management Services (EMS) Solution (SP) Encryption Management CP (EMCP) POI Deployment CP (PDCP) POI Management CP (PMCP) Encryption Management Services relates to the distribution, management, and use of PTS-approved POI devices in a P2PE Solution. Solution assessments that have not satisfied the entirety of their Encryption Management Services (Domain 1 with Domain 5) via the use of Validated Component Providers must complete the EMS P-ROV in addition to the Solution P-ROV. Component Provider assessments for an EMCP, PDCP, or …

Encryption Management Services (EMS) Solution (SP) Encryption Management CP (EMCP) POI Deployment CP (PDCP) POI Management CP (PMCP) Encryption Management Services relates to the distribution, management, and use of PTS-approved POI devices in a P2PE Solution.

Modified p. 6

P2PE Application P2PE Application Any assessment that utilizes software on the PTS-approved POI devices intended for use in a P2PE Solution that has the potential to access clear-text account data must complete a P2PE Application P- ROV (one for each application).

P2PE Application P2PE Application Any assessment that utilizes software on the PTS-approved POI devices intended for use in a P2PE Solution that has the potential to access clear-text account data must complete the P2PE Application P- ROV (one for each application).

Modified p. 6

Decryption Management Services (DMS) Solution (SP) Decryption Management CP (DMCP) Decryption Management Services relates to the management of a decryption environment, including applicable account-data decryption devices used to support a P2PE Solution. Solution assessments that have not satisfied the entirety of their Decryption Management Services (Domain 4 with Domain 5) to applicable Validated P2PE Component Providers must complete the DMS P-ROV in addition to the Solution P-ROV. Component Provider assessments for a DMCP must complete the DMS P-ROV.

Decryption Management Services (DMS) Solution (SP) Decryption Management CP (DMCP) Decryption Management Services relates to the management of a decryption environment, including applicable account-data decryption devices used to support a P2PE Solution.

Modified p. 6

Key Management Services (KMS) Solution (SP) ~~Key Injection~~ Facility (KIF) Key Management CP (KMCP) Key Loading CP (KLCP) CA/RA Key Management Services relates to the generation, conveyance, management, and loading of cryptographic keys including the management of associated devices.

Key Management Services (KMS) Solution (SP) Key-injection Facility (KIF) Key Management CP (KMCP) Key Loading CP (KLCP) CA/RA Key Management Services relates to the generation, conveyance, management, and loading of cryptographic keys including the management of associated devices.

Modified p. 6

Solution assessments that have not satisfied the entirety of key management services requirements (Domain 5) either through the use of Validated P2PE Component Providers and/or through the assessment of their Encryption Management Services and/or Decryption Management Services must complete the KMS P-ROV. E.g., if the P2PE Solution offers remote key-distribution using asymmetric techniques for the distribution of keys to POI devices for use in connection with account-data encryption, or the operation of an applicable ~~CA/RA, or~~ any other relevant key …

Solution assessments that have not satisfied the entirety of key management services requirements (Domain 5) either through the use of Validated P2PE Component Providers and/or through the assessment of their Encryption Management Services and/or Decryption Management Services must complete the KMS P-ROV. E.g., if the P2PE Solution offers remote key-distribution using asymmetric techniques for the distribution of keys to POI devices for use in connection with account-data encryption, or the operation of an applicable CA/RA. Or if any other relevant …

Modified p. 7

Section 1: Contact Information and Report Date

• Section 1: Contact Information and Report Date

Modified p. 7

Section 2: Summary Overview

• Section 2: Summary Overview

Modified p. 7

Section 3: Details and Scope of P2PE Assessment

• Section 3: Details and Scope of P2PE Assessment

Modified p. 7

Section 4: Findings and Observations This Reporting Template includes tables with Reporting Instructions. Details provided should focus on concise quality of detail, rather than lengthy, repeated verbiage.

• Section 4: Findings and Observations This Reporting Template includes tables with Reporting Instructions. Details provided should focus on concise quality of detail, rather than lengthy, repeated verbiage.

Modified p. 7

P-ROV Summary of Findings This version of the P2PE Reporting Template reflects an on-going effort to simplify assessor summary reporting. All summary findings for “In Place,” “Not in Place,” and “Not Applicable” are found at the beginning of section 4 ~~“Findings~~ and ~~Observations”~~ and are only addressed at that high-level. The summary of the overall compliance status is at section 2.8 “Summary of P2PE Assessment Compliance Status.” The following table is a representation when considering which selection to make. Assessors …

P-ROV Summary of Findings This version of the P2PE Reporting Template reflects an on-going effort to simplify assessor summary reporting. All summary findings for “In Place,” “Not in Place,” and “Not Applicable” are found at the beginning of section 4 ”Findings and Observations”, and are only addressed at that high-level. The summary of the overall compliance status is at section 2.8 “Summary of P2PE Assessment Compliance Status.” The following table is a representation when considering which selection to make. Assessors …

Modified p. 8

Document name or interviewee reference At section 3.6, ~~”Documentation~~ Reviewed,” and section 3.7, “Individuals Interviewed,” there is a space for a reference number; it is the P2PE Assessor’s choice to use the document name/interviewee job title or the reference number in responses. A listing is sufficient ~~here;~~ no further detail is required.

Document name or interviewee reference At section 3.6, “Documentation Reviewed,” and section 3.7, “Individuals Interviewed,” there is a space for a reference number; it is the P2PE Assessor’s choice to use the document name/interviewee job title or the reference number in responses. A listing is sufficient here, no further detail required.

Modified p. 10

Confirm that internal QA was fully performed on the entire P2PE ~~submission,~~ per requirements in the relevant program documentation.

Confirm that internal QA was fully performed on the entire P2PE submission per requirements in the relevant program documentation.

Modified p. 10

~~Yes~~ No (If No, this is not in accordance with PCI Program requirements) QA reviewer name: QA reviewer credentials:

No (If No, this is not in accordance with PCI Program requirements) QA reviewer name: QA reviewer credentials:

Modified p. 11

(From DD-MMM-YYYY To DD-MMM-YYYY) 1.3 Additional Services Provided by PA-QSA(P2PE) / QSA(P2PE) / P2PE QSA Company The current version of the “Qualification Requirements for Point-to-Point Encryption (P2PE)TM Qualified Security Assessors

• QSA (P2PE) and PA-QSA (P2PE)” (P2PE QSA Qualification Requirements), section ~~“Independence”,~~ specifies requirements for P2PE QSAs around disclosure of such services and/or offerings that could reasonably be viewed to affect independence of assessment. Complete the sections below after review of this portion of the P2PE QSA Qualification Requirements to ensure …

(From DD-MMM-YYYY To DD-MMM-YYYY) 1.3 Additional Services Provided by PA-QSA(P2PE) / QSA(P2PE) / P2PE QSA Company The current version of the “Qualification Requirements for Point-to-Point Encryption (P2PE)TM Qualified Security Assessors

• QSA (P2PE) and PA-QSA (P2PE)” (P2PE QSA Qualification Requirements), section “Independence” specifies requirements for P2PE QSAs around disclosure of such services and/or offerings that could reasonably be viewed to affect independence of assessment. Complete the sections below after review of this portion of the P2PE QSA Qualification Requirements to ensure …

Modified p. 12

2. Summary Overview 2.1 P2PE Assessment Details Solution or Component Assessment Is this P-ROV being submitted as part of a Solution assessment or for ~~an EMS~~ Component assessment? Solution If Solution, enter the Solution Name: (Complete this P-ROV with the Solution P-ROV) ~~EMS~~ Component If ~~EMS~~ Component, complete the P2PE Component Details below.

2. Summary Overview 2.1 P2PE Assessment Details Solution or Component Assessment Is this P-ROV being submitted as part of a Solution assessment or for a DMS Component assessment? Solution If Solution, enter the Solution Name: (Complete this P-ROV with the Solution P-ROV) DMS Component If DMS Component, complete the P2PE Component Details below.

Modified p. 12

P2PE Component Details (for ~~EMS~~ Component assessments ONLY) P2PE Component Name:

P2PE Component Details (for DMS Component assessments ONLY) P2PE Component Name:

Modified p. 12

Is the Component ~~already~~ (or was it previously) listed on the PCI SSC List of Validated P2PE Components? Yes (If Yes, provide listing reference #):

Is the Component currently (or was it previously) listed on the PCI SSC List of Validated P2PE Components? Yes (If Yes, provide listing reference #):

Modified p. 12

No (If No, the component has never been listed) P2PE ~~EMS~~ Component Type for this ~~assessment. Select one of the following: (Do not check anything for Solution Assessments) Encryption~~ Management Component Provider ~~(EMCP) POI Deployment Component Provider (PDCP) POI Management Component Provider (PMCP)~~

No (If No, the component has never been listed) P2PE Component Type for this assessment: Decryption Management Component Provider (DMCP)

Removed p. 13

For every PDCP and PMCP Component below, document the PTS Approval #s associated with their respective Validated P2PE Component listing that are being included in this assessment. The PTS approval #s here must also be present in Table 2.5. For non-EMS Component Types denote “N/A” in the PTS Approval # column.

Note 3: POI Device Types associated with PDCPs and PMCPs are only assessed to a subset of applicable Domain 1 and Domain 5 requirements. Therefore, only where a POI Device Type is supported by BOTH a Validated PDCP and a PMCP below is it excluded from requiring any additional assessment. Otherwise, each POI Device Type must be assessed to all requirements that were not covered under its associated Component Type assessment. Reference the “P2PE Applicability of Requirements” in the P2PE Program Guide.

Modified p. 13

~~EMS~~ COMPONENT ASSESSMENTS: Complete this table if Validated P2PE Component Providers are being used to help satisfy applicable requirements for this ~~EMS~~ Component assessment.

DMS COMPONENT ASSESSMENTS: Complete this table if Validated P2PE Component Providers are being used to help satisfy applicable requirements for this DMS Component assessment.

Modified p. 13

Note 1: It is not permissible to use a PCI-listed P2PE Component Provider of the same type as the entity under assessment. A PCI-listed ~~EMCP~~ cannot be used to satisfy the requirements of ~~an EMCP~~ under assessment. This applies to all Component ~~type~~ assessments.

Note 1: It is not permissible to use a PCI-listed P2PE Component Provider of the same type as the entity under assessment. A PCI-listed DMCP cannot be used to satisfy the requirements of a DMCP under assessment. This applies to all Component Type assessments.

Modified p. 13

Are Validated P2PE Component Providers being used to help satisfy requirements of this assessment? Yes (If Yes, document below accordingly. Ensure all remaining applicable requirements are assessed and satisfied as they relate to the full scope of the assessment.) No (If No, leave the remainder of this table blank. Ensure all applicable requirements are assessed and satisfied as they relate to the full scope of the assessment.) Type of Validated P2PE Component (select ONLY one Component Type per row) P2PE …

Note 2: The use of PCI-listed P2PE Component Providers must be considered Validated. Refer to the P2PE Program Guide for additional details. https://www.pcisecuritystandards.org/assessors_and_solutions/point_to_point_encryption_components Are Validated P2PE Component Providers being used to help satisfy requirements in scope for this assessment? Yes (If Yes, document below accordingly. Ensure all remaining applicable requirements are assessed and satisfied as they relate to the full scope of the assessment.) No (If No, leave the remainder of this table blank. Ensure all applicable requirements are assessed …

Modified p. 14

Provide more detail than simply, e.g., “The KIF is satisfying Domain 5 for the ~~EMCP”.~~ Do not leave this blank unless No was checked above.

Provide more detail than simply, e.g., “The KIF is satisfying Domain 5 for the DMCP”. Do not leave this blank unless No was checked above.

Modified p. 15

SOLUTION ASSESSMENTS: Document the use of all Third Parties as they relate to (only) ~~Encryption~~ Management Services here. It is not necessary to duplicate this information in the Solution P-ROV.

SOLUTION ASSESSMENTS: Document the use of all Third Parties as they relate to (only) Decryption Management Services here. It is not necessary to duplicate this information in the Solution P-ROV.

Modified p. 15

~~EMS~~ COMPONENT ASSESSMENTS: Document the use of all applicable Third Parties.

DMS COMPONENT ASSESSMENTS: Document the use of all applicable Third Parties.

Modified p. 15

Are Third Party entities involved in the scope of ~~Encryption~~ Management Services for this assessment? Yes (If Yes, provide details below - insert additional rows as necessary) No (If No, leave remainder of this table blank) Entity Name Entity Location(s) Role / Function Provide any additional details regarding the use of Third Parties, as necessary. Otherwise, check No Additional Details. No Additional Details <Additional Details, as needed>

Are Third Party entities involved in the scope of Decryption Management Services for this assessment? Yes (If Yes, provide details below - insert additional rows as necessary) No (If No, leave remainder of this table blank) Entity Name Entity Location(s) Role / Function Provide any additional details regarding the use of Third Parties, as necessary. Otherwise, check No Additional Details. No Additional Details <Additional Details, as needed> 2.4 (Table not currently used) 2.5 (Table not currently used)

Removed p. 16

SOLUTION ASSESSMENTS: All non-payment software used by the Solution must be accounted for and satisfy requirement 1C-2.

EMS COMPONENT ASSESSMENTS: Complete this table as applicable. Note that non-payment software is not listed, and as such, any non-payment software, while it must be accounted for in the scope of the EMS assessment, cannot be used in another Component or Solution without being reassessed.

Non-payment software is any software/files that does not have the potential to access clear-text account data. (Refer to P2PE Glossary)

Note: “P2PE Applications” and “P2PE non-payment software” (refer to P2PE Glossary) do not meet the PTS POI definition of “firmware”, and as such they are not reviewed as part of the POI device’s PTS POI assessment (i.e., they cannot be excluded from the scope of a P2PE assessment). Therefore, any software intended for use in a P2PE Solution that does not meet the PTS POI definition of "firmware" must be assessed …

Removed p. 17

EMS COMPONENT ASSESSMENTS: The use of any non-Validated applications that have the potential to access clear-text account data requires a P2PE Application P-ROV and associated Domain 2 assessment. P2PE Component assessments are not permitted to include non-Validated P2PE Applications (i.e., applications that can access clear-text account data must be listed on the List of Validated P2PE Applications). This table is only for Validated P2PE Applications. ONLY list the PTS Approval #s from each Validated P2PE Application in use that are actually supported by the P2PE Component or Solution under assessment. Each PTS Approval # here must be in Table 2.5 - i.e., all POI Device Types associated with a Validated P2PE Application must have been assessed to all applicable requirements in Domains 1 and 5. As POI Device Types associated with Validated P2PE Applications are only assessed to Domain 2, each POI Device Type supported by a Validated P2PE Application …

Removed p. 19

• Only list each unique PTS Approval # once.

• List ALL associated hardware (HW) and firmware (FW) versions supported by the Encryption Management Services or Solution and tested as part of the P2PE assessment.

• Ensure all the information below is correct, accurate, and there are no discrepancies between the information listed here and the information present on the POI device’s associated PTS Approval listing.

• Do NOT include POI devices (including HW and/or FW) that are ineligible for P2PE (e.g., non-SRED).

• Do NOT include HW and/or FW on the POI device listing that was NOT tested as part of the P2PE assessment.

Note 1: Be advised there can be POI device approval listings that appear similar/identical on the PCI SSC list of Approved PTS devices, however, they are associated with different major versions of the PTS POI Standard. Be sure the correct listing is being referenced and utilized in the assessment.

Note 2: …

Removed p. 20

PTS Approval # (One unique # per row) Make / Mfr. Model Name / Number Hardware (HW) #(s) Tested Firmware (FW) #(s) Tested For each PTS Approval #, denote the manner that the PTS- approved POI Device Types were assessed to all applicable requirements in Domains 1 and 5:

“Entirely through the use of applicable Validated P2PE Components (Only an option for Solution assessments)” “A combination of applicable Validated P2PE Components and an assessment to the remaining requirements in section 4 below” “A complete assessment to all applicable requirements in Domains 1 and 5 in section 4 below”

Removed p. 21

Note: PTS-approved POI device information used for account-data capture and encryption must be entered in Table 2.5. Do not enter it here. Insert additional rows as necessary.

Modified p. 21 → 16

SOLUTION ASSESSMENTS: Document the use of all SCDs as they relate to (only) ~~Encryption~~ Management Services here. It is not necessary to duplicate this information in the Solution P-ROV.

SOLUTION ASSESSMENTS: Document the use of all SCDs as they relate to (only) Decryption Management Services here. It is not necessary to duplicate this information in the Solution P-ROV.

Modified p. 21 → 16

~~EMS~~ COMPONENT ASSESSMENTS: Complete this table as applicable.

DMS COMPONENT ASSESSMENTS: Complete this table as applicable. Insert additional rows as necessary.

Modified p. 21 → 16

Identifier Type PTS and/or FIPS Approval # Manufacturer / Model Name / Number ~~Hardware #(s) (comma delimited) Firmware #(s) (comma delimited)~~ Location Number of Devices per Location Approved Key Function(s) & Purpose

Identifier Type PTS and/or FIPS Approval # Manufacturer / Model Name / Number Hardware#(s) Firmware#(s) Location Number of Devices per Location Approved Key Function(s) & Purpose

Removed p. 22

Note 2: While non-payment software is not permitted to have access to clear-text account data, it might still be involved in supporting additional encryption implementations. Non-payment software detailed below must be able to be cross-referenced to Table 2.4.a in the EMS P-ROV.

Yes (If Yes, provide details below) No (If No, leave details blank) Complete the following information for ONLY the relevant POI devices, P2PE Applications and/or Non-payment software that are involved in supporting additional encryption implementations.

PTS Approval # (One unique # per row) POI Device Firmware(s) (comma delimited) P2PE Application Listing Reference # Non-Payment Software Details (Name, version#) Describe the additional account data encryption implementations and the involvement of the POI device firmware, P2PE Application, and/or non-payment software as detailed above. Where there is more than one implementation, clearly describe each implementation along with the applicable entity (e.g., acquirer / solution provider) managing it.

Modified p. 23 → 17

Mark Yes or No, as applicable to the assessment type and the overall findings, and mark N/A for all other assessment types.

Note: This table must correlate correctly with Table 2.1 for the assessment type. Refer to the “P2PE Applicability of Requirements” in the P2PE Program Guide. Mark Yes or No, as applicable to the assessment type and the overall findings, and mark N/A for all other assessment types.

Modified p. 23 → 17

~~Type of P2PE Assessment Compliant Comments (optional)~~ Solution Provider (or MMS as a Solution Provider) Yes No N/A ~~Encryption~~ Management Component Provider ~~(EMCP)~~ Yes No N/A ~~POI Deployment Component Provider (PDCP) Yes No N/A POI Management Component Provider (PMCP) Yes No N/A~~

Solution Provider (or MMS as a Solution Provider) Yes No N/A Decryption Management Component Provider (DMCP) Yes No N/A

Modified p. 24 → 18

3. Details and Scope of P2PE Assessment INSTRUCTIONS FOR SECTION 3 Solution Assessments: Complete the entirety of section 3 here as it pertains to the scope of ~~Encryption~~ Management Services of the Solution assessment. It is not necessary to duplicate information between this section here and section 3 in the Solution P-ROV. However, while there may be overlap in section 3 between the two P-ROVs, this section here must be completed and satisfied in its entirety within the scope of …

3. Details and Scope of P2PE Assessment INSTRUCTIONS FOR SECTION 3 Solution Assessments: Complete the entirety of section 3 here as it pertains to the scope of Decryption Management Services of the Solution assessment. It is not necessary to duplicate information between this section here and section 3 in the Solution P-ROV. However, while there may be overlap in section 3 between the two P-ROVs, this section here must be completed and satisfied in its entirety within the scope of …

Modified p. 24 → 18

~~EMS~~ Component Assessments: Complete the entirety of Section 3.

DMS Component Assessments: Complete the entirety of Section 3.

Modified p. 24 → 18

• The methods or processes used to identify all elements in scope of the P2PE assessment:

The methods or processes used to identify all elements in scope of the P2PE assessment:

Modified p. 24 → 18

• How the scope of the assessment was confirmed to be accurate and to cover all components and facilities for the ~~Encryption~~ Management Services:

How the scope of the assessment was confirmed to be accurate and to cover all components and facilities for the Decryption Management Services:

Modified p. 25 → 19

Locations of critical facilities Location of systems performing ~~encryption~~ management functions Other necessary components, as applicable to the ~~Encryption~~ Management Services Provide any additional information below that is not adequately captured within the diagram(s). Otherwise, check No Additional Details. No Additional Details <Additional Details, as needed> <Insert ~~Encryption~~ Management Services diagram(s) here>

Locations of critical facilities Location of systems performing decryption management functions Other necessary components, as applicable to the Decryption Management Services Provide any additional information below that is not adequately captured within the diagram(s). Otherwise, check No Additional Details. No Additional Details <Additional Details, as needed> <Insert Decryption Management Services diagram(s) here>

Modified p. 26 → 21

Key Generation ~~Key Distribution / Loading / Injection into POI devices Other~~ Key Distribution / Loading / Injection activities Key Storage Key Usage Key Archiving (if applicable) Any other relevant information

Key Generation Key Distribution / Loading / Injection activities Key Storage Key Usage Key Archiving (if applicable) Any other relevant information

Removed p. 27

Solution/Component Provider:

Describe the lab/test environment(s) used for this assessment. When more than one environment is used, be clear which environment you are describing.

Facilities INCLUDED in the scope of this assessment (insert additional rows as necessary) Were any facilities included in the scope of the assessment? Yes (If Yes, document below) No (If No, leave details blank) Description and purpose of facility included in the assessment Address of facility Relevant facilities EXCLUDED from the scope of this assessment (insert additional rows as necessary) Note: Does not apply to merchant locations.

Removed p. 28

Note: If the P2PE Application Implementation Guide consists of more than one document, the brief description below should explain the purpose of each document it includes, e.g., if it is for different POI Device Types, different functions, different uses of the P2PE Application, etc.

P2PE Application Implementation Guide(s) (IG) Reference # (optional use) Document Name (Title of the IG) Version Number Document Date (latest version date) Which P2PE Application(s) is addressed? (must align with Table 2.4.b) All other documentation reviewed for this P2PE Assessment Reference # (optional use) Document Name (including version, if applicable) Document Date (latest version date) Document Purpose (brief summary)

Modified p. 29 → 24

Sample Ref # (optional) PTS and/or FIPS Approval # Sample Size (x of y) Serial Numbers of Tested Devices / Other Identifiers Sampling Rationale

Sample Ref #: (optional) PTS and/or FIPS Approval # Sample Size (x of y) Serial Numbers of Tested Devices / Other Identifiers Sampling Rationale

Modified p. 30 → 25

Key ID: Retain generic ID or use specific IDs from assessment Key Type: E.g., DEK, MFK, BDK, KEK, IEK, PEK, MAC, Public, Private, etc. Algorithm: E.g., TDEA, AES, RSA, DSA, etc. Key Mgmt: E.g., DUKPT, MK/SK, Fixed, One-time use, etc.

Key ID: Retain generic ID or use specific IDs from assessment Key Type: E.g., DEK, MFK, BDK, KEK, IEK, PEK, MAC, Public, Private, etc. Algorithm: E.g., TDEA, AES, RSA, DSA, ECC, etc. Key Mgmt: E.g., DUKPT, MK/SK, Fixed, One-time use, etc.

Removed p. 31

Encryption Management Services

• Summary of Findings Reference Appendix I: P2PE Applicability of Requirements in the latest P2PE v3.x Program Guide.

EMCP Encryption Management Component Provider PDCP POI Deployment Component Provider PMCP POI Management Component Provider SP Solution Provider (or MMS as a Solution Provider) Encryption Management Services: P2PE Validation Requirements Summary of Findings (check one for EVERY row) EMCP PDCP PMCP SP Requirements In Place N/A Not in Place Applies to: 1A Account data must be encrypted in equipment that is resistant to physical and logical compromise.

1A-1 PCI-approved POI devices with SRED are used for transaction acceptance.

1A-2 Applications on POI devices with access to clear-text account data are assessed per P2PE Application P-ROV before being deployed into a P2PE solution.

1B Logically secure POI devices.

1B-1 Solution/component provider ensures that logical access to POI devices deployed at merchant encryption environment(s) is restricted to authorized personnel.

1B-2 Solution/component provider secures any remote access to POI …

Modified p. 31 → 27

NOTE: Entities only meeting a partial set of applicable requirements (where a Validated P2PE Component Provider is not being used to satisfy the remaining applicable requirements) are not eligible for PCI SSC’s Validated P2PE ~~Product~~ listings.

NOTE: Entities only meeting a partial set of applicable requirements (where a Validated P2PE Component Provider is not being used to satisfy the remaining applicable requirements) are not eligible for PCI SSC’s Validated P2PE listings.

Modified p. 31 → 27

Reference Appendix I: P2PE Applicability of Requirements in the latest P2PE v3.x Program Guide.

Decryption Management Services

• Summary of Findings Reference Appendix I: P2PE Applicability of Requirements in the latest P2PE v3.x Program Guide.

Removed p. 32

1B-4 Solution/component provider implements procedures to secure account data when troubleshooting.

1B-5 The P2PE solution/component provides auditable logs of any changes to critical functions of the POI device(s).

1C Use P2PE applications that protect PAN and SAD.

1C-1 Applications are implemented securely, including when using shared resources and when updating applications and application functionality.

1C-2 All applications/software without a business need do not have access to account data.

1D Implement secure application-management processes.

1D-1 Integrity of applications is maintained during installation and updates.

1D-2 Maintain instructional documentation and training programs for the application’s installation, maintenance/upgrades, and use.

Not used in P2PE 1-1 Not used in EMS 1-2

Modified p. 32 → 27

~~1E-1~~ For component providers of ~~encryption-management~~ services, maintain and monitor critical P2PE controls and provide reporting to the responsible solution provider.

4E-1 For component providers of decryption-management services, maintain and monitor critical P2PE controls and provide reporting to the responsible solution provider.

Modified p. 32

1E Component providers ONLY: Report status to solution providers.

5I Component providers ONLY: Report status to solution providers.

Modified p. 33 → 28

Cryptographic keys used for account-data encryption/decryption and related key management are created using processes that ensure it is not possible to predict any key or determine that certain keys are more probable than other keys ~~Applies to: Control Objective 3:~~

Cryptographic keys used for account-data encryption/decryption and related key management are created using processes that ensure it is not possible to predict any key or determine that certain keys are more probable than other keys 5 All keys, key components, and key shares are generated using an approved random or pseudo-random function.

Removed p. 43

NOTE: Within this domain, the term “solution provider” refers to whichever entity is undergoing the P2PE assessment. This may be a solution provider, a component provider, or a merchant as a solution provider (MMS). Refer to Domain 1 in the P2PE Standard for additional details.

1A-1.1 Account data encryption operations must be performed using a POI device approved per the PCI PTS program with SRED (secure reading and exchange of data). The PTS approval listing must match the deployed devices in the following characteristics:

• SRED listed as a function provided 1A-1.1 Account data encryption operations must be performed using a POI device approved per the PCI PTS program with SRED (secure reading and exchange of data). The PTS approval listing must match the deployed devices in the following characteristics:

• SRED listed as a function provided For each POI device type used in the solution, examine the POI device and review the …

Modified p. 43 → 35

• ~~Firmware~~ version number

• Device firmware version number

Modified p. 43 → 35

• ~~Firmware~~ version number

• Device firmware version number

Removed p. 44

1A-1.1.1.a Examine documented procedures and interview personnel to verify that procedures are defined to ensure that SRED capabilities are enabled and active on all POI devices prior to devices being deployed to merchant encryption environments.

Documented procedures reviewed: <Report Findings Here> Personnel interviewed: <Report Findings Here> 1A-1.1.1.b For all POI device types used in the solution, review POI device configurations to verify that all POI device types used in the solution have SRED capabilities enabled and active (that is, the POI devices are operating in “encrypting mode”) prior to devices being deployed to merchant encryption environments.

For all POI device types used in the solution, review POI device configurations to verify that all POI device types used in the solution have SRED capabilities enabled and active (that is, the POI devices are operating in “encrypting mode”) prior to devices being deployed to merchant encryption environments.

<Report Findings Here> 1A-1.2 POI devices must be …

Removed p. 45

1A-1.2.1.a Examine POI configuration and deployment procedures to verify they include either:

• Disabling all capture mechanisms that are not SRED validated, or

• Implementing configurations that prevent all non-SRED validated capture mechanisms from being used for P2PE transactions.

Documented POI configuration and deployment procedures reviewed:

<Report Findings Here> 1A-1.2.1.b Verify that the documented procedures include ensuring that all non-SRED-validated capture mechanisms are disabled or otherwise prevented from being used for P2PE transactions prior to devices being deployed to merchant encryption environments.

Documented procedures reviewed: <Report Findings Here> 1A-1.2.1.c For all POI device types, verify:

• All non-validated capture mechanisms are either disabled or configured to prevent their use for P2PE transactions prior to devices being deployed to merchant encryption environments.

• Disabled capture mechanisms cannot be enabled by the merchant, and/or the configurations that prevent capture mechanisms from being used for P2PE transactions cannot be enabled by the merchant.

Describe the testing methods used to verify that …

Removed p. 46

• Link Layer Protocols

• IP Services 1A-1.3 For all POI device types that implement open protocols, examine device configurations and review the list of approved PTS devices at www.pcisecuritystandards.org, to verify that all POI devices that implement open protocols used in this solution are listed. Confirm each such device has a valid SSC listing number on the PCI SSC website under “Approved PCI PTS Devices” with “OP” listed as a “function provided”.

1A-1.4 Clear-text account data must not be disclosed to any component or device outside of the PCI-approved POI device.

1A-1.4.a Examine documented transaction processes and data flows to verify that clear-text account data is not disclosed to any component or device outside of the PCI-approved POI device.

Documented transaction processes and data flows reviewed:

<Report Findings Here> 1A-1.4.b Using forensic tools and/or other data tracing methods, inspect a sample of transactions to verify that clear-text account data is not disclosed to any …

Removed p. 47

• Version number 1A-2.1.a For applications on the PCI SSC list of Validated P2PE Applications, review the list and compare to applications used in the solution to verify that the applications match the P2PE application listing in the following characteristics:

• Version number Refer to Section 2.3 “Listed P2PE Applications used in the P2PE Solution” in the Summary Overview for this documentation. No further reporting required here.

1A-2.1.b For applications not on the PCI SSC list of Validated P2PE Applications, review the application P-ROV(s) and verify that the applications used in the solution match the application P-ROV in the following characteristics:

• Version number Identify application P-ROV(s) reviewed:

Removed p. 48

• Explicitly included in that application’s listing 1A-2.2.a For applications on the PCI SSC list of Validated P2PE Applications, review the list and verify all POI device types the application is used on are:

• Explicitly included in that application’s listing Refer to Section 2.3 “Listed P2PE Applications used in the P2PE Solution” and Section 2.5 “PTS Devices Supported” in the Summary Overview for this documentation. No further reporting required here.

1A-2.2.b For applications not on the PCI SSC list of Validated P2PE Applications, review the application P-ROV and verify the POI device types the application is used on are:

• Explicitly included in that P-ROV as assessed for that application.

Refer to Section 2.5 “PTS Devices Supported” in the Summary Overview for confirmation per 1A-1.1 of PTS-approval (if this testing procedure is applicable).

Identify application P-ROV(s) reviewed:

Removed p. 49

• Does not use any POI vendor default device passwords 1B-1.1.a Examine documented POI device configuration procedures and documented account privilege assignment rules to verify that merchant logical access to POI devices is restricted as follows:

• Cannot enable disabled device interfaces or disabled data- capture mechanisms

• Does not use the POI vendor’s default passwords Documented procedures reviewed: <Report Findings Here> Describe how documented POI device configuration procedures and documented account privilege assignment rules verified that merchant logical access to POI devices is restricted as follows:

• Cannot view or access SAD.

• Does not use the POI vendor’s default passwords <Report Findings Here>

• Cannot enable disabled device interfaces or disabled data- capture mechanisms

• Does not use the POI vendor’s default passwords <Report Findings Here>

Removed p. 50

• Cannot view or access device configuration settings that could impact the security controls of the device, or allow access to cryptographic keys or clear text PAN and/or SAD Only view transaction-related data

• Cannot view or access device configuration settings that could impact the security controls of the device, or allow access to cryptographic keys or clear text PAN and/or SAD Only view transaction-related data

• Does not use the POI vendor’s default passwords Identify the sample of POI devices used: <Report Findings Here> Describe how logon to the device using an authorized test merchant account verified that merchant-account logical access meets the following:

Removed p. 51

• The solution/component provider must document which payment application(s) facilitates printing of PANs for merchants.

• The P2PE application that facilitates this is confirmed per 1A-2.1 as assessed to P2PE Application P-ROV and on PCI SSC’s list of Validated P2PE Applications.

Note: P2PE Application P-ROV (at 2A-3.1.2) and Solution P-ROV (at 3A-1.3) also include requirements that must be met for any P2PE application and P2PE solution provider, respectively, that facilitates merchant printing of full PAN where there is a legal or regulatory obligation to do so.

1B-1.1.1.a Review solution provider’s documentation about the legal/regulatory obligation that requires merchants to have access to full PANs for receipt printing purposes to verify that the documentation specifies the payment application(s) that facilitate printing of PANs for merchants.

Solution provider’s documented procedures reviewed:

<Report Findings Here> 1B-1.1.1.b Review applications confirmed at 1A-2.1 to verify the application(s) that facilitates printing of full PANs on merchant receipts is on PCI SSC’s …

Removed p. 52

1B-1.2.a Examine documented authorizations to verify:

All personnel with access to devices are documented in a formal list.

• All personnel with access to devices are authorized by management.

• The list of authorized personnel is reviewed at least annually.

Documented authorizations reviewed: <Report Findings Here> 1B-1.2.b For a sample of all POI device types, examine account- access configurations to verify that only personnel documented and authorized in the formal list have access to POI devices.

Identify the sample of POI devices used: <Report Findings Here> Describe how account-access configurations for a sample of all POI device types verified that only personnel documented and authorized in the formal list have access to POI devices:

Removed p. 53

1B-1.2.1a Examine documented access-control policies and procedures to verify that solution provider personnel with logical access to POI devices deployed at merchant encryption environments is assigned according to least privilege and need to know.

Documented access-control policies and procedures reviewed:

<Report Findings Here> 1B-1.2.1.b For a sample of all POI devices and personnel, observe configured accounts and permissions, and interview responsible personnel to verify that the level of logical access granted is according to least privilege and need to know.

Identify the sample of POI devices used: <Report Findings Here> Identify the sample of personnel used: <Report Findings Here> Responsible personnel interviewed: <Report Findings Here> Describe how configured accounts and permissions for the sample of all POI devices and personnel verified that the level of logical access granted is according to least privilege and need to know:

Removed p. 54

Note: This includes personnel authenticating to a terminal management system (TMS) or other similar systems to gain remote access to POI devices 1B-2.1.a Examine documented procedures to verify that either multi-factor or cryptographic authentication must be used for all remote access to POI devices.

Documented procedures reviewed: <Report Findings Here> 1B-2.1.b Observe remote-access mechanisms and controls to verify that either multi-factor or cryptographic authentication is configured for all remote access to POI devices.

Describe how remote-access mechanisms and controls verified that either multi-factor or cryptographic authentication is configured for all remote access to POI devices:

<Report Findings Here> 1B-2.1.c Interview personnel and observe actual remote connection attempts to verify that either multi-factor or cryptographic authentication is used for all remote access to POI devices.

Personnel interviewed: <Report Findings Here> Describe how actual remote connection attempts verified that either multi-factor or cryptographic authentication is configured for all remote access to POI devices:

<Report Findings Here> 1B-2.2 …

Removed p. 55

1B-2.3.a Examine documented POI-configuration procedures and interview personnel to verify that devices must be configured to ensure merchants do not have remote access to the POI devices.

Documented POI-configuration procedures reviewed:

<Report Findings Here> Personnel interviewed: <Report Findings Here> 1B-2.3.b For all devices used in the solution, observe a sample of device configurations to verify that merchants do not have remote access to the POI devices.

Describe how sampled device configurations for all devices used in the solution verified that merchants do not have remote access to the POI devices:

<Report Findings Here> 1B-2.4 Solution provider must implement secure identification and authentication procedures for remote access to POI devices deployed at merchant encryption environments:

1B-2.4.a Examine documentation to verify secure identification and authentication procedures are defined for remote access to POI devices deployed at merchant encryption environments.

Documented identification and authentication procedures reviewed:

Documented identification and authentication procedures reviewed:

<Report Findings Here> 1B-2.5 Solution Provider must maintain individual …

Removed p. 56

1B-2.5.1.a Examine POI device configurations and authentication mechanisms to verify that all logical access to POI devices by solution-provider personnel can be traced to an individual user.

Describe how the POI device configurations and authentication mechanisms examined, verified that all logical access to POI devices by solution-provider personnel can be traced to an individual user.

<Report Findings Here> 1B-2.5.1.b Observe a sample of authorized logical accesses and examine access records/logs to verify that all logical access is traced to an individual user.

Describe how sampled authorized logical accesses and access records/logs verified that all logical access is traced to an individual user.

<Report Findings Here> 1B-2.5.2 Maintaining audit logs of all logical access to POI devices by solution-provider personnel and retaining access logs for at least one year.

1B-2.5.2.a Examine documentation to verify that access records/logs of all logical access to POI devices by solution- provider personnel are required to be retained for at least …

Removed p. 57

Note: A POI system build includes at least the following information:

• Model name and number

• Firmware version number(s)

• P2PE Payment Applications

• Non-payment Software 1B-3.2.a Examine documented procedures to verify they include:

• Procedures for maintaining an up-to-date inventory of POI device system builds

• Procedures for confirming all builds at least annually and upon any changes to the build Documented procedures reviewed: <Report Findings Here> 1B-3.2.b Review documented inventory of devices, and examine the inventory of system builds to verify:

• The inventory includes all POI device system builds.

• The inventory includes all POI device system builds.

• The inventory of POI device system builds is up-to-date.

• The inventory of POI device system builds is up-to-date.

Describe how the documented inventory of devices and inventory of system builds verified that:

Removed p. 58

Note: A “critical software security update” is one that addresses an imminent risk to account data, either directly or indirectly.

Note: These security patches can be deployed via “push” from the solution provider or vendor, or via “pull” from the POI device or merchant. In all cases, the solution provider is ultimately responsible to ensure security patches are installed in a timely manner.

• Aligns with 2C-1.2 1B-3.3.a Examine documented procedures to verify they include defined procedures for deploying critical software security updates to POI devices in the field within 30 days of receipt from device or application vendors.

Documented procedures reviewed: <Report Findings Here> 1B-3.3.b Examine security update deployment records and device logs, and interview responsible solution provider personnel and to verify that critical security updates are deployed to devices and applications in the field within 30 days of receipt from device and application vendors.

Responsible solution provider personnel interviewed:

<Report Findings Here> Describe …

Modified p. 58 → 37

Responsible personnel interviewed: <Report Findings Here> ~~Describe how the processes for delivering updates verified that updates are delivered in a secure manner with a known chain-of-trust and following guidance from the device or application vendor:~~

Responsible personnel interviewed: <Report Findings Here> Solution-provider documentation reviewed: <Report Findings Here>

Removed p. 59

1B-4.1.a Examine the Solution/Component provider’s procedures for troubleshooting customer problems and verify the procedures include:

• PAN and/or SAD is never output to merchant environments

• Collection of PAN and/or SAD only when needed to solve a specific problem

• Storage of such data in a specific, known location with limited access

• Collection of only a limited amount of data needed to solve a specific problem

• Encryption of PAN and/or SAD while stored

• Secure deletion of such data immediately after use Documented Solution/Component provider’s procedures for troubleshooting customer problems reviewed:

<Report Findings Here> 1B-4.1.b For a sample of recent troubleshooting requests, observe data collection and storage locations, and interview responsible personnel to verify the procedures identified at 1B- 4.1.a were followed.

Identify the sample of recent troubleshooting requests:

<Report Findings Here> Responsible personnel interviewed: <Report Findings Here> Describe how the data collection and storage locations for the sample of recent troubleshooting requests verified that procedures identified …

Removed p. 60

Note: Critical functions include application and firmware updates as well as changes to security-sensitive configuration options, such as whitelists or debug modes.

1B-5.1.a Examine device and/or system configurations to verify that any changes to the critical functions of the POI devices are logged, including:

Removed p. 60

• Changes to any security-sensitive configuration options within the device (including whitelists and debug modes) Describe how the device and/or system configurations observed verified that any changes to the critical functions of the POI devices are logged, including:

• Changes to any security-sensitive configuration options within the device (including whitelists and debug modes) <Report Findings Here> 1B-5.1.b Observe authorized personnel perform authorized changes on POI devices, as follows, and examine log files to verify that all such activities result in a correlating log file:

• Changes to any security-sensitive configuration options within the device (including whitelists and debug modes) Describe how observation of authorized personnel performing authorized changes on POI devices, as follows, and examination of log files verified that all such activities result in a correlating log file:

• Changes to any security-sensitive configuration options within the device (including whitelists and debug modes) <Report Findings Here> 1B-5.1.c Examine documented procedures and sample …

Modified p. 60 → 40

Documented procedures reviewed:

Documented policies and procedures reviewed:

Removed p. 61

• Implementing whitelisting functionality in accordance with the device vendor's security guidance or the application’s Implementation Guide

• Confirmation that it was reviewed prior to release to only output non-PCI payment brand account/card data 1C-1.1.a Review documented policies and procedures and interview personnel to verify that processes for implementing any whitelisting functionality include:

• Following the device vendor's security guidance or the application’s Implementation Guide

Modified p. 61 → 44

• Cryptographic signing (or similar) prior to installation ~~on the POI device~~ by authorized personnel using dual control

• Cryptographic signing (or similar) prior to installation by authorized personnel using dual control

Modified p. 61 → 44

• Cryptographic authentication by the ~~POI device’s firmware~~

• Cryptographic authentication by the HSM

Modified p. 61 → 44

• ~~The identity of the authorized person who~~ approved the new installation or updated functionality prior to release

• Who approved the new installation or updated functionality prior to release

Modified p. 61 → 45

• Cryptographic signing (or similar) prior to installation ~~on the POI device~~ by authorized personnel using dual ~~control~~

• Cryptographic signing (or similar) prior to installation by authorized personnel using dual control.

Modified p. 61 → 45

• Cryptographic authentication ~~of whitelisting functionality~~ by the ~~POI device’s firmware~~

• Cryptographic authentication by the HSM

Modified p. 61 → 45

• Review of whitelist functionality to confirm it only outputs non-PCI payment brand account/card ~~data~~

• Review of whitelist functionality to confirm it only outputs non-PCI payment brand account/card data.

Modified p. 61 → 45

• Documentation for all new installations ~~and~~ updates to whitelist functionality that includes the following:

• Documentation for all new installations or updates to whitelist functionality that includes the following:

Modified p. 61 → 45

• Description and justification for the functionality

- Description and justification for the functionality

Modified p. 61 → 45

~~• The identity of the authorized person who~~ approved the new installation or updated functionality prior to release - Confirmation that it was reviewed prior to release to only output ~~non-PCI payment brand account/card data Personnel interviewed: <Report Findings Here> Documented procedures reviewed:~~

- Who approved the new installation or updated functionality prior to release - Confirmation that it was reviewed prior to release to only output non-

Removed p. 62

1C-1.1.1.a Observe application and device configurations and interview personnel to verify that whitelisting functionality only allows for the output of non-PCI payment brand accounts/cards, by following guidance in either the device vendor's security guidance or the application’s Implementation Guide.

Describe how the application and device configurations observed verified that whitelisting functionality only allows for the output of non-PCI payment brand accounts/cards.

<Report Findings Here> Personnel interviewed <Report Findings Here> 1C-1.1.1.b For all device types with whitelisting functionality, perform test transactions to verify output of clear text account data is only enabled for non-PCI payment brand account/card data.

Describe how the test transactions performed, verified that any output of clear text account data is only enabled for non-PCI payment brand account/card data.

• Cryptographically authenticated by the POI device’s firmware in accordance with the device vendor's security guidance or the application’s Implementation Guide.

• Cryptographically authenticated by the POI device firmware, in accordance with the device …

Modified p. 62 → 46

<Report Findings Here> ~~1C-1.1.2~~ Any new installations of, or ~~updates, to~~ whitelisting functionality must be:

<Report Findings Here> 4B-1.9.2 Any new installations of, or updates to, whitelisting functionality implemented in the decryption environment that transmits data to the encryption environment must be:

Modified p. 62 → 46

• Cryptographically signed (or similar) prior to installation ~~on the POI device~~ only by authorized personnel using dual ~~control.~~

• Cryptographically signed (or similar) prior to installation only by authorized personnel using dual control

Modified p. 62 → 46

~~1C-1.1.2.a~~ Observe the process for new installations ~~of,~~ or updates ~~to,~~ whitelisting functionality and interview personnel to verify ~~they~~ are performed as follows:

• Cryptographically authenticated by the HSM 4B-1.9.2 Observe the process for new installations or updates to whitelisting functionality and interview personnel to verify that additions or updates to whitelisting functionality implemented in the decryption environment that transmits data to the encryption environment are performed as follows:

Modified p. 62 → 46

• Cryptographically signed (or similar) prior to installation ~~on the POI device~~ only by authorized personnel using dual control

• Cryptographically signed (or similar) prior to installation only by authorized personnel using dual control

Removed p. 63

• Description and justification for the functionality.

• The identity of the person who approved the new installation or update prior to release

Modified p. 63 → 47

• ~~The identity of the person who~~ approved the new installation or update prior to release

• Who approved the new installation or update prior to release

Modified p. 63 → 47

• Confirmation that it was reviewed prior to release to only output non-PCI payment account/card ~~data 1C-1.1.3.a Review records of both new installations and updated whitelisting functionality, and confirm they include the following:~~

• Confirmation that it was reviewed prior to release to only output non-PCI payment account/card data.

Modified p. 63 → 47

• ~~Coverage for both~~ new installations and updates to ~~such~~ functionality

• Both new installations and updates to whitelisting functionality are documented.

Modified p. 63 → 47

• ~~Confirmation~~ that it was reviewed prior to release to only output non-PCI payment account/card ~~data Identify sampled records of updated whitelisting functionality:~~

• The documentation includes confirmation that it was reviewed prior to release to only output non-PCI payment account/card data.

Removed p. 64

• Does not have any logical interfaces (e.g., application programming interfaces (APIs)) that allow for the storing, processing, or transmitting of clear text account data

• Is cryptographically authenticated by the POI device’s firmware

• Requires an SCD with dual control for the application-signing process PDCP PMCP EMCP 1C-2.1 Review the solution provider’s documented processes and interview responsible personnel to confirm the processes include:

• Review of the non-payment software vendor’s documentation to determine all logical interfaces used by the non-payment software do not allow for the storing, processing, or transmitting of clear text account data

• Documenting how the Solution/Component provider confirmed that the non-payment software has no logical interfaces that allow for storing, processing, or transmitting clear text account data

• Authentication of the non-payment software by the POI device’s firmware

• Requiring an SCD with dual control to sign the non-payment software

• Following this process both for new installations and for updates Responsible …

Modified p. 64 → 59

~~Solution/Component provider’s~~ documentation reviewed:

Vendor/solution provider documentation reviewed:

Removed p. 65

PDCP PMCP EMCP 1C-2.1.2 Interview Solution/Component-provider personnel and observe the process for new installations or updates of non- payment software to verify that it is authenticated to the POI device using an approved security mechanism of the POI device.

Describe how the process for new application installations or application updates verified that applications with no need to access clear-text account data are authenticated to the device using an approved security mechanism:

<Report Findings Here> 1C-2.1.3 Requires an SCD with dual control for the application-signing process (i.e., signing non-payment software).

PDCP PMCP EMCP 1C-2.1.3 Interview Solution/Component-provider personnel and observe processes for new installations or updates of non- payment software to confirm that application signing process is performed under dual control using an SCD.

Modified p. 65 → 59

Personnel interviewed: <Report Findings Here> Describe how ~~the process for new application installations or application updates~~ verified that ~~application signing~~ is ~~performed under dual control:~~

Personnel interviewed: <Report Findings Here> Describe how logs/records verified that the Host System performs a self-test when a security-impacting function or operation is modified:

Removed p. 66

• Following vendor guidance in the application’s Implementation Guide.

• Documented approval for all changes by appropriate personnel.

• Documented reason and impact for all changes.

• Functionality testing of all changes on the intended device(s).

• Documented back-out procedures for application installations/updates.

• changed POI device to a PCI-listed P2PE Component requires the Component Provider to undergo an assessment per PCI’s “Delta-Change” process. See the P2PE Program Guide for more information.

Aligns with 2C-2.1 1D-1.1.a Review the Solution/Component provider’s documented processes for implementing changes to applications, and interview Solution/Component-provider personnel, and confirm the following processes are in place:

• Guidance in the Implementation Guide is followed.

• All changes to applications include documented approval by appropriate authorized Solution/Component-provider personnel.

• All changes to applications are documented as to reason and impact of the change.

• Functionality testing of all changes on the intended devices is performed.

• Documentation includes back-out procedures for application installations/updates.

Solution/Component provider personnel interviewed:

Modified p. 66 → 47

• ~~changed application or a~~

• Changes to the applications

Modified p. 66 → 55

<Report Findings Here> ~~Solution/Component provider’s documentation reviewed:~~

Solution provider documentation reviewed: <Report Findings Here>

Removed p. 67

• Documentation includes back-out procedures for application installations/updates.

• All Implementation Guide requirements were followed.

• Approval of the change by appropriate parties is documented.

• The documentation describes functionality testing that was performed.

<Report Findings Here> 1D-1.2 All new installations and updates to applications must be authenticated as follows:

1D-1.2.a Review the Solution/Component provider’s documentation and confirm their documented processes include using the guidance in the application’s Implementation Guide for any application installations and updates.

<Report Findings Here> 1D-1.2.1 All applications must be cryptographically signed (or similar) prior to installation on the POI device only by authorized personnel using dual control.

1D-1.2.1.a Confirm the following through interviews with responsible Solution/Component provider personnel and by observing an installation/update:

• Cryptographic signing processes for applications are followed as specified in the Implementation Guide.

• Cryptographic signing (or similar) is performed prior to installation only by authorized personnel using dual control.

• All new installations and updates to applications are signed prior …

Modified p. 67 → 47

• The documentation includes ~~reason~~ and ~~impact of the change.~~

• The documentation includes description and justification.

Modified p. 67 → 63

~~Solution/Component provider’s~~ documentation ~~reviewed:~~

Solution provider documentation reviewed (including data-flow diagrams):

Modified p. 67 → 73

Identify the ~~sample of records of changes to applications:~~

Identify the tamper-detection mechanisms observed:

Removed p. 68

Documentation reviewed: <Report Findings Here> 1D-1.3.b Interview Solution/Component-provider personnel to confirm that they follow key-management security guidance in accordance with the Implementation Guide.

<Report Findings Here> 1D-2.1 Upon receipt from the application vendor, a current copy of the application vendor’s Implementation Guide must be retained and distributed to any outsourced integrators/resellers used for the P2PE Solution/Component.

Aligns with 2C-3.1.3 1D-2.1 Interview Solution/Component-provider personnel and examine documentation (including a current copy of the Implementation Guide from the application vendor) to confirm the following:

• The Solution/Component provider retains a current copy of the Implementation Guide.

• The Solution/Component provider distributes the Implementation Guide to any outsourced integrators/resellers the Solution/Component provider uses for the P2PE Solution/Component upon obtaining updates from the application vendor.

Documentation reviewed, in addition to the current copy of the Implementation Guide from the application vendor:

<Report Findings Here> Current Application Vendor Implementation Guide(s) reviewed:

Note: This section (1E-1) is ONLY applicable for P2PE component providers …

Modified p. 68 → 47

<Report Findings Here> ~~Current Application Vendor Implementation Guide(s)~~ reviewed:

<Report Findings Here> Records of updated whitelisting functionality reviewed:

Modified p. 68 → 79

Responsible ~~Personnel~~ interviewed:

Responsible personnel interviewed: <Report Findings Here>

Removed p. 69

• Date list of personnel with logical remote access to deployed merchant POI devices was last reviewed/updated Responsible component provider personnel interviewed:

<Report Findings Here> Reports reviewed for this testing procedure:

<Report Findings Here> PDCP PMCP EMCP 1E-1.1.b Observe reports provided to applicable solution providers annually and upon significant changes to the solution, and confirm they include at least the following:

• Types/models of POI devices

• Number of devices deployed and changed since last report

• Date list of personnel with logical remote access to deployed merchant POI devices was last reviewed/updated Reports reviewed for this testing procedure:

Modified p. 69 → 88

• Types/models of ~~POI devices~~

• Types/models of HSMs

Modified p. 69 → 88

• Types/models of ~~POI devices~~

• Types/models of HSMs

Modified p. 69 → 88

• Number of ~~devices~~ deployed and any change in numbers since last report

• Number of HSMs deployed and any change in numbers since last report

Modified p. 69 → 88

• ~~Date list~~ of ~~personnel with logical remote access to deployed merchant POI devices was last reviewed/updated PDCP PMCP EMCP 1E-1.1.a~~ Review component provider’s documented procedures for providing required reporting to applicable solution providers, and interview responsible component-provider personnel, and to confirm that the following processes are documented and implemented:

• Details of any suspicious activity that occurred, per 4C-1.2 4E-1.1.a Review component provider’s documented procedures for providing required reporting to applicable solution providers, and interview responsible component-provider personnel, and to confirm that the following processes are documented and implemented:

Modified p. 69 → 88

• Number of ~~devices~~ deployed and ~~change~~ since last report

• Number of HSMs deployed and description of any changes since last report

Removed p. 70

• Addition and/or removal of POI device types

• Addition and/or removal of POI device types

Removed p. 70

• Adding, changing, and/or removing P2PE non-payment software on POI devices (without access to clear-text account data), including description of change

• Adding, changing, and/or removing P2PE non-payment software on POI devices (without access to clear-text account data), including description of change

• Updated list of POI devices, P2PE applications, and/or P2PE non-payment software Note that adding, changing, or removing POI device types, P2PE applications, and/or P2PE non-payment software may require adherence to PCI SSC’s process for making changes. Please refer to the P2PE Program Guide for details about obligations when adding, changing, or removing elements of a P2PE solution.

PDCP PMCP EMCP 1E-1.2.a Review component provider’s documented procedures and interview responsible component-provider personnel, and confirm that processes include notifying the solution provider upon occurrence of the following:

• Updated list of POI devices, P2PE applications, and/or P2PE non-payment software Documented component provider’s procedures reviewed:

Removed p. 71

• Adding, changing, and/or removing P2PE non-payment software (without access to clear-text account data), including description of change

• Updated list of POI devices, P2PE applications, and/or P2PE non-payment software Reports reviewed for this testing procedure:

Modified p. 71 → 89

• Addition and/or removal of ~~POI device types~~

• Addition and/or removal of HSM types.

Modified p. 72 → 90

~~• PCI approved~~ Note: HSM approval listings must be current⎯HSMs must have a non-expired PCI PTS HSM approval or a non-expired FIPS 140-2 or FIPS 140-3 certificate (i.e., the FIPS 140 HSM certificates must not be listed as historical or revoked).

Note: HSM approval listings must be current⎯HSMs must have a non-expired PCI PTS HSM approval or a non-expired FIPS 140-2 or FIPS 140-3 certificate (i.e., the FIPS 140 HSM certificates must not be listed as historical or revoked).

Modified p. 72 → 90

~~1-3.a~~ For all HSM brands/models used, examine approval documentation (e.g., FIPS certification or PTS ~~approval),~~ and examine the list of approved devices to verify that all HSMs are either:

1-3 For all HSM brands/models used, examine approval documentation (e.g., FIPS certification or PTS approval) and examine the list of approved devices to verify that all HSMs are either:

Modified p. 72 → 90

Approval documentation ~~examined:~~

Approval documentation reviewed:

Modified p. 73 → 91

• For PCI-approved HSMs, any applications, including application version number, resident within the device which were included in the PTS assessment 1-4.a For all PCI-approved HSMs used, examine HSM devices and examine the PCI SSC list of Approved PCI PTS Devices to verify that all of the following device characteristics match the PCI PTS listing for each HSM:

• The PCI PTS HSM or FIPS 140 Approval Number For PCI-approved HSMs, any applications, including application version number, resident within the device which were included in the PTS assessment 1-4.a For all PCI-approved HSMs used, examine HSM devices and examine the PCI SSC list of Approved PCI PTS Devices to verify that all of the following device characteristics match the PCI PTS listing for each HSM:

Modified p. 73 → 91

• Any applications, including application version number, resident within the device which were included in the PTS assessment ~~For each PCI-approved HSM used, describe how~~ the ~~observed HSM device configurations verified that all of the device characteristics at 6A-1.4.a match the PTS listing:~~

• Any applications, including application version number, resident within the device which were included in the PTS assessment Review the PCI approval listing(s) for any implementation-specific notes and if present, verify they are accounted for.

Modified p. 73 → 92

• The FIPS 140 Approval Number For each FIPS-approved HSM ~~used,~~ describe how the ~~observed~~ HSM device configurations verified that all of the device characteristics at ~~6A-1.4.b~~ match the FIPS140-2 Level 3 (or higher) approval listing:

• Firmware version number The FIPS 140 Approval Number For each FIPS-approved HSM used in the solution, describe how the HSM device configurations observed verified that all of the device characteristics at 1-4.b match the FIPS140-2 Level 3 (or higher) approval listing:

Removed p. 74

• approved HSM or POI device

Modified p. 74 → 93

• An approved key-generation function of a PCI

•approved HSM or POI device

• An approved key-generation function of a PCI-approved HSM or POI device

Modified p. 74 → 93

• An approved key-generation function of a ~~PCI~~

• An approved key-generation function of a PCI-approved HSM or POI device

Modified p. 74 → 93

• An SCD that has an approved random number generator that has been certified by an independent qualified laboratory according to NIST SP ~~800-22 Documented POI configuration and deployment procedures examined:~~

• An SCD that has an approved random number generator that has been certified by an independent qualified laboratory according to NIST SP 800-22.

Removed p. 75

• approved HSM or POI device

Modified p. 75 → 93

• An approved key-generation function of a PCI

• An approved key-generation function of a PCI •approved HSM or POI device

Modified p. 75 → 93

• An SCD that has an approved random number generator that has been certified by an independent qualified laboratory according to NIST SP 800-22 Certification ~~Letters/technical~~ documentation ~~examined:~~

• An SCD that has an approved random number generator that has been certified by an independent qualified laboratory according to NIST SP 800-22 Certification letters/technical documentation reviewed:

Modified p. 75 → 94

~~Identify~~ the ~~P2PE Assessor who confirms that~~ devices used for ~~key-generation~~ are ~~those~~ noted above, including validation of ~~firmware used.~~

Describe how the reviewed devices used for key generation verified that devices are as noted above, including validation of the firmware:

Modified p. 76 → 94

6-1.1 Any clear-text output of the key-generation process must be managed under dual control. Only the assigned custodian can have direct access to the ~~clear text~~ of any key component/share. Each custodian’s access to clear-text output is limited to the individual component(s)/share(s) assigned to that custodian, and not to the entire key.

6-1.1 Any clear-text output of the key-generation process must be managed under dual control. Only the assigned custodian can have direct access to the clear-text of any key component/share. Each custodian’s access to clear-text output is limited to the individual component(s)/share(s) assigned to that custodian, and not the entire key.

Modified p. 76 → 94

• Each custodian’s access to clear-text output is limited to the individual component(s)/share(s) assigned to that custodian, and not the entire ~~key Documented procedures examined: <Report Findings Here> 6-1.1.b Observe key-generation process demonstration and interview responsible personnel to verify:~~

• Each custodian’s access to clear-text output is limited to the individual component(s)/share(s) assigned to that custodian, and not the entire key.

Modified p. 76 → 95

~~• Each custodian’s access to clear-text output is limited to the individual component(s)/share(s) assigned to that custodian and not the entire key Responsible personnel interviewed:~~ <Report Findings Here> Describe how the ~~key generation~~ processes observed verified that any clear-text output of the key-generation process is overseen by only the assigned key custodian(s) for that component/share and is limited to those individual components and not the entire key:

<Report Findings Here> Describe how the key-generations processes observed verified that any clear-text output of the key-generation process is overseen by only the assigned key custodian(s) for that component/share and is limited to those individual components and not the entire key:

Removed p. 77

Describe how the end-to-end process observed verified that there is no point in the process where a single person has the ability to determine, obtain, or ascertain any part of a clear-text key or all the components for a key:

Modified p. 77 → 95

6-1.2.a Examine documented procedures for all ~~key- generation~~ methods and observe demonstrations of the key-generation process from end-to-end to verify there is no point in the process where a single person has the ability to determine, obtain, or ascertain any part of a clear-text key or all the components for a key.

6-1.2.a Examine documented procedures for all key-generation methods and observe demonstrations of the key-generation process from end-to-end to verify there is no point in the process where a single person has the ability to determine, obtain, or ascertain any part of a clear-text key or all the components for a key.

Modified p. 77 → 95

Key-generation logs ~~reviewed:~~

Key-generation logs examined: <Report Findings Here>

Modified p. 78 → 96

~~6-1.3.a~~ Examine documented procedures for all ~~key- generation~~ methods. Verify procedures require that:

6-1.3 Examine documented procedures for all key-generation methods. Verify procedures require that:

Modified p. 79 → 97

6-1.4.a Examine documented procedures for all ~~key- generation~~ methods to verify they include inspections of the key-generation equipment for evidence of tampering prior to use. Verify procedures include a validation step to ensure no unauthorized mechanism exists that might disclose a clear-text key or key component (e.g., a tapping device).

6-1.4.a Examine documented procedures for all key-generation methods to verify they include inspections of the key-generation equipment for evidence of tampering prior to use. Verify procedures include a validation step to ensure no unauthorized mechanism exists that might disclose a clear-text key or key component (e.g., a tapping device).

Modified p. 80 → 97

Documentation ~~examined:~~ <Report Findings Here> 6-1.5.b During the demonstration for 6-1.1.b, observe the physical security controls (e.g., partitions or barriers) used, and validate that they ensure the key-generation process cannot be observed or accessed by unauthorized personnel directory or via camera monitoring (including those on cellular devices).

Documentation reviewed: <Report Findings Here> 6-1.5.b During the demonstration for 6-1.1.b, observe the physical security controls (e.g., partitions or barriers) used, and validate that they ensure the key-generation process cannot be observed or accessed by unauthorized personnel directory or via camera monitoring (including those on cellular devices).

Modified p. 80 → 97

Describe how the physical security controls observed verified that ~~key-component/key- generation~~ process cannot be observed or accessed by unauthorized personnel:

Describe how the physical security controls observed verified that the key- component/key-generation process cannot be observed or accessed by unauthorized personnel:

Removed p. 81

Note: See Requirement 5 and Requirement 13.

Modified p. 81 → 98

Additionally, this requirement excludes from its scope computers used only for administration of SCDs, or ~~key-generation~~ devices that do not have the ability to access clear-text cryptographic keys or components.

Additionally, this requirement excludes from its scope computers used only for administration of SCDs, or key- generation devices that do not have the ability to access clear-text cryptographic keys or components.

Modified p. 81 → 98

6-2.a Examine documented procedures to verify that multi-purpose computing systems are not permitted for key generation where any ~~clear-text~~ secret or private key or component thereof appears in memory outside the tamper-protected boundary of an SCD.

SCDs used for key generation must meet Requirement 5-1. Note: See Requirement 5 and Requirement 13 6-2.a Examine documented procedures to verify that multi-purpose computing systems are not permitted for key generation where any clear- text secret or private key or component thereof appears in memory outside the tamper-protected boundary of an SCD.

Modified p. 81 → 98

~~Documented procedures examined:~~ <Report Findings Here> 6-2.b Observe the generation process and examine documentation for each type of key to verify that ~~multi- purpose~~ computing systems are not used for key generation where any clear-text secret or private key or component thereof appears in memory outside the tamper-protected boundary of an SCD except where Requirement 5 and Requirement 13 are met.

<Report Findings Here> 6-2.b Observe the generation process and examine documentation for each type of key to verify that multi-purpose computing systems are not used for key generation where any clear-text secret or private key or component thereof appears in memory outside the tamper-protected boundary of an SCD except where Requirement 5 and Requirement 13 are met.

Modified p. 81 → 98

<Report Findings Here> Describe how the generation process observed for each type of key verified that ~~multi-purpose~~ computing systems are not used for key generation where any clear-text secret or private key or component thereof appears in unprotected memory:

<Report Findings Here> Describe how the generation process observed for each type of key verified that multi- purpose computing systems are not used for key generation where any clear-text secret or private key or component thereof appears in unprotected memory:

Modified p. 82 → 99

• Clear keying material is injected directly from a secure port on the SCD to the target (e.g., a POI ~~device)~~ or

• Clear keying material is injected directly from a secure port on the SCD to the target (e.g., a POI device), or

Modified p. 82 → 99

• Where clear keying material passes through ~~unprotected~~ memory of the PC, the PC requirements of Requirement 13 are met.

• Where clear keying material passes through memory of the PC, the PC requirements of Requirement 13 are met.

Modified p. 82 → 99

• Tampering can be ~~visually~~ detected.

• Tampering can be detected.

Modified p. 82 → 99

Documented procedures for printed key components ~~examined:~~

Documented procedures for printed key components reviewed:

Modified p. 83 → 100

Describe how the blind mailers or other sealed containers used for key components observed verified that tampering can be ~~visually~~ detected:

Describe how the blind mailers or other sealed containers used for key components observed verified that tampering can be detected:

Modified p. 83 → 100

<Report Findings Here> 6-3.c Observe processes for printing key components to verify ~~that :~~

<Report Findings Here> 6-3.c Observe processes for printing key components to verify that:

Modified p. 83 → 100

• Key components are printed within blind mailers or sealed in ~~tamper-evident~~ and authenticable packaging (that is able to be authenticated) immediately after printing, such that no one but the authorized custodian ever has physical access to the output;

• Key components are printed within blind mailers or sealed in tamper- evident and authenticable packaging (that is able to be authenticated) immediately after printing, such that no one but the authorized custodian ever has physical access to the output;

Modified p. 85 → 102

• Anti-pass-back <Report Findings Here> 6-3.3.b Examine alarm mechanisms and interview ~~alarm- response~~ personnel to verify that the badge-control system supports generation of an alarm when one person remains alone in the secure room for more than 30 seconds.

• Anti-pass-back <Report Findings Here> 6-3.3.b Examine alarm mechanisms and interview alarm-response personnel to verify that the badge-control system supports generation of an alarm when one person remains alone in the secure room for more than 30 seconds.

Modified p. 86 → 103

<Report Findings Here> 6-3.6.b Inspect access-control configurations for the CCTV server/storage secure location and the ~~key- injection~~ secure room to identify all personnel who have access to each area. Compare access lists to verify that personnel with access to the secure room do not have access to the CCTV server/storage secure location.

<Report Findings Here> 6-3.6.b Inspect access-control configurations for the CCTV server/storage secure location and the key-injection secure room to identify all personnel who have access to each area. Compare access lists to verify that personnel with access to the secure room do not have access to the CCTV server/storage secure location.

Modified p. 86 → 103

Identify the P2PE Assessor who confirms all personnel who have access to the ~~access-control~~ configurations for the CCTV server/storage secure location and the key-injection secure room do not have access to the CCTV server/storage secure location.

Identify the P2PE Assessor who confirms all personnel who have access to the access- control configurations for the CCTV server/storage secure location and the key-injection secure room do not have access to the CCTV server/storage secure location.

Modified p. 89 → 105

Examples of where such key residue may exist include (but are not limited to):

Examples of where such key residue may exist include (but are not limited to): • Printing material, including ribbons and paper waste

Modified p. 89 → 105

~~• Other types of displaying or recording (e.g., printer memory, printer drum)~~ 6-4.a Examine documented procedures to identify all locations where key residue may exist. Verify procedures ensure the following:

6-4.a Examine documented procedures to identify all locations where key residue may exist. Verify procedures ensure the following:

Modified p. 89 → 105

Examine logs of past destructions and deletions to verify that procedures are followed.

• Examine logs of past destructions and deletions to verify that procedures are followed.

Modified p. 89 → 105

Documented procedures ~~examined: <Report Findings Here>~~

Documented procedures reviewed:

Removed p. 90

• deleted immediately after generation.

• deleted (zeroized) from the generation and/or injection device immediately after the transfer to the device(s) that will use the key.

<Report Findings Here> Identify the P2PE Assessor who confirms that the method of destruction is consistent with Requirement 24.

Modified p. 90 → 106

• Any residue that may contain clear-text keys or components is destroyed or securely

• Any residue that may contain clear-text keys or components is destroyed or securely deleted immediately after generation.

Modified p. 90 → 106

• If a key is generated in a separate device before being exported into the end-use device, confirm that the key and all related critical security parameters (e.g., secret seeds) are

• If a key is generated in a separate device before being exported into the end-use device, confirm that the key and all related critical security parameters (e.g., secret seeds) are deleted (zeroized) from the generation and/or injection device immediately after the transfer to the device(s) that will use the key.

Modified p. 90 → 106

Describe how the destruction process of the identified key residue observed verified that any residue that may contain clear-text keys or components is destroyed or securely deleted immediately after ~~generation:~~

Describe how the destruction process of the identified key residue observed verified that any residue that may contain clear-text keys or components is destroyed or securely deleted immediately after generation and that the method of destruction is consistent with Requirement 24:

Modified p. 91 → 107

6-5.a Examine documented procedures for ~~asymmetric- key~~ generation to confirm that procedures are defined to ensure that asymmetric-key pairs are either:

6-5.a Examine documented procedures for asymmetric-key generation to confirm that procedures are defined to ensure that asymmetric-key pairs are either:

Modified p. 91 → 107

Documented procedures for asymmetric-key generation ~~examined:~~

Documented procedures for asymmetric-key generation reviewed:

Modified p. 92 → 108

• Conveying clear-text private key shares or secret key components/shares without containing them within ~~tamper-evident~~ and authenticable packaging

• Conveying clear-text private key shares or secret key components/shares without containing them within tamper- evident and authenticable packaging

Modified p. 92 → 108

• Writing key or component values in procedure manual Documented policy and procedures ~~examined:~~

• Writing key or component values in procedure manual Documented policy and procedures reviewed:

Modified p. 93 → 109

• Conveying clear-text private or secret key components without containing them within ~~tamper- evident,~~ authenticable packaging

• Conveying clear-text private or secret key components without containing them within tamper-evident, authenticable packaging

Modified p. 94 → 110

~~Responsible personnel interviewed:~~ <Report Findings Here> 7-1.c Observe key-generation ceremonies, whether actual or for demonstration purposes, and verify that the documented procedures are demonstrably in use.

<Report Findings Here> 7-1.c Observe key-generation ceremonies, whether actual or for demonstration purposes, and verify that the documented procedures are demonstrably in use.

Modified p. 95 → 110

7-2.a Examine documented key-generation procedures to verify that ~~key-generation~~ events for higher-level keys (e.g., KEKs shared with other organizations or otherwise manually loaded as components and MFKs and BDKs) are logged.

7-2.a Examine documented key-generation procedures to verify that key- generation events for higher-level keys (e.g., KEKs shared with other organizations or otherwise manually loaded as components and MFKs and BDKs) are logged.

Modified p. 95 → 110

<Report Findings Here> 7-2.c Examine logs of key generation to verify that exchanges of ~~higher-level~~ keys with other organizations have been recorded and that all required elements were captured.

<Report Findings Here> 7-2.c Examine logs of key generation to verify that exchanges of higher- level keys with other organizations have been recorded and that all required elements were captured.

Modified p. 96 → 111

Where key components are transmitted in ~~clear text~~ using pre-numbered, tamper-evident, authenticable mailers:

• Where key components are transmitted in clear-text using pre-numbered, tamper-evident, authenticable mailers:

Modified p. 96 → 111

Components/shares must be conveyed using at least two separate communication channels, such as different courier services. Components/shares sufficient to form the key must not be conveyed using the same communication channel.

- Components/shares must be conveyed using at least two separate communication channels, such as different courier services. Components/shares sufficient to form the key must not be conveyed using the same communication channel. - Details of the serial number of the package are conveyed separately from the package itself. - Documented procedures exist and are followed to require that the serial numbers be verified prior to the usage of the keying material.

Modified p. 96 → 111

Where SCDs are used for conveying components/shares, the mechanisms or data (e.g., PIN) to obtain the key component/share from the SCD must be conveyed using a separate communication from the SCD channel, or it must be conveyed in the same manner as a paper component. SCDs must be inspected for signs of tampering.

• Where SCDs are used for conveying components/shares, the mechanisms or data (e.g., PIN) to obtain the key component/share from the SCD must be conveyed using a separate communication from the SCD channel, or it must be conveyed in the same manner as a paper component. SCDs must be inspected for signs of tampering.

Modified p. 96 → 111

Where an SCD (i.e., HSM or KLD) is conveyed with pre-loaded secret and/or private keys, the SCD must require dual control mechanisms to become operational. Those mechanisms must not be conveyed using the same communication channel as the SCD. SCDs must be inspected for signs of tampering.

• Where an SCD (i.e., HSM or KLD) is conveyed with pre-loaded secret and/or private keys, the SCD must require dual control mechanisms to become operational. Those mechanisms must not be conveyed using the same communication channel as the SCD. SCDs must be inspected for signs of tampering.

Removed p. 97

• They define how the details of the package serial number are to be transmitted.

• There is a requirement that the package serial number is to be sent separately from the package itself.

• Each component is to be sent to/from only the custodian(s) authorized for the component.

Modified p. 97 → 112

Examine documented procedures for sending components in ~~tamper-evident,~~ authenticable packaging to verify ~~that~~

• Examine documented procedures for sending components in tamper- evident, authenticable packaging to verify that:

Modified p. 97 → 112

• At least two communication channels are used to send the components of a given key (not just separation by sending on different days).

- At least two communication channels are used to send the components of a given key (not just separation by sending on different days). - Prior to the use of the components, the serial numbers are to be confirmed.

Modified p. 97 → 112

• ~~Prior to the use of the components, the serial numbers are to be confirmed.~~ Confirm through observation, interview, and inspection of the records of past key transfers that the process used to transport clear-text key ~~components using pre-~~ Documented procedures reviewed:

• Confirm through observation, interview, and inspection of the records of past key transfers that the process used to transport clear-text key Documented procedures reviewed:

Modified p. 97 → 112

~~<Report Findings Here> Responsible personnel interviewed:~~ <Report Findings Here> Describe how the observed method to transport clear-text key components using tamper- evident mailers verified ~~that details of the serial number of the package are transmitted separately from the package itself:~~

<Report Findings Here> Describe how the observed method to transport clear-text key components using tamper- evident mailers verified that:

Modified p. 98 → 112

• The package serial number was transmitted as ~~prescribed.~~

• The package serial number was transmitted as prescribed

Modified p. 98 → 112

• Each component was sent to/from only the custodian(s) authorized for the ~~component.~~

• Each component was sent to/from only the custodian(s) authorized for the component

Modified p. 99 → 114

• Examine documented procedures to verify that the SCD requires ~~dual-control~~ mechanisms to become operational.

• Examine documented procedures to verify that the SCD requires dual- control mechanisms to become operational.

Modified p. 100 → 115

Note: An m-of-n scheme is a component- or share-allocation scheme where m is the number of shares or components necessary to form the key, and n is the number of the total set of shares or components related to the key. Management of the shares or components must be sufficient to ensure that no one person can gain access to enough of the item to form the key alone E.g., in an m-of-n scheme (which must use a recognized secret-sharing …

Modified p. 100 → 115

Documented ~~device-configuration~~ procedures ~~examined:~~

Documented procedures reviewed:

Modified p. 101 → 116

• Only designated custodians can send/receive the component or ~~share~~

• Only designated custodians can send/receive the component or share.

Modified p. 101 → 116

• There is a clear understanding that an individual with access to a key component or key share does not have access to other components/shares of this key or to any other medium conveying any other components or shares of this key that are sufficient to form the necessary threshold to derive the ~~key~~

• There is a clear understanding that an individual with access to a key component or key share does not have access to other components/shares of this key or to any other medium conveying any other components or shares of this key that are sufficient to form the necessary threshold to derive the key.

Modified p. 101 → 116

• There is sufficient evidence to show that a person with access to the media conveying a key component or key share could not have access to other components/shares of this key or to any other medium conveying any other components or shares of this key that are sufficient to form the necessary threshold to derive the key without ~~detection Personnel interviewed: <Report Findings Here> Describe how the observed key-transfer processes verified that:~~

• There is sufficient evidence to show that a person with access to the media conveying a key component or key share could not have access to other components/shares of this key or to any other medium conveying any other components or shares of this key that are sufficient to form the necessary threshold to derive the key without detection.

Modified p. 101 → 116

• An individual with access to a key component or key share does not have access to other components/shares of this key or to any other medium conveying other components or shares of this key that are sufficient to form the necessary threshold to derive the key.

• An individual with access to a key component or key share does not have access to other components/shares of this key or to any other medium conveying any other components or shares of this key that are sufficient to form the necessary threshold to derive the key.

Modified p. 101 → 116

• Any person with access to the media conveying a key component or key share ~~must~~ not have access to other components/shares of this key or to any other medium conveying any other components or shares of this key that are sufficient to form the necessary threshold to derive the ~~key.~~

• Any person with access to the media conveying a key component or key share could not have access to other components/shares of this key or to any other medium conveying any other components or shares of this key that are sufficient to form the necessary threshold to derive the key without detection.

Removed p. 102

8-3.a Validate through interviews, observation, and log inspection that e-mail, SMS, fax, telephone, or similar communication is not used as means to convey secret or private keys or key components/shares.

Modified p. 103 → 118

• Examples of acceptable methods include:

Examples of acceptable methods include:

Modified p. 103 → 118

• Use of public-key certificates as defined in within this Domain that are created by a trusted CA that meets the applicable requirements of this Domain

• Use of public-key certificates as defined within this Domain that are created by a trusted CA that meets the applicable requirements of this Domain

Modified p. 103 → 118

Self-signed root certificates protect the integrity of the data within the certificate but do not guarantee the authenticity of the data. The authenticity of the root ~~certificate~~ is based on the use of secure procedures to distribute them. Specifically, they must be directly installed into the PIN pad of the ATM or POS device and not remotely loaded to the device subsequent to manufacture.

Self-signed root certificates protect the integrity of the data within the certificate but do not guarantee the authenticity of the data. The authenticity of the root certificates is based on the use of secure procedures to distribute them. Specifically, they must be directly installed into the PIN pad of the ATM or POS device and not remotely loaded to the device subsequent to manufacture.

Modified p. 103 → 118

For all methods used to convey public keys, perform the following:

8-4 For all methods used to convey public keys, perform the following:

Modified p. 103 → 118

• Encrypted Documented procedures ~~examined:~~

• Encrypted Documented procedures reviewed:

Removed p. 104

Responsible personnel interviewed: <Report Findings Here> Describe how the observed process for conveying public keys verified that all methods ensure public keys are conveyed in a manner that protects their integrity and authenticity:

Modified p. 104 → 118

~~Identify the P2PE Assessor who attests~~ that ~~self- signed~~ certificates must not be used as the sole method of ~~authentication:~~

<Report Findings Here> 8-4.b Validate that procedures dictate that self-signed certificates must not be used as the sole method of authentication.

Modified p. 104 → 119

~~<Report Findings Here> 8-4.c Observe~~ the process for conveying public ~~keys, associated logs, and interview responsible personnel to verify~~ that ~~the implemented method ensures~~ public keys are conveyed in a manner that protects their integrity and ~~authenticity.~~

Describe how the observed process for conveying public keys verified that all methods ensure public keys are conveyed in a manner that protects their integrity and authenticity:

Modified p. 105 → 119

9-1.a Examine documented procedures for transmission, conveyance, or movement of keys between any two locations to verify that any single ~~clear-text~~ secret or private key component/share must at all times be either:

9-1.a Examine documented procedures for transmission, conveyance, or movement of keys between any two locations to verify that any single clear- text secret or private key component/share must at all times be either:

Modified p. 105 → 119

• Under the continuous supervision of a person with authorized access to this ~~component,~~

• Under the continuous supervision of a person with authorized access to this component

Modified p. 105 → 119

• Sealed in a security container or courier mailer (including ~~pre-numbered,~~ tamper-evident, authenticable packaging) in such a way that it can be obtained only by a person with authorized access to it, unauthorized access to it would be detected, or

• Sealed in a security container or courier mailer (including pre- numbered, tamper-evident, authenticable packaging) in such a way that it can be obtained only by a person with authorized access to it, unauthorized access to it would be detected, or

Modified p. 106 → 120

• Sealed in a security container or courier mailer (including ~~pre-numbered~~ tamper-evident, authenticable packaging) in such a way that it can be obtained only by a person with authorized access to it, or ~~contained within a physically secure SCD.~~

• Sealed in a security container or courier mailer (including pre- numbered tamper-evident, authenticable packaging) in such a way that it can be obtained only by a person with authorized access to it, or

Modified p. 106 → 120

• ~~Locked~~ in a security container (including pre-numbered ~~tamper-evident,~~ authenticable packaging) in such a way that it can be obtained only by a person with authorized access to it, ~~unauthorized access to it would be detected,~~ or

• Sealed in a security container or courier mailer (including pre-numbered tamper- evident, authenticable packaging) in such a way that it can be obtained only by a person with authorized access to it, or

Modified p. 106 → 120

• ~~Contained~~ within a physically secure SCD.

• contained within a physically secure SCD.

Modified p. 106 → 120

<Report Findings Here> 9-2 Packaging or mailers (i.e., pre-numbered, tamper-evident packaging) containing clear-text key components are examined for evidence of tampering before being opened. Any sign of package tampering indicating a component was potentially compromised must be assessed and the analysis formally documented. If compromise is confirmed, and the result is that one person could have knowledge of the key, it must result in the destruction and replacement of:

<Report Findings Here> 9-2 Packaging or mailers (i.e., pre-numbered, tamper-evident packaging) containing clear-text key components are examined for evidence of tampering before being opened. Any sign of package tampering indicating a component was potentially compromised must be assessed and the analysis formally documented. If a compromise is confirmed, and the result is that one person could have knowledge of the key, it must result in the destruction and replacement of:

Modified p. 106 → 120

Documented procedures reviewed: ~~<Report Findings Here>~~

Documented procedures reviewed:

Removed p. 107

<Report Findings Here> 9-2.c Verify documented procedures require that any sign of package tampering is identified, reported, and, if compromise is confirmed, ultimately results in the destruction and replacement of both:

Modified p. 107 → 120

~~Responsible personnel interviewed:~~ <Report Findings Here> Describe how the processes observed verified that all packaging or mailers containing ~~clear- text~~ key components are examined for evidence of tampering before being opened:

<Report Findings Here> Describe how the processes observed verified that all packaging or mailers containing clear-text key components are examined for evidence of tampering before being opened:

Modified p. 107 → 121

• The set of ~~components, and~~

• The set of components

Modified p. 107 → 121

~~• Any keys encrypted under this (combined) key Responsible personnel interviewed :~~ <Report Findings Here> Describe how the process observed verified that if a package shows signs of tampering, processes are implemented that result in the destruction and replacement of both:

<Report Findings Here> Describe how the process observed verified that if a package shows signs of tampering, processes are implemented that result in the destruction and replacement of both:

Modified p. 107 → 121

• Any keys encrypted under this (combined) key ~~Documented records~~ examined: ~~<Report Findings Here>~~

• Any keys encrypted under this (combined) key Records related to escalated transmital events examined:

Modified p. 108 → 122

9-3.a Verify the existence of a list(s) of key ~~custodians and~~ designated ~~backup(s) authorized~~ to have physical access to key components prior to being secured in transmittal packaging and upon removal of a secured key component from transmittal packaging.

9-3.a Verify the existence of a list(s) of key custodians⎯and designated backup(s)⎯authorized to have physical access to key components prior to being secured in transmittal packaging and upon removal of a secured key component from transmittal packaging.

Modified p. 108 → 122

~~Documented reviewed:~~ <Report Findings Here> 9-3.b Observe implemented access controls and processes to verify that only those authorized key ~~custodians and~~ designated ~~backup(s) have~~ physical access to key components prior to being secured in transmittal packaging and upon removal of a secured key component from transmittal packaging.

<Report Findings Here> 9-3.b Observe implemented access controls and processes to verify that only those authorized key custodians⎯and designated backup(s)⎯have physical access to key components prior to being secured in transmittal packaging and upon removal of a secured key component from transmittal packaging.

Modified p. 108 → 122

Describe the implemented access controls and processes observed that verified that only those authorized key custodians (and designated backup(s)) have physical access to key components prior to being secured in transmittal ~~packaging:~~

Describe the implemented access controls and processes observed that verified that only those authorized key custodians (and designated backup(s)) have physical access to key components prior to being secured in transmittal packaging and upon removal of a secured key component from transmittal packaging <Report Findings Here> 9-3.c Examine physical access logs (e.g., to security containers for key components) to verify that only the authorized individual(s) have access to each component.

Removed p. 109

• Upon receipt, check the tamper-evident packaging for signs of tampering prior to opening the tamper-evident packaging containing the key component.

• Check the serial number of the tamper-evident packaging upon receipt of a component package.

Modified p. 109 → 123

• Check tamper-evident packaging upon receipt for signs of ~~tampering~~ prior to opening tamper-evident authenticable packaging containing key components.

• Check tamper-evident packaging upon receipt for signs of tamper prior to opening tamper-evident authenticable packaging containing key components.

Modified p. 109 → 123

• Check the serial number of the tamper-evident packaging upon receipt of a component package.

Check the serial number of the tamper-evident packaging upon receipt of a component package.

Modified p. 109 → 123

• Place the key component into pre-numbered ~~tamper- evident~~ packaging for transmittal.

• Place the key component into pre-numbered tamper-evident packaging for transmittal.

Modified p. 109 → 123

• Place the key component into pre-numbered ~~tamper- evident~~ packaging for transmittal.

• Place the key component into pre-numbered tamper-evident packaging for transmittal.

Modified p. 109 → 123

• Upon receipt, check the tamper-evident packaging for signs of ~~tampering~~ prior to opening the ~~tamper- evident~~ packaging containing the key component.

• Upon receipt, check the tamper-evident packaging for signs of tamper prior to opening the tamper-evident packaging containing the key component.

Modified p. 109 → 123

• Upon receipt, check the tamper-evident packaging for signs of ~~tampering~~ prior to opening the ~~tamper- evident~~ packaging containing the key component.

• Upon receipt, check the tamper-evident packaging for signs of tamper prior to opening the tamper-evident packaging containing the key component.

Modified p. 109 → 123

~~Documented~~ reviewed: <Report Findings Here> ~~9-4.b Observe~~ implemented mechanisms and processes ~~and examine logs to verify~~ that only the authorized key custodians can perform the following:

Logs reviewed: <Report Findings Here> Describe how the implemented mechanisms and processes observed verified that only the authorized key custodians can perform the following:

Modified p. 110 → 124

9-5 Verify that pre-numbered, tamper-evident, authenticable bags are used for the conveyance of ~~clear- text~~ key components and perform the following:

9-5 Verify that pre-numbered, tamper-evident, authenticable bags are used for the conveyance of clear-text key components and perform the following:

Modified p. 110 → 124

~~Documented procedures reviewed:~~ <Report Findings Here> Responsible personnel interviewed:

<Report Findings Here> Responsible personnel interviewed:

Removed p. 111

Documented procedures reviewed: <Report Findings Here> 9-6.b Examine logs to verify that procedures are followed.

Modified p. 111 → 125

• Records reflect the receipt of the shipped bag and association with subsequent individual ~~bags.~~

• Records reflect the receipt of the shipped bag and association with subsequent individual bags <Report Findings Here> 9-6.b Examine logs to verify that procedures are followed. Logs reviewed: <Report Findings Here>

Removed p. 112

Appropriate Personnel interviewed: <Report Findings Here> Documented procedures reviewed: <Report Findings Here>

Modified p. 112 → 126

• RSA keys encrypting keys greater in strength than 80 bits ~~shall~~ must have a bit strength of at least 112 bits.

• RSA keys encrypting keys greater in strength than 80 bits must have a bit strength of at least 112 bits.

Modified p. 112 → 126

10-1.a Examine documented procedures to verify there is a requirement that all keys used to transmit or convey other cryptographic keys must be at least as strong as any key transmitted or conveyed, as delineated in Annex C. (except as noted for RSA keys).

10-1.a Examine documented procedures to verify there is a requirement that all keys used to transmit or convey other cryptographic keys must be at least as strong as any key transmitted or conveyed, as delineated in Annex C (except as noted for RSA keys).

Modified p. 112 → 126

~~Documented procedures reviewed:~~ <Report Findings Here> 10-1.b Using the network schematic and the summary listing of cryptographic keys and through interview of personnel, identify keys that protect other keys for transmission. Consider keys manually transferred (e.g., cryptograms sent to an ESO) as well as those that are ~~system-generated~~ and transferred (e.g., KEK or TMK encrypting working keys).

<Report Findings Here> 10-1.b Using the network schematic and the summary listing of cryptographic keys and through interview of personnel, identify keys that protect other keys for transmission. Consider keys manually transferred (e.g., cryptograms sent to an ESO) as well as those that are system- generated and transferred (e.g., KEK or TMK encrypting working keys).

Removed p. 113

• A triple-length TDEA key must not be encrypted with a TDEA key of lesser strength.

• RSA keys encrypting keys greater in strength than 80 bits have a bit strength at least 112 bits.

<Report Findings Here> 10-1.d Examine system documentation and configuration files to validate the above, including HSM settings.

System documentation examined:

Modified p. 113 → 127

• TDEA keys used for encrypting keys must be at least triple-length keys (have an effective bit strength of 112 bits) and use the TDEA in an encrypt, decrypt, encrypt mode of operation for ~~key-encipherment.~~

- TDEA keys used for encrypting keys must be at least triple-length keys (have an effective bit strength of 112 bits) and use the TDEA in an encrypt, decrypt, encrypt mode of operation for key- encipherment. - A triple-length TDEA key must not be encrypted with a TDEA key of lesser strength.

Modified p. 113 → 127

• TDEA keys are not be used to encrypt keys greater in strength than 112 bits.

• TDEA keys are not be used to encrypt keys greater in strength than 112 bits. - RSA keys encrypting keys greater in strength than 80 bits have a bit strength at least 112 bits.

Modified p. 113 → 127

Describe how the key-generation processes observed verified that all keys used to transmit or convey other cryptographic keys are at least as strong as any key transmitted or conveyed, as delineated in Annex C.

<Report Findings Here> Describe how the key-generation processes observed verified that all keys used to transmit or convey other cryptographic keys are at least as strong as any key transmitted or conveyed, as delineated in Annex C:

Modified p. 113 → 127

<Report Findings Here> 10-2 to 10-5 Not used in P2PE

<Report Findings Here> 10-2 Not used in P2PE 10-3 Not used in P2PE 10-4 Not used in P2PE 10-5 Not used in P2PE

Modified p. 114 → 128

Documented procedures ~~examined:~~ <Report Findings Here> 11-1.b Interview responsible personnel to verify that the documented procedures are known and understood by all affected parties for key transmission and conveyance processing.

Documented procedures reviewed: <Report Findings Here> 11-1.b Interview responsible personnel to verify that the documented procedures are known and understood by all affected parties for key transmission and conveyance processing.

Modified p. 114 → 128

~~11-2.a~~ Verify documented procedures include all methods used for the conveyance or receipt of keys.

11-2 Verify documented procedures include all methods used for the conveyance or receipt of keys.

Removed p. 115

<Report Findings Here> 12-1.d Verify that the process includes the entry of individual key components by the designated key custodians.

Modified p. 115 → 128

Documented ~~procedures~~ reviewed: <Report Findings Here> 12-1.b Interview appropriate personnel to determine the number of key components for each manually loaded key.

Documented process reviewed: <Report Findings Here> 12-1.b Interview appropriate personnel to determine the number of key components for each manually loaded key.

Modified p. 115 → 128

Appropriate personnel interviewed: <Report Findings Here> 12-1.c Witness a structured walk-through/demonstration of various ~~key-loading~~ processes for all key types (MFKs, AWKs, TMKs, PEKs, etc.). Verify the number and length of the key components against information provided through verbal discussion and written documentation.

Appropriate personnel interviewed: <Report Findings Here> 12-1.c Witness a structured walk-through/demonstration of various key- loading processes for all key types (MFKs, AWKs, TMKs, PEKs, etc.). Verify the number and length of the key components against information provided through verbal discussion and written documentation.

Removed p. 116

Describe how the review of locations where keys may have been recorded verified there are no key or component values recorded.

Modified p. 116 → 129

<Report Findings Here> 12-2 Procedures must be established that will prohibit any one person from having access to components sufficient to form an encryption key when components are removed from and returned to storage for key loading.

Documents reviewed: <Report Findings Here> 12-2 Procedures must be established that will prohibit any one person from having access to components sufficient to form an encryption key when components are removed from and returned to storage for key loading.

Modified p. 116 → 129

12-2.a. Examine logs of access to security containers for key components/shares to verify that only the authorized custodian(s) have ~~accessed them.~~ Compare the number on the current tamper-evident and authenticable package for each component to the last log entry for that component.

12-2.a. Examine logs of access to security containers for key components/shares to verify that only the authorized custodian(s) have accessed. Compare the number on the current tamper-evident and authenticable package for each component to the last log entry for that component.

Modified p. 116 → 129

Trace historical movement of higher-order keys (MFK, KEK, and BDK) in and out of secure storage to ensure there is no break in the ~~package-number~~ chain that would call into question authorized handling and sufficient storage of the component or share. This must address at a minimum the time frame from the date of the prior audit.

Trace historical movement of higher-order keys (MFK, KEK, and BDK) in and out of secure storage to ensure there is no break in the package- number chain that would call into question authorized handling and sufficient storage of the component or share. This must address at a minimum the time frame from the date of the prior audit.

Modified p. 116 → 129

Access logs examined:

Access logs examined: <Report Findings Here>

Modified p. 117 → 130

• Dual control must be implemented using one or more of, but not limited to, the following techniques:

Dual control must be implemented using one or more of, but not limited to, the following techniques:

Modified p. 117 → 130

Note: Passwords/authentication codes to the same object may be assigned to a custodian group ~~team e.g.,~~ custodian team for component A.

Note: Passwords/authentication codes to the same object may be assigned to a custodian group team⎯e.g., custodian team for component A.

Modified p. 118 → 130

• Procedures require dual control to authorize any ~~key- loading~~ session.

• Procedures require dual control to authorize any key-loading session.

Modified p. 118 → 130

• There is a requirement that if passwords/authentication codes or tokens are used, they be maintained separately.

There is a requirement that if passwords/authentication codes or tokens are used, they are maintained separately.

Modified p. 118 → 130

Documented procedures ~~examined:~~

Documented procedures reviewed: <Report Findings Here>

Modified p. 118 → 131

Describe how the observed processes for loading clear-text cryptographic keys for all types of production SCDs verified that dual control is required to authorized any key-loading sessions, expected techniques are used, any passwords used are a minimum of five characters (default passwords/authentication codes are reset) and any passwords/authentication codes or tokens are maintained separately:

Describe how the observed processes for loading clear-text cryptographic keys for all types of production SCDs verified that

Modified p. 119 → 131

<Report Findings Here> 12-3.d Ensure that any default dual-control mechanisms (e.g., default passwords/authentication codes

•usually printed in the vendor's manual ~~•in a key-loading device) have been disabled or changed.~~

<Report Findings Here> 12-3.d Ensure that any default dual-control mechanisms (e.g., default passwords/authentication codes

•usually printed in the vendor's manual

Modified p. 119 → 132

12-4.a Examine documented procedures for combining symmetric-key components and observe processes to verify that key components are combined using a process such that no active bit of the key can be determined without knowledge of the remaining ~~components e.g.,~~ only within an SCD.

12-4.a Examine documented procedures for combining symmetric-key components and observe processes to verify that key components are combined using a process such that no active bit of the key can be determined without knowledge of the remaining components⎯e.g., only within an SCD.

Modified p. 119 → 132

Describe how ~~the~~ key-component lengths or device configuration settings ~~observed~~ verified that key components used to create a key are the same length as the resultant key:

Describe how key-component lengths or device configuration settings verified that key components used to create a key are the same length as the resultant key:

Removed p. 120

<Report Findings Here> 12-6 Any other SCD loaded with the same key components must combine all entered key components using the identical process.

Modified p. 120 → 132

~~12-5.a~~ Examine vendor documentation describing options for how the HSM MFK is created and verify the current MFK was created using AES (or triple-length TDEA for existing P2PE implementations only). Corroborate this via observation of processes, with information gathered during the interview process, and procedural documentation provided by the entity under review.

12-5 Examine vendor documentation describing options for how the HSM MFK is created and verify the current MFK was created using AES (or triple-length TDEA for existing P2PE implementations only). Corroborate this via observation of processes, with information gathered during the interview process, and procedural documentation provided by the entity under review.

Modified p. 120 → 133

~~12-6.a~~ Thorough examination of documented procedures, interviews, and observation, confirm that any devices that are loaded with the same key components use the same mathematical process to derive the final key.

12-6 Thorough examination of documented procedures, interviews, and observation, confirm that any devices that are loaded with the same key components use the same mathematical process to derive the final key.

Modified p. 120 → 133

Documented procedures reviewed: <Report Findings Here> Personnel interviewed: <Report Findings Here> Describe ~~how it was~~ confirmed that any devices that are loaded with the same key components use the same mathematical process to derive the final key:

Documented procedures reviewed: <Report Findings Here> Personnel interviewed: <Report Findings Here> Describe the observations that confirmed that any devices that are loaded with the same key components use the same mathematical process to derive the final key:

Modified p. 121 → 133

• Asymmetric ~~techniques~~

• Asymmetric techniques;

Modified p. 121 → 133

• The existing TMK to encrypt the replacement TMK for ~~download~~

• The existing TMK to encrypt the replacement TMK for download;

Modified p. 121 → 133

• Keys must not be reloaded by any methodology in the event of a compromised device and must be withdrawn from use.

Keys must not be reloaded by any methodology in the event of a compromised device and must be withdrawn from use.

Modified p. 121 → 133

Documented procedures reviewed:

Documented procedures reviewed: <Report Findings Here>

Modified p. 122 → 134

• A public-key technique for the distribution of symmetric secret keys must:

A public-key technique for the distribution of symmetric secret keys must:

Modified p. 122 → 134

~~Documented procedures~~ reviewed: <Report Findings Here> 12-8.b If key-establishment protocols using public-key cryptography are used to remotely distribute secret keys, verify that the applicable requirements detailed in this Domain are met, including:

Documentation reviewed: <Report Findings Here> 12-8.b If key-establishment protocols using public-key cryptography are used to remotely distribute secret keys, verify that the applicable requirements detailed in this Domain are met, including:

Modified p. 122 → 134

Identify the P2PE Assessor who confirms that requirements detailed in this document are met where key-establishment protocols using ~~public- key~~ cryptography are used to remotely distribute secret keys:

Identify the P2PE Assessor who confirms that requirements detailed in this document are met where key-establishment protocols using public-key cryptography are used to remotely distribute secret keys:

Modified p. 122 → 134

<Report Findings Here> ~~12.9~~ Not used in ~~EMS~~

<Report Findings Here> 12-9 Not used in DMS

Removed p. 123

<Report Findings Here> Describe how the demonstration verified that:

• An SCD must transfer a plaintext secret or private key only when at least two authorized individuals are identified by the device.

• There is not any mechanism (including cabling) at the interface between the conveyance medium and the SCD device that might disclose the transferred keys.

• The SCD is inspected to ensure it has not been subject to any prior tampering that could lead to the disclosure of clear-text keying material.

Modified p. 123 → 135

~~13-1.a~~ Observe key-loading environments, processes, and mechanisms (e.g., terminals, PIN pads, key guns, etc.) used to transfer keys and key components. Perform the following:

13-1 Observe key-loading environments, processes, and mechanisms (e.g., terminals, PIN pads, key guns, etc.) used to transfer keys and key components. Perform the following:

Modified p. 123 → 135

Documented procedures reviewed:

Documented procedures reviewed: <Report Findings Here> Describe how the demonstration verified that

Modified p. 123 → 135

• SCDs ~~must be~~ inspected to detect evidence of monitoring and to ensure dual-control procedures are not circumvented during key loading.

- SCDs are inspected to detect evidence of monitoring and to ensure dual-control procedures are not circumvented during key loading. - An SCD transfers a plaintext secret or private key only when at least two authorized individuals are identified by the device.

Modified p. 124 → 135

• The SCD is inspected to ensure it has not been subject to any prior ~~tampering or unauthorized modification,~~ which could lead to the disclosure of clear-text keying material.

• The SCD is inspected to ensure it has not been subject to any prior tampering, which could lead to the disclosure of clear-text keying material.

Modified p. 125 → 136

Note: The addition of applications that replace or disable the PCI-evaluated firmware functionality invalidates the device approval for each such implementation unless those applications are validated for compliance to PTS POI Security Requirements and listed as such in the approval listings. If a PED that has been modified to perform these functions has not been validated and approved to the KLD approval class, ~~they~~ must be managed in accordance with Requirement 13-9.

Note: The addition of applications that replace or disable the PCI-evaluated firmware functionality invalidates the device approval for each such implementation unless those applications are validated for compliance to PTS POI Security Requirements and listed as such in the approval listings. If a PED that has been modified to perform these functions has not been validated and approved to the KLD approval class, the PED must be managed in accordance with Requirement 13-9.

Modified p. 125 → 136

<Report Findings Here> 13-2.b Observe a demonstration of key loading to verify that only SCDs are used in the loading of clear-text secret or private keys or their components outside of a secure key-loading facility.

Documented procedures reviewed: <Report Findings Here> 13-2.b Observe a demonstration of key loading to verify that only SCDs are used in the loading of clear-text secret or private keys or their components outside of a secure key-loading facility.

Modified p. 125 → 136

Describe how the ~~observed~~ demonstration verified that only SCDs are used in the loading of clear-text secret or private keys or their components outside of a secure ~~key-loading~~ facility.

Describe how the key loading demonstration verified that only SCDs are used in the loading of clear-text secret or private keys or their components outside of a secure key- loading facility.

Removed p. 126

• All traces of the component are erased or otherwise destroyed from the electronic medium.

Modified p. 126 → 137

<Report Findings Here> 13-3.b Observe key-loading processes to verify that the injection process results in one of the following:

Documented procedures reviewed: <Report Findings Here> 13-3.b Observe key-loading processes to verify that the injection process results in one of the following:

Modified p. 126 → 137

• The medium used for key injection is placed into secure storage and managed under dual control (only if there is a possibility it will be required for future ~~re- loading~~ of the component into the cryptographic device); or

• The medium used for key injection is placed into secure storage and managed under dual control (only if there is a possibility it will be required for future re-loading of the component into the cryptographic device); or

Modified p. 126 → 137

• The medium used for key injection is placed into secure storage and managed under dual control (only if there is a possibility it will be required for future re-loading of the component into the cryptographic device); or

• The medium used for key injection is placed into secure storage and managed under dual control (only if there is a possibility it will be required for future re-loading of the component into the cryptographic device); or • All traces of the component are erased or otherwise destroyed from the electronic medium in accordance with Requirement 24.

Removed p. 127

Logs examined: <Report Findings Here> 13-4 For secret or private keys transferred from the cryptographic hardware that generated the key to an electronic key- loading device:

Modified p. 127 → 138

13-4.1 The key-loading device must be a physically secure SCD, designed and implemented in such a way that any unauthorized disclosure of the key is prevented or detected.

13-4.1 The key-loading device must be a physically secure SCD, designed and implemented in such a way that any unauthorized disclosure of the key is prevented or detected. Note: A PCI-approved KLD meets this requirement for an SCD.

Modified p. 127 → 138

<Report Findings Here> Describe how the observed processes for the use of key-loading devices verified that the ~~key- loading~~ device is a physically secure SCD, designed and implemented in such a way that any unauthorized disclosure of the key is prevented or detected:

Documented procedures reviewed: <Report Findings Here> Describe how the observed processes for the use of key-loading devices verified that the key-loading device is a physically secure SCD, designed and implemented in such a way that any unauthorized disclosure of the key is prevented or detected:

Removed p. 128

<Report Findings Here> Describe how the observed processes for the use of key-loading devices verified that the key- loading device is designed or controlled so that only authorized personnel under dual control can use and enable it to output a key into another SCD:

Modified p. 128 → 138

Note: Furniture-based locks or containers with a limited set of unique keys

•e.g., desk drawers

•are not sufficient to meet this requirement.

<Report Findings Here> 13-4.2 The key-loading device must be under the supervision of a person authorized by management, or stored in a secure container such that no unauthorized person can have access to it. Note: Furniture-based locks or containers with a limited set of unique keys

•e.g., desk drawers

•are not sufficient to meet this requirement.

Modified p. 128 → 138

<Report Findings Here> Describe how the observed processes for the use of key-loading devices verified that the ~~key- loading~~ device is under the supervision of a person authorized by management, or stored in a secure container such that no unauthorized person can have access to it:

Documented procedures reviewed: <Report Findings Here> Describe how the observed processes for the use of key-loading devices verified that the key-loading device is under the supervision of a person authorized by management, or stored in a secure container such that no unauthorized person can have access to it:

Modified p. 128 → 139

~~13-4.3.a Verify~~ the key-loading device is designed or controlled so that only authorized personnel under dual control can use and enable it to output a key into another SCD.

Documented procedures reviewed: <Report Findings Here> Describe how the observed processes for the use of key-loading devices verified that the key-loading device is designed or controlled so that only authorized personnel under dual control can use and enable it to output a key into another SCD. Such personnel must ensure that a key-recording device is not inserted between the SCDs.

Modified p. 128 → 139

<Report Findings Here> 13-4.3.b Verify that both authorized personnel involved in key-loading activity inspect the key-loading device prior to use to ensure that a ~~key-recording~~ device has not been inserted between the SCDs.

<Report Findings Here> 13-4.3.b Verify that both authorized personnel involved in key-loading activity inspect the key-loading device prior to use to ensure that a key- recording device has not been inserted between the SCDs.

Modified p. 129 → 139

Documented procedures reviewed: <Report Findings Here> Describe how the observed processes for the use of key-loading devices verified that the ~~key- loading~~ device does not retain any information that might disclose the key that was installed in the device or a key that it has successfully ~~transferred:~~

Documented procedures reviewed: <Report Findings Here> Describe how the observed processes for the use of key-loading devices verified that the key-loading device does not retain any information that might disclose the key (e.g., allow replay of the key for injection into a non-SCD) that was installed in the device or a key that it has successfully transferred.

Removed p. 130

• from the secure storage location. Verify procedures include the following:

Documented procedures examined:

Modified p. 130 → 140

Key components that can be read (e.g., those printed on paper or stored on magnetic cards, PROMs, or smartcards) must be managed so they are never used in a manner that would result in the component being displayed in ~~clear text~~ to anyone who is not a designated custodian for that component.

Key components that can be read (e.g., those printed on paper or stored on magnetic cards, PROMs, or smartcards) must be managed so they are never used in a manner that would result in the component being displayed in clear-text to anyone who is not a designated custodian for that component.

Modified p. 130 → 140

Personnel interviewed: <Report Findings Here> Media locations observed: <Report Findings Here> 13-5.b Examine documented procedures for removing media or devices containing key components

•or that are otherwise used for the injection of cryptographic keys

Personnel interviewed: <Report Findings Here> Media locations observed: <Report Findings Here> 13-5.b Examine documented procedures for removing media or devices containing key components

•or that are otherwise used for the injection of cryptographic keys •from the secure storage location. Verify procedures include the following:

Modified p. 131 → 140

<Report Findings Here> 13-5.d Interview key-injection personnel and examine logs for the removal of media/devices from secure storage to verify they are removed only for the minimum practical time necessary to complete the key-loading process.

<Report Findings Here> Key-management logs examined: <Report Findings Here> 13-5.d Interview key-injection personnel and examine logs for the removal of media/devices from secure storage to verify they are removed only for the minimum practical time necessary to complete the key-loading process.

Modified p. 131 → 140

Key-injection personnel interviewed:

Key-injection personnel interviewed: <Report Findings Here> Logs examined: <Report Findings Here>

Modified p. 132 → 141

Describe how the observed key-loading processes verified that printed/written ~~key-component~~ documents are not opened until immediately prior to use:

Describe how the observed key-loading processes verified that printed/written key component documents are not opened until immediately prior to use:

Removed p. 133

<Report Findings Here> 13-9 Not used in EMS

Removed p. 134

Note: Where key-loading is performed for POI devices, the secure environment as defined in Requirement 32-9 must additionally be met.

Modified p. 134 → 142

• Any resources (e.g., passwords/authentication codes and associated hardware) used in the key-loading function or for the signing of authenticated applications must be controlled and managed such that no single individual has the capability to enable key loading of ~~clear-text~~ keys or their components.

• Any resources (e.g., passwords/authentication codes and associated hardware) used in the key-loading function or for the signing of authenticated applications must be controlled and managed such that no single individual has the capability to enable key loading of clear- text keys or their components.

Modified p. 134 → 142

Documented procedures ~~examined:~~ <Report Findings Here> 14-1.b Observe key-loading environments and controls to verify the following:

Documented procedures reviewed: <Report Findings Here> 14-1.b Observe key-loading environments and controls to verify the following:

Modified p. 134 → 142

• All hardware used in the key-loading function is controlled and maintained in a secure environment under dual control.

• All hardware used in the key-loading function is controlled and maintained in a secure environment under dual control. • All resources (e.g., passwords and associated hardware) used for key-loading functions are controlled and managed such that no single individual has the capability to enable key loading.

Removed p. 135

<Report Findings Here> 14-2 All cable attachments over which clear-text keying material traverses must be examined at the beginning of an entity’s key activity operations (system power on/authorization) or application signing operations to ensure they have not been tampered with or compromised.

Modified p. 135 → 143

14-2.a Examine documented procedures to ensure they require that cable attachments are examined at the beginning of an entity’s key-activity operations (system power on/authorization) or ~~application signing~~ operations.

14-2.a Examine documented procedures to ensure they require that cable attachments are examined at the beginning of an entity’s key-activity operations (system power on/authorization) or application-signing operations.

Modified p. 135 → 143

Documented procedures ~~examined:~~ <Report Findings Here> 14-2.b Observe key-loading processes to verify that all cable attachments are properly examined at the beginning of an entity’s key-activity operations (system power on/authorization) or application-signing operations.

Documented procedures reviewed: <Report Findings Here> 14-2.b Observe key-loading processes to verify that all cable attachments are properly examined at the beginning of an entity’s key-activity operations (system power on/authorization) or application-signing operations.

Modified p. 136 → 143

<Report Findings Here> 14-3.b Verify logs of all key-loading and ~~application- signing~~ activities are maintained and contain all required information.

<Report Findings Here> 14-3.b Verify logs of all key-loading and application-signing activities are maintained and contain all required information.

Modified p. 138 → 145

14-5.a Verify that documented procedures require default passwords/authentication codes used to enforce ~~dual- control~~ mechanisms are changed.

14-5.a Verify that documented procedures require default passwords/authentication codes used to enforce dual-control mechanisms are changed.

Modified p. 140 → 146

<Report Findings Here> 15-3 ~~not~~ used in ~~EMS~~ 15-4 ~~not~~ used in ~~EMS~~ 15-5 ~~not~~ used in ~~EMS~~

<Report Findings Here> 15-3 Not used in DMS 15-4 Not used in DMS 15-5 Not used in DMS

Removed p. 141

Documented procedures reviewed: <Report Findings Here> 16-1.b Interview responsible personnel to verify that the documented procedures are known and understood by all affected parties for all key-loading operations.

Modified p. 141 → 147

16-1.a Verify documented procedures exist for all key- loading operations.

16-1.a Verify documented procedures exist for all key-loading operations. Documented procedures reviewed: <Report Findings Here> 16-1.b Interview responsible personnel to verify that the documented procedures are known and understood by all affected parties for all key- loading operations.

Modified p. 141 → 147

Log files examined: <Report Findings Here> Describe how the logging processes observed verified that audit trails are in place for all ~~key- loading~~ events:

Log files examined: <Report Findings Here> Describe how the logging processes observed verified that audit trails are in place for all key-loading events:

Modified p. 142 → 148

• Be unique to those two entities or logically separate ~~systems, and~~

• Be unique to those two entities or logically separate systems

Modified p. 142 → 148

Documented key matrix reviewed: <Report Findings Here> Documented operational procedures ~~<Report Findings Here> Personnel interviewed: <Report Findings Here>~~

Documented key matrix reviewed: <Report Findings Here> Documented operational procedures reviewed:

Modified p. 143 → 148

Generate or otherwise obtain ~~key check~~ values for any ~~key-encipherment~~ keys (KEKs) to verify key uniqueness between the two organizations. A random sample may be used where more than 10 zone connections are in use. This is not intended to be based on values retained on paper or otherwise sent as part of the original conveyance of the keying material, but rather on values generated from stored zone production keys from the production host database. Cryptograms may be used for …

• Generate or otherwise obtain key-check values for any key- encipherment keys (KEKs) to verify key uniqueness between the two organizations. A random sample may be used where more than 10 zone connections are in use. This is not intended to be based on values retained on paper or otherwise sent as part of the original conveyance of the keying material, but rather on values generated from stored zone production keys from the production host database. Cryptograms may be used …

Modified p. 143 → 148

If a remote key-establishment and distribution scheme is implemented between networks, examine public keys and/or hash values and/or fingerprints of the keys to verify key uniqueness of the asymmetric-key pairs.

• If a remote key-establishment and distribution scheme is implemented between networks, examine public keys and/or hash values and/or fingerprints of the keys to verify key uniqueness of the asymmetric-key pairs.

Modified p. 143 → 148

Compare ~~key check~~ values against those for known or default keys to verify that known or default key values are not used.

• Compare key-check values against those for known or default keys to verify that known or default key values are not used.

Modified p. 143 → 148

Describe how the generation of (or otherwise obtaining) key check values for any key- encipherment keys ~~(KEKs), public keys, and/or hash values and/or fingerprints (where a remote key-establishment and distribution scheme is implemented)~~ verified key uniqueness between the two organizations:

Describe how the generation of (or otherwise obtaining) key check values for any key- encipherment keys (KEKs) verified key uniqueness between the two organizations:

Removed p. 144

• Proactive safeguards that shut down the source of any synchronization errors and start an investigative process to determine the true cause of the event.

Modified p. 144 → 149

Documented procedures ~~examined:~~ <Report Findings Here> 18-1.b Verify that implemented procedures include:

Documented procedures reviewed: <Report Findings Here> 18-1.b Verify that implemented procedures include:

Modified p. 144 → 149

• Specific actions that determine whether the legitimate value of the cryptographic key has changed. (For example, encryption of a known value to determine whether the resulting cryptogram matches the expected result.)

Specific actions that determine whether the legitimate value of the cryptographic key has changed. (For example, encryption of a known value to determine whether the resulting cryptogram matches the expected result.) Proactive safeguards that shut down the source of any synchronization errors and start an investigative process to determine the true cause of the event.

Modified p. 144 → 149

~~Documented procedures examined:~~ <Report Findings Here>

Removed p. 145

18-2.a Verify that documented procedures require that key-component packaging/containers showing signs of tampering indicating a component was potentially compromised are assessed and the analysis is formally documented. If compromise is confirmed, and the result is that one person could have knowledge of the key, it must result in the discarding and invalidation of all associated key components and the resultant cryptographic key(s) at all locations where they exist.

Documented procedures examined: <Report Findings Here> 18-2.b Interview personnel and observe processes to verify procedures are implemented to require that key- component packaging/containers showing signs of tampering indicating a component was potentially compromised are assessed and the analysis is formally documented. If compromise is confirmed, and the result is that one person could have knowledge of the key, it results in the discarding and invalidation of all associated key components and the resultant cryptographic key(s) at all locations where they exist.

Modified p. 145 → 149

<Report Findings Here> Describe how the processes observed verified that procedures are implemented to require that key-component packaging/containers showing signs of tampering result in the discarding and invalidation of all associated key components and the resultant cryptographic key(s) at all locations where they exist:

Personnel interviewed: <Report Findings Here> Describe how the processes observed verified that procedures are implemented to require that key-component packaging/containers showing signs of tampering result in the discarding and invalidation of all associated key components and the resultant cryptographic key(s) at all locations where they exist:

Removed p. 146

<Report Findings Here> Where key blocks are not implemented, describe how the examined project plans verified that key block implementation is in accordance with the prescribed timeline(s).

Modified p. 146 → 150

• A MAC computed over the concatenation of the clear-text attributes and the enciphered portion of the key block, which includes the key itself ~~e.g.~~ TR-31;

• A MAC computed over the concatenation of the clear-text attributes and the enciphered portion of the key block, which includes the key itself e.g., TR-31;

Modified p. 146 → 150

Describe how the ~~documented procedures examined and the~~ key operations ~~observed~~ verified that secret cryptographic keys are managed as key blocks using mechanisms that cryptographically bind the key usage to the key at all times via one of the acceptable methods or an ~~equivalent.~~

Documented procedures reviewed: <Report Findings Here> Describe how the observed key operations verified that secret cryptographic keys are managed as key blocks using mechanisms that cryptographically bind the key usage to the key at all times via one of the acceptable methods or an equivalent, or where key blocks are not implemented, identify and examine project plans to implement in accordance with the prescribed timeline.

Modified p. 146 → 150

<Report Findings Here> 18-4 Not used in ~~EMS~~ 18-5 Not used in ~~EMS~~

<Report Findings Here> 18-4 Not used in DMS 18-5 Not used in DMS 18-6 Not used in DMS

Modified p. 147 → 151

19-1.a Examine key-management documentation (e.g., the ~~cryptographic-key~~ inventory) and interview key custodians and key-management supervisory personnel to verify that cryptographic keys are defined for a specific purpose.

19-1.a Examine key-management documentation (e.g., the cryptographic- key inventory) and interview key custodians and key-management supervisory personnel to verify that cryptographic keys are defined for a specific purpose.

Modified p. 147 → 151

Key-management documentation <Report Findings Here> Key custodians interviewed: <Report Findings Here> Key-management supervisory personnel interviewed:

Key-management documentation reviewed: <Report Findings Here> Key custodians interviewed: <Report Findings Here> Key-management supervisory personnel interviewed:

Removed p. 149

Note: For logically partitioned HSMs and computing platforms, if one or more logical partitions of a physical device are used for production and one or more other logical partitions are used for testing, including QA or similar, the entire configuration that is impacted

•computing platform(s) and networking equipment

•must be managed and controlled as production.

Modified p. 149 → 153

Keys used for ~~production~~ must y present or used in a production system.

• Keys used for testing keys must never be present or used in a production system.

Modified p. 149 → 153

19-4.a Examine key-management documentation and interview key custodians and key-management supervisory personnel to verify that cryptographic keys are never shared or substituted between production and ~~test/development~~ systems.

19-4.a Examine key-management documentation and interview key custodians and key-management supervisory personnel to verify that cryptographic keys are never shared or substituted between production and development systems.

Modified p. 149 → 153

<Report Findings Here> 19-4.b Observe processes for generating and loading keys into production systems to ensure that they are in no way associated with test or development keys.

<Report Findings Here> 19-4.b Observe processes for generating and loading keys into in production systems to ensure that they are in no way associated with test or development keys.

Modified p. 149 → 153

<Report Findings Here> 19-4.d Compare check, hash, cryptogram, or fingerprint values for production and test/development keys ~~with~~ higher-level keys ~~(MFKs,~~ KEKs shared with other network nodes, and BDKs) to verify that development and test keys have different key values.

<Report Findings Here> 19-4.d Compare check, hash, cryptogram, or fingerprint values for production and test/development keys for higher-level keys (e.g., MFKs, KEKs shared with other network nodes, and BDKs) to verify that development and test keys have different key values.

Modified p. 150 → 154

• deleted from the HSM(s) and the server/computer platforms prior to testing. Subsequent to completion of testing, all keying materials must be deleted, the server/computer platforms must be wiped and rebuilt from read-only media, and the relevant production keying material restored using the principles of dual control and

• deleted from the HSM(s) and the key-injection server/computer platforms prior to testing. Subsequent to completion of testing, all keying materials must be deleted, the server/computer platforms must be wiped and rebuilt from read-only media, and the relevant production keying material restored using the principles of dual control and

Modified p. 150 → 154

At all ~~times,~~ the HSMs and servers/computers must be physically and logically secured in accordance with these requirements.

At all times the HSMs and servers/computers must be physically and logically secured in accordance with these requirements.

Modified p. 150 → 154

~~Note: This~~ does not apply to HSMs that are never intended to be used for production.

Note this does not apply to HSMs that are never intended to be used for production.

Modified p. 150 → 154

• Prior to reuse for production ~~purposes,~~ the HSM is returned to factory state.

• Prior to reuse for production purposes the HSM is returned to factory state.

Modified p. 150 → 154

Personnel interviewed: <Report Findings Here> Documented procedures ~~examined:~~ <Report Findings Here> 19-6 Not used in ~~EMS~~ 19-7 Not used in ~~EMS~~ 19-8 Not used in ~~EMS~~ 19-9 Not used in ~~EMS~~

Personnel interviewed: <Report Findings Here> Documented procedures reviewed: <Report Findings Here> 19-6 Not used in DMS 19-7 Not used in DMS 19-8 Not used in DMS 19-9 Not used in DMS 19-10 Not used in DMS 19-11 Not used in DMS 19-12 Not used in DMS

Removed p. 151

POI device private keys must not exist anywhere but the specific POI device they belong to, except where generated external to the POI device and prior to the injection into the POI device.

Modified p. 151 → 155

This means not only the account-data-encryption key(s), but also keys that are used to protect other ~~keys,~~ firmware- authentication keys, ~~payment-application authentication~~ and ~~display-prompt~~ control keys. As stated in the requirement, this does not apply to public keys resident in the device.

This means that not only the account-data-encryption key(s), but also keys that are used to protect other keys: firmware- authentication keys, payment application authentication, and display prompt control keys. As stated in the requirement, this does not apply to public keys resident in the device.

Modified p. 151 → 155

20-1.a Examine documented procedures for the ~~loading~~ and usage of all keys used in transaction-originating POI devices. Verify the procedures ensure that all private and secret keys used in ~~transaction-originating~~ POI devices are:

20-1.a Examine documented procedures for the generation, loading, and usage of all keys used in transaction-originating POI devices. Verify the procedures ensure that all private and secret keys used in transaction- originating POI devices are:

Modified p. 151 → 155

Documented procedures ~~examined:~~ <Report Findings Here> 20-1.b Observe HSM functions and procedures for generating and loading secret and private keys for use in transaction-originating ~~POI devices~~ to verify that unique keys are generated and used for each POI device.

Documented procedures reviewed: <Report Findings Here> 20-1.b Observe HSM functions and procedures for generating and loading secret and private keys for use in transaction-originating POIs to verify that unique keys are generated and used for each POI device.

Removed p. 152

<Report Findings Here> 20-2 If a POI device directly interfaces with more than one entity for decryption of account data (e.g., different acquiring organizations), the POI device must have a completely different and unique key or set of keys for each acquirer. These different keys, or sets of keys, must be totally independent and not variants of one another.

Modified p. 152 → 156

20-2.a Examine documented procedures for generating all types of keys and verify procedures ~~exist to~~ ensure that unique ~~keys~~ or sets of ~~keys~~ are used for each acquiring organization and totally independent and ~~are~~ not variants of one another.

20-2.a Examine documented procedures for generating all types of keys and verify the procedures ensure that unique keys, or sets of keys, are used for each acquiring organization and are totally independent and not variants of one another.

Modified p. 152 → 156

Documented procedures ~~examined:~~ <Report Findings Here> 20-2.b Interview personnel and observe key-generation processes to verify that unique keys or sets of keys ~~will be~~ generated for each acquiring ~~organization when required.~~

Documented procedures reviewed: <Report Findings Here> 20-2.b Interview personnel and observe key-generation processes to verify that unique keys or sets of keys are generated for each acquiring organization.

Modified p. 152 → 156

~~Personnel interviewed: <Report Findings Here>~~ Describe how the key-generation processes observed verified that unique keys or sets of keys are generated for each acquiring organization:

Describe how the key-generation processes observed verified that unique keys or sets of keys are generated for each acquiring organization:

Removed p. 153

Documented procedures examined: <Report Findings Here> Key generation logs examined: <Report Findings Here> Describe how the processes observed for generating master keys verified that the following is implemented where master keys are generated by a derivation process and derived from the same Base Derivation Key:

• Unique data is used for the derivation process such that all transaction-originating POI devices receive unique secret keys.

• Key derivation is performed prior to a key being loaded/sent to the recipient transaction- originating POI.

Modified p. 153 → 157

This requirement refers to the use of a single “base” key to derive initial keys for many different POI devices, using a key- derivation process as described above. This requirement does not preclude multiple unique keys being loaded on a single device, or for the device to use a unique key for derivation of other keys once loaded•e.g., as done with DUKPT.

This requirement refers to the use of a single “base” key to derive initial keys for many different POI devices, using a key- derivation process as described above. This requirement does not preclude multiple unique keys being loaded on a single device, or for the device to use a unique key for the derivation of other keys once loaded•e.g., as done with DUKPT.

Modified p. 153 → 157

Describe how the processes ~~observed~~ for generating master keys verified that derivation keys used to generate keys for multiple devices are never loaded into a POI device:

Describe how the processes for generating master keys verified that derivation keys used to generate keys for multiple devices are never loaded into a POI device:

Modified p. 154 → 158

• Different BDKs for each financial ~~institution~~

• Different BDKs for each financial institution;

Modified p. 154 → 158

• Different BDKs for each financial ~~institution~~

• Different BDKs for each financial institution;

Modified p. 154 → 158

• Different BDKs by injection vendor (e.g., ESO), terminal manufacturer, or terminal ~~model~~

• Different BDKs by injection vendor (e.g., ESO), terminal manufacturer, or terminal model;

Modified p. 154 → 158

• Different BDKs by injection vendor (e.g., ESO), terminal manufacturer, or terminal ~~model~~

• Different BDKs by injection vendor (e.g., ESO), terminal manufacturer, or terminal model;

Modified p. 154 → 158

~~• Different BDKs by geographic region, market segment, processing platform, or sales unit~~ COMPONENT PROVIDERS ONLY: Must use at least one unique Base Derivation Key (BDK) per acquiring organization and must be able to support segmentation of multiple BDKS of acquiring organizations.

COMPONENT PROVIDERS ONLY: Must use at least one unique Base Derivation Key (BDK) per acquiring organization and must be able to support segmentation of multiple BDKS of acquiring organizations.

Modified p. 154 → 158

• Different BDKs by geographic region, market segment, processing platform, or sales ~~unit~~ FOR COMPONENT PROVIDERS ONLY: Examine documented ~~key-generation~~ and injection procedures to verify that key-injection vendors use at least one unique Base Derivation Key (BDK) per acquiring organization and are able to support segmentation of multiple BDKs of acquiring organizations.

• Different BDKs by geographic region, market segment, processing platform, or sales unit; FOR COMPONENT PROVIDERS ONLY: Examine documented key- generation and injection procedures to verify that key-injection vendors use at least one unique Base Derivation Key (BDK) per acquiring organization and are able to support segmentation of multiple BDKs of acquiring organizations.

Modified p. 154 → 158

~~Documented procedures examined:~~ <Report Findings Here> 20-5 Not used in ~~EMS~~ 20-6 Not used in ~~EMS~~

<Report Findings Here> 20-5 Not used in DMS 20-6 Not used in DMS

Removed p. 155

Documented procedures examined:

Note: Key-injection facilities may have clear-text keying material outside of a SCD when used within a secure room in accordance with Requirement 32.

Note for hybrid decryption solutions: Clear-text Data Decryption Keys (DDKs) may temporarily be retained by the Host System in volatile memory for the purpose of decrypting account data.

Modified p. 155 → 159

21-1.a Examine documented procedures for key storage and usage to verify that secret or private keys only exist in one or more approved forms at all times when ~~stored (with the exception of DDKs used on the Host System for hybrid decryption solutions).~~

• Contained within a secure cryptographic device 21-1.a Examine documented procedures for key storage and usage to verify that secret or private keys only exist in one or more approved forms at all times when stored.

Modified p. 155 → 159

<Report Findings Here> 21-1.b Observe key stores to verify that secret or private keys only exist in one or more approved forms at all times when ~~stored (with the exception of DDKs used on the Host System for hybrid decryption solutions).~~

Documented procedures reviewed: <Report Findings Here> 21-1.b Observe key stores to verify that secret or private keys only exist in one or more approved forms at all times when stored.

Modified p. 155 → 159

Describe how the processes observed for constructing keys verified that at least two key ~~components~~ are required for each key construction:

Describe how the processes observed for constructing keys verified that at least two key components/shares are required for each key construction:

Modified p. 156 → 160

Key-management documentation <Report Findings Here> Key custodians interviewed: <Report Findings Here> Key-management supervisory personnel interviewed:

Key-management documentation reviewed: <Report Findings Here> Key custodians interviewed: <Report Findings Here> Key-management supervisory personnel interviewed:

Modified p. 156 → 160

Describe how the ~~key-component~~ access controls and key-custodian authorizations/assignments observed verified that all individuals with access to key ~~components~~ are designated as key custodians for those particular ~~components:~~

Describe how the key-component/share access controls and key-custodian authorizations/assignments observed verified that all individuals with access to key components/shares are designated as key custodians for those particular components/shares:

Modified p. 157 → 161

In an m-of-n scheme where n=5, where three shares are required to reconstruct the cryptographic key, a single custodian may be permitted to have access to two of the key shares (e.g., share A and share ~~B);~~ and a second custodian (with, in this example, share C) would be required to reconstruct the final key, ensuring that dual control is maintained.

In an m-of-n scheme where n=5, where three shares are required to reconstruct the cryptographic key, a single custodian may be permitted to have access to two of the key shares (e.g., share A and share B), as; and a second custodian (with, in this example, share C) would be required to reconstruct the final key, ensuring that dual control is maintained.

Modified p. 157 → 161

Documented procedures ~~examined:~~ <Report Findings Here> 21-2.4.b Examine key-component/share access controls and access logs to verify that authorized custodians cannot access sufficient key components or shares to reconstruct a secret or private cryptographic key.

Documented procedures reviewed: <Report Findings Here> 21-2.4.b Examine key-component/share access controls and access logs to verify that authorized custodians cannot access sufficient key components or shares to reconstruct a secret or private cryptographic key.

Modified p. 157 → 161

Describe how the ~~key-component~~ access controls and access logs observed verified that authorized custodians cannot access sufficient key components or shares to reconstruct a secret or private cryptographic key:

Describe how the key-component/share access controls and access logs observed verified that authorized custodians cannot access sufficient key components or shares to reconstruct a secret or private cryptographic key:

Modified p. 157 → 161

21-3 Examine documented procedures, interview responsible personnel and inspect key-component/share storage locations to verify that key components/shares are stored as outlined in Requirements 21-3.1 through ~~21- 3.3~~ below:

21-3 Examine documented procedures, interview responsible personnel and inspect key-component/share storage locations to verify that key components/shares are stored as outlined in Requirements 21-3.1 through 21-3.3 below:

Modified p. 157 → 161

Documented procedures ~~examined:~~ <Report Findings Here> Responsible personnel interviewed: <Report Findings Here>

Documented procedures reviewed: <Report Findings Here> Responsible personnel interviewed: <Report Findings Here>

Removed p. 158

Note: Tamper-evident authenticable packaging

•opacity may be envelopes within tamper-evident packaging

Modified p. 158 → 162

• used to secure key components must ensure that the key component cannot be determined. For components written on paper, opacity may be sufficient, but consideration must be given to any embossing or other possible methods to “read” the component without opening of the packaging. Similarly, if the component is stored on a magnetic ~~card,~~ or other media that can be read without direct physical contact, the packaging should be designed to prevent such access to the key component.

Note: Tamper-evident, authenticable packaging (opacity may be envelopes within tamper-evident packaging) used to secure key components must ensure that the key component cannot be determined. For components written on paper, opacity may be sufficient, but consideration must be given to any embossing or other possible methods to “read” the component without opening of the packaging. Similarly, if the component is stored on a magnetic card or other media that can be read without direct physical contact, the packaging should be …

Modified p. 158 → 162

21-3.1.a Examine key components and storage locations to verify that components are stored in individual opaque, ~~pre-numbered, tamper-evident, authenticable~~ packaging that prevents the determination of the key component without noticeable damage to the packaging.

21-3.1.a Examine key components and storage locations to verify that components are stored in individual opaque, pre-numbered tamper-evident packaging that prevents the determination of the key component without noticeable damage to the packaging.

Modified p. 158 → 162

Describe how the key components and storage locations observed verified that components are stored in opaque, pre-numbered tamper-evident packaging that prevents the determination of the key component without noticeable damage to the packaging:

Describe how the key components and storage locations observed verified that components are stored in individual opaque, pre-numbered tamper-evident packaging that prevents the determination of the key component without noticeable damage to the packaging:

Modified p. 158 → 162

<Report Findings Here> 21-3.1.b Inspect any tamper-evident packaging used to secure key components ~~•e.g.,~~ is the package sufficiently opaque to prevent reading of a component ~~•and~~ ensure that it prevents the determination of the key component without visible damage to the packaging.

<Report Findings Here> 21-3.1.b Inspect any tamper-evident packaging used to secure key components e.g., is the package sufficiently opaque to prevent reading of a component and ensure that it prevents the determination of the key component without visible damage to the packaging.

Modified p. 158 → 162

<Report Findings Here> 21-3.1.c ~~Ensure~~ clear-text key components do not exist in non-secure containers, such as databases or in software programs.

<Report Findings Here> 21-3.1.c Interview responsible personnel to determine that clear-text key components do not exist in non-secure containers, such as databases or in software programs.

Modified p. 158 → 162

~~Responsible personnel interviewed:~~ <Report Findings Here>

Removed p. 159

<Report Findings Here> 21-3.2 Key components/shares for each specific custodian must be stored in a separate secure container that is accessible only by the custodian and/or designated backup(s).

Modified p. 159 → 162

Identify the P2PE Assessor who confirms that start-up instructions and other notes used by service technicians do not contain ~~initialization- key~~ values written in the clear:

Identify the P2PE Assessor who confirms that start-up instructions and other notes used by service technicians do not contain initialization-key values written in the clear:

Modified p. 159 → 163

Identify the P2PE Assessor who confirms that for each key ~~component~~ storage container:

Identify the P2PE Assessor who confirms that for each key component/share storage container:

Modified p. 159 → 163

• Key ~~components~~ for different custodians are stored in separate secure containers.

• Key components/shares for different custodians are stored in separate secure containers.

Modified p. 160 → 163

<Report Findings Here> 21-4 Not used in DMS

Modified p. 160 → 164

22-1 Verify documented procedures exist for replacing known or suspected compromised keys that ~~includes~~ all of the following (22-1.1 through 22-1.5 below):

22-1 Verify documented procedures exist for replacing known or suspected compromised keys that include all of the following (22-1.1 through 22-1.5 below):

Modified p. 160 → 164

Documented procedures ~~examined:~~ <Report Findings Here> 22-1.1 Key ~~components~~ are never reloaded when there is any suspicion that either the originally loaded key or the SCD ~~(or, for hybrid decryption solutions, the Host System)~~ has been compromised.

Documented procedures reviewed: <Report Findings Here> 22-1.1 Key components/shares are never reloaded when there is any suspicion that either the originally loaded key or the SCD has been compromised.

Modified p. 160 → 164

22-1.1 Interview responsible personnel and observe implemented processes to verify key components/shares are never reloaded when there is any suspicion that either the originally loaded key or the SCD ~~(or, for hybrid decryption solutions, the Host System)~~ has been compromised.

22-1.1 Interview responsible personnel and observe implemented processes to verify key components/shares are never reloaded when there is any suspicion that either the originally loaded key or the SCD has been compromised.

Modified p. 160 → 164

Responsible personnel interviewed: <Report Findings Here> Describe how the implemented processes observed verified that key ~~components~~ are never reloaded when there is any suspicion that either the originally loaded key or the SCD ~~(or, for hybrid decryption solutions, the Host System)~~ has been compromised:

Responsible personnel interviewed: <Report Findings Here> Describe how the implemented processes observed verified that key components/shares are never reloaded when there is any suspicion that either the originally loaded key or the SCD has been compromised:

Modified p. 160 → 164

<Report Findings Here> 22-1.2 If unauthorized alteration is suspected, new keys are not installed until the SCD ~~(or, for hybrid decryption solutions, the Host System)~~ has been inspected and assurance reached that the equipment has not been subject to any form of unauthorized modification.

<Report Findings Here> 22-1.2 If unauthorized alteration is suspected, new keys are not installed until the SCD has been inspected and assurance reached that the equipment has not been subject to any form of unauthorized modification.

Modified p. 160 → 164

22-1.2 Interview responsible personnel and observe implemented processes to verify that if unauthorized alteration is suspected, new keys are not installed until the SCD ~~(or, for hybrid decryption solutions, the Host System)~~ has been inspected and assurance reached that the equipment has not been subject to any form of unauthorized modification.

22-1.2 Interview responsible personnel and observe implemented processes to verify that if unauthorized alteration is suspected, new keys are not installed until the SCD has been inspected and assurance reached that the equipment has not been subject to any form of unauthorized modification.

Modified p. 160 → 164

Responsible personnel interviewed: <Report Findings Here> Describe how the implemented processes observed verified that if unauthorized alteration is suspected, new keys are not installed until the SCD ~~(or, for hybrid decryption solutions, the Host System)~~ has been inspected and assurance reached that the equipment has not been subject to any form of unauthorized modification:

Responsible personnel interviewed: <Report Findings Here> Describe how the implemented processes observed verified that if unauthorized alteration is suspected, new keys are not installed until the SCD has been inspected and assurance reached that the equipment has not been subject to any form of unauthorized modification:

Modified p. 161 → 165

Known or suspected substitution of a secret key must result in the replacement of that key and based on an analysis of how the key was substituted, any associated key-encipherment keys that may have been compromised 22-1.3 Interview responsible personnel and observe implemented processes to verify that if compromise of the cryptographic key is suspected, an assessment and analysis is performed. If compromise is confirmed, and all the following are performed:

Known or suspected substitution of a secret key must result in the replacement of that key and based on an analysis of how the key was substituted, any associated key-encipherment keys that may have been compromised.

Modified p. 161 → 165

Responsible personnel interviewed: <Report Findings Here> Describe how the implemented processes observed verified that if compromise of the cryptographic key is suspected, an assessment and analysis is performed. If compromise is confirmed, the following are performed:

Responsible personnel interviewed: <Report Findings Here> Describe how the implemented processes observed verified that if compromise of the cryptographic key is suspected, an assessment and analysis is performed. If compromise is confirmed, all the following are performed:

Modified p. 161 → 165

• ~~Processing with~~ that key is halted, and the key is replaced with a new unique key.

• Use of that key is halted, and the key is replaced with a new unique key.

Removed p. 162

<Report Findings Here> 22-1.4.b A documented escalation process and notification to organizations that currently share or have previously shared the key(s), including:

• Identification of key personnel

Modified p. 162 → 166

Responsible personnel interviewed: <Report Findings Here> ~~Describe how~~ the implemented processes observed verified that key personnel are identified and that the escalation process includes notification to organizations that currently share or have previously shared the key(s):

Responsible personnel interviewed: <Report Findings Here> Documented procedures reviewed: <Report Findings Here> 22-1.4.b Verify notifications include the following:

Modified p. 162 → 166

• A damage assessment including, where necessary, the engagement of outside ~~consultants~~

• A damage assessment including, where necessary, the engagement of outside consultants.

Modified p. 162 → 166

• ~~Specific~~ actions to be taken with system software and hardware, encryption keys, encrypted data, etc.

• Details of specific actions to be taken with system software and hardware, encryption keys, encrypted data, etc.

Removed p. 163

• Host System tamper-detection mechanism has been activated, for hybrid decryption solutions 22-1.5 Interview responsible personnel and review documented procedures to verify that specific events that may indicate a compromise are identified. This must include, at a minimum, the following events:

• Host System tamper-detection mechanism has been activated, for hybrid decryption solutions Responsible personnel interviewed: <Report Findings Here> Documented procedures examined: <Report Findings Here>

Modified p. 163 → 167

• Failure to document that a secret or private key has been managed using the principles of dual control and split knowledge from its date of creation

• Failure to document that a secret or private key has been managed using the principles of dual control and split knowledge from its date of creation 22-1.5 Interview responsible personnel and examine documented procedures to verify that specific events that may indicate a compromise are identified. This must include, at a minimum, the following events:

Modified p. 163 → 167

• Failure to document that a secret or private key has been managed using the principles of dual control and split knowledge from its date of creation

• Failure to document that a secret or private key has been managed using the principles of dual control and split knowledge from its date of creation Responsible personnel interviewed: <Report Findings Here> Documented procedures reviewed: <Report Findings Here>

Removed p. 164

Responsible personnel interviewed: <Report Findings Here> Describe how the implemented processes observed verified that if attempts to load a secret key or key component into an KLD or POI device fail, the same key or component is not loaded into a replacement device unless it can be ensured that all residue of the key or component has been erased from or otherwise destroyed in the original KLD or POI device (or Host System):

Modified p. 164 → 168

<Report Findings Here> 22-3 Not used in ~~EMS~~ 22-4 Not used in ~~EMS~~ 22-5 Not used in ~~EMS~~

<Report Findings Here> 22-3 Not used in DMS 22-4 Not used in DMS 22-5 Not used in DMS

Modified p. 164 → 168

~~22-2 Interview responsible~~ personnel ~~and observe~~ implemented processes ~~to verify~~ that if attempts to load a secret key or key component into an KLD or POI device ~~(or a Host System, for hybrid decryption solutions)~~ fail, the same key or component is not loaded into a replacement device unless it can be ensured that all residue of the key or component has been erased from or otherwise destroyed in the original KLD or POI ~~device (or Host System).~~

Responsible personnel interviewed: <Report Findings Here> Describe how the implemented processes observed verified that if attempts to load a secret key or key component into an KLD or POI device fail, the same key or component is not loaded into a replacement device unless it can be ensured that all residue of the key or component has been erased from or otherwise destroyed in the original KLD or POI device:

Modified p. 165 → 169

23-1.a Examine documented procedures and interview responsible personnel to determine whether keys are generated using reversible ~~key-calculation~~ methods.

23-1.a Examine documented procedures and interview responsible personnel to determine whether keys are generated using reversible key- calculation methods.

Removed p. 166

A logical configuration is defined as one where all the components form a system used to undertake a particular task and are managed and controlled under a single operational and security policy.

Modified p. 166 → 170

~~23-2.a~~ Interview responsible personnel to determine which host MFKs keys exist as variants.

23-2 Interview responsible personnel to determine which host MFKs keys exist as variants.

Modified p. 166 → 170

Vendor documentation ~~examined:~~ <Report Findings Here> 23-2.c Via examination of the network schematic detailing transaction flows with the associated key usage and identification of the sources of the keys used, determine that variants of the MFK are not used external to the logical configuration that houses the MFK.

Vendor documentation reviewed: <Report Findings Here> 23-2.c Via examination of the network schematic detailing transaction flows with the associated key usage and identification of the sources of the keys used, determine that variants of the MFK are not used external to the logical configuration that houses the MFK.

Modified p. 166 → 170

Describe how the ~~review~~ of the network schematic detailing transaction flows with the associated key usage and identification of the sources of the keys used verified that variants of the MFK are not used external to the logical configuration that houses the MFK:

Describe how the examination of the network schematic detailing transaction flows with the associated key usage and identification of the sources of the keys used verified that variants of the MFK are not used external to the logical configuration that houses the MFK:

Removed p. 167

Documented procedures examined: <Report Findings Here> Describe how the implemented processes observed verified that reversible key transformations are not used across different levels of the key hierarchy, as follows:

• Variants used as KEKs must only be calculated from other key-encrypting keys

Documented procedures examined: <Report Findings Here>

Modified p. 167 → 171

Note: Using transformations of keys across different levels of a key hierarchy

•e.g., generating a DEK from a ~~key-encrypting~~ key

•increases the risk of exposure of each of those keys.

Note: Using transformations of keys across different levels of a key hierarchy

•e.g., generating a DEK from a key- encrypting key

•increases the risk of exposure of each of those keys.

Modified p. 168 → 173

24-2.a Examine documented procedures for destroying keys and confirm they are sufficient to ensure that no part of the key or component can be recovered. ~~Documented procedures examined: <Report Findings Here> 24-2.b Observe key-destruction processes to verify that no part of the key or component can be recovered.~~

24-2.a Examine documented procedures for destroying keys and confirm they are sufficient to ensure that no part of the key or component can be recovered.

Removed p. 169

• 9564 or ISO

•11568.

Modified p. 169 → 173

24-2.1.a Examine documented procedures for destroying keys and confirm that keys on all other storage media types in all permissible forms •physically secured, enciphered, or components

•must be destroyed following the procedures outlined in ISO

•9564 or ISO

•11568.

24-2.1.a Examine documented procedures for destroying keys and confirm that keys on all other storage media types in all permissible forms

Modified p. 169 → 173

Documented procedures ~~examined:~~ <Report Findings Here> 24-2.1.b Observe key-destruction processes to verify that keys on all other storage media types in all permissible forms

•physically secured, enciphered, or ~~component~~

Documented procedures reviewed: <Report Findings Here> 24-2.1.b Observe key-destruction processes to verify that keys on all other storage media types in all permissible forms

•physically secured, enciphered, or components

•are destroyed following the procedures outlined in ISO

•9564 or ISO

•11568.

Modified p. 169 → 173

• ~~are~~ destroyed following the procedures outlined in ISO

• physically secured, enciphered, or components

•must be destroyed following the procedures outlined in ISO •9564 or ISO

•11568.

Modified p. 170 → 174

24-2.2.a Observe key-destruction process and verify that it is witnessed by a third party other than a key ~~custodian for any component of that key.~~

24-2.2.a Observe key-destruction process and verify that it is witnessed by a third party other than a key custodian.

Modified p. 170 → 174

Identify the P2PE Assessor who confirms the ~~key- destruction~~ process is witnessed by a third party other than a key custodian for any component of that key:

Identify the P2PE Assessor who confirms the key-destruction process is witnessed by a third party other than a key custodian for any component of that key:

Modified p. 170 → 174

<Report Findings Here> 24-2.2.b Inspect key-destruction logs and verify that a third-party, ~~non-key-custodian~~ witness signs an affidavit as a witness to the ~~key destruction~~ process.

<Report Findings Here> 24-2.2.b Inspect key-destruction logs and verify that a third-party, non-key- custodian witness signs an affidavit as a witness to the key-destruction process.

Modified p. 171 → 174

24-2.3.a Verify documented procedures exist for destroying key components of ~~keys~~ once the keys are successfully loaded and validated as operational.

24-2.3.a Verify documented procedures exist for destroying key components of keys, once the keys are successfully loaded and validated as operational.

Modified p. 171 → 174

Documented procedures ~~examined:~~ <Report Findings Here> 24-2.3.b Observe key-conveyance/loading processes to verify that any key components are destroyed once the keys are successfully loaded and validated as operational.

Documented procedures reviewed: <Report Findings Here> 24-2.3.b Observe key-conveyance/loading processes to verify that any key components are destroyed once the keys are successfully loaded and validated as operational.

Removed p. 172

• Key custodian(s) are designated for each component.

Modified p. 172 → 175

~~25-1.1.a~~ Examine key-custodian assignments for each component to verify that:

25-1.1 Examine key-custodian assignments for each component to verify that:

Modified p. 172 → 175

• Assigned key custodians are employees or contracted ~~personnel.~~

• Assigned key custodians are employees or contracted personnel Describe how the key-custodian assignments observed for each component verified that:

Modified p. 172 → 175

~~Describe how the key-custodian assignments reviewed~~ for each ~~component verified that:~~

• A primary and a backup key custodian are designated for each component.

Modified p. 172 → 175

Completed key-custodian forms ~~examined:~~ <Report Findings Here> 25-1.2.b Examine completed key-custodian forms to verify that backup custodians sign the form.

Completed key-custodian forms reviewed: <Report Findings Here> 25-1.2.b Examine completed key-custodian forms to verify that backup custodians sign the form.

Modified p. 172 → 175

Completed key-custodian forms ~~examined:~~ <Report Findings Here>

Completed key-custodian forms reviewed: <Report Findings Here>

Modified p. 173 → 176

• An effective date ~~and time~~ for the custodian’s access

• An effective date for the custodian’s access

Modified p. 173 → 176

• An effective date ~~and time~~ for the custodian’s access

• An effective date for the custodian’s access

Modified p. 173 → 176

• Signature of management authorizing the access Completed key-custodian forms ~~examined:~~ <Report Findings Here>

• Signature of management authorizing the access Completed key-custodian forms reviewed: <Report Findings Here>

Removed p. 174

Organizations that are of insufficient size that they cannot support the reporting-structure requirement must:

Modified p. 174 → 177

The components collectively held by an individual and his or her direct reports must not constitute a quorum (or must not provide any information about the value of the key that is not derivable from a single component).

The components collectively held by an individual and his or her direct reports must not constitute a quorum (or must not provide any information about the value of the key that is not derivable from a single component). Custodians must not become a custodian for a component/share of a key where the custodian has previously been or is currently a custodian for another component/share of that key if that would collectively constitute a quorum to form the actual key.

Modified p. 174 → 177

~~Ensure~~ key custodians do not report to each other (i.e., the manager cannot also be a key ~~custodian); Receive~~ explicit training to instruct them from sharing key components with their direct ~~manager; Sign~~ key-custodian agreements that ~~include~~ an attestation to the ~~requirement; and Receive training that includes procedures to report any violations.~~

Organizations that are of such insufficient size that they cannot support the reporting-structure requirement must ensure key custodians do not report to each other (i.e., the manager cannot also be a key custodian), receive explicit training to instruct them from sharing key components with their direct manager and must sign key-custodian agreements that includes an attestation to the requirement.

Modified p. 175 → 177

Documented key-custodian assignments ~~examined:~~

Documented key-custodian assignments reviewed:

Modified p. 175 → 177

<Report Findings Here> Documented organization charts ~~examined:~~ <Report Findings Here> ~~25-1.4.b For organizations that are such a small, modest size that they cannot support the reporting-structure requirement, ensure that documented procedures exist and are followed to:~~

<Report Findings Here> Documented organization charts reviewed: <Report Findings Here>

Modified p. 175 → 178

Documented procedures ~~examined:~~ <Report Findings Here> 25-2 Not used in ~~EMS~~ 25-3 Not used in ~~EMS~~ 25-4 Not used in ~~EMS~~

Documented procedures reviewed: <Report Findings Here> 25-2 Not used in DMS 25-3 Not used in DMS 25-4 Not used in DMS 25-5 Not used in DMS 25-6 Not used in DMS 25-7 Not used in DMS 25-8 Not used in DMS 25-9 Not used in DMS

Modified p. 176 → 179

• Tamper-evident ~~and authenticable~~ package number (if applicable) 26-1.a Interview responsible personnel and examine documented procedures to determine the following:

• Tamper-evident package number (if applicable) 26-1.a Interview responsible personnel and examine documented procedures to determine the following:

Modified p. 176 → 179

• Logs must be archived for a minimum of two years subsequent to key destruction Personnel interviewed:

• Logs must be archived for a minimum of two years subsequent to key destruction Personnel interviewed: <Report Findings Here> Documented procedures reviewed: <Report Findings Here> 26-1.b Examine log files and audit log settings to verify that logs are kept for any time that keys, key components, or related materials are:

Removed p. 177

• Tamper-evident package number (if applicable) <Report Findings Here>

Modified p. 177 → 179

• Loaded to an SCD Log files ~~examined:~~ <Report Findings Here> Describe how ~~log files and~~ audit log settings verified that logs are kept for any time that keys, key components, or related materials are:

• Loaded to an SCD Log files reviewed: <Report Findings Here> Describe how the audit log settings observed verified that logs are kept for any time that keys, key components, or related materials are:

Modified p. 177 → 179

• Loaded to an SCD <Report Findings Here> ~~26-1.c Examine log files to verify they are:~~

• Loaded to an SCD <Report Findings Here>

Modified p. 177 → 180

• Archived for a minimum of two years subsequent to key ~~destruction.~~

• Archived for a minimum of two years subsequent to key destruction

Modified p. 177 → 180

• Securely stored Log files ~~examined:~~ <Report Findings Here> ~~Describe how the~~ log files ~~examined verified~~ that ~~they are archived for a minimum of two years subsequent to key destruction.~~

• Securely stored Log files reviewed: <Report Findings Here> 26-1.d Examine log files and audit log settings to verify that logs include the following:

Modified p. 177 → 180

• ~~Key component~~ identifier

• Key-component identifier

Modified p. 177 → 180

• ~~Key component~~ identifier

• Key-component identifier

Modified p. 177 → 180

• Tamper-evident and authenticable package number (if applicable) Log files ~~examined:~~ <Report Findings Here> Describe how ~~log files and~~ audit log settings verified that logs include the following:

• Tamper-evident and authenticable package number (if applicable) Log files reviewed: <Report Findings Here> Describe how the audit log settings observed verified that logs include the following:

Modified p. 178 → 180

27-1.a Interview responsible personnel and examine documented procedures and backup records to determine whether any backup copies of keys or their components exist. ~~Perform the following:~~

27-1.a Interview responsible personnel and examine documented procedures and backup records to determine whether any backup copies of keys or their components exist.

Modified p. 178 → 180

~~Responsible personnel interviewed:~~ <Report Findings Here> ~~Documented procedures examined:~~ <Report Findings Here> Backup records ~~examined:~~ <Report Findings Here> 27-1.b Observe backup processes to verify backup copies of secret and/or private keys are maintained in accordance with the same requirements as are followed for the primary keys.

Documented procedures reviewed: <Report Findings Here> Personnel interviewed: <Report Findings Here> Backup records reviewed: <Report Findings Here> 27-1.b Observe backup processes to verify backup copies of secret and/or private keys are maintained in accordance with the same requirements as are followed for the primary keys.

Modified p. 178 → 181

• Subject to at least the same level of security control as operational keys as specified in this document ~~Documented procedures examined: <Report Findings Here> Personnel interviewed: <Report Findings Here> OR~~ Describe how backup storage locations verified that backups are maintained as follows:

• Subject to at least the same level of security control as operational keys as specified in this document Describe how the backup storage locations observed verified that backups are maintained as follows:

Modified p. 178 → 181

• Subject to at least the same level of security control as operational keys as specified in this document <Report Findings Here>

• Subject to at least the same level of security control as operational keys as specified in this document <Report Findings Here> 27-2 If backup copies are created, the following must be in place:

Modified p. 179 → 181

• Creation (including cloning) of top-level keys

•e.g., MFKs

•must require a minimum of two authorized individuals to enable the process.

• Creation (including cloning) must require a minimum of two authorized individuals to enable the process.

Modified p. 179 → 181

• The creation of any backup copies ~~for top-level keys~~ requires at least two authorized individuals to enable the process.

• The creation of any backup copies requires at least two authorized individuals to enable the process.

Modified p. 179 → 181

• The creation of any backup copies ~~for top-level keys~~ requires at least two authorized individuals to enable the process

• The creation of any backup copies requires at least two authorized individuals to enable the process

Modified p. 180 → 182

• Management of personnel changes, including revocation of access control and other privileges when personnel move 28-1.a Examine documented procedures for ~~key- administration~~ operations to verify they ~~cover all activities related to key administration, and~~ include:

• Management of personnel changes, including revocation of access control and other privileges when personnel move 28-1.a Examine documented procedures for key-administration operations to verify they include:

Modified p. 180 → 182

• Background checks for personnel (within the constraints of local ~~laws)~~

• Background checks for personnel (within the constraints of local laws

Modified p. 180 → 182

• Management of personnel changes, including revocation of access control and other privileges when personnel move Documented procedures ~~examined:~~ <Report Findings Here> 28-1.b Interview personnel responsible for ~~key- administration~~ operations to verify that the documented procedures are known and understood.

• Management of personnel changes, including revocation of access control and other privileges when personnel move Documented procedures reviewed: <Report Findings Here> 28-1.b Interview personnel responsible for key-administration operations to verify that the documented procedures are known and understood.

Modified p. 180 → 182

Responsible personnel interviewed: <Report Findings Here>

Responsible personnel interviewed: <Report Findings Here> 28-1.c Interview personnel to verify that security-awareness training is provided for the appropriate personnel.

Modified p. 181 → 182

<Report Findings Here> 28-2 Not used in ~~EMS~~ 28-3 Not used in ~~EMS~~ 28-4 Not used in ~~EMS~~ 28-5 Not used in ~~EMS~~

Responsible HR personnel interviewed: <Report Findings Here> 28-2 Not used in DMS 28-3 Not used in DMS 28-4 Not used in DMS 28-5 Not used in DMS

Modified p. 182 → 183

• SCDs used for ~~key injection/loading~~ or code signing have not been substituted or subjected to unauthorized modifications or tampering.

• SCDs used for key-injection/loading or code signing have not been substituted or subjected to unauthorized modifications or tampering.

Modified p. 182 → 183

• SCDs used for ~~key injection/loading~~ or code signing have not been substituted or subjected to unauthorized modifications or tampering.

• SCDs used for key-injection/loading or code signing have not been substituted or subjected to unauthorized modifications or tampering.

Modified p. 182 → 183

Documented ~~procedures~~ reviewed: <Report Findings Here> 29-1.b Observe processes and interview personnel to verify that processes are followed to provide the following assurances prior to the loading of cryptographic keys:

Documented processes reviewed: <Report Findings Here> 29-1.b Observe processes and interview personnel to verify that processes are followed to provide the following assurances prior to the loading of cryptographic keys:

Removed p. 183

The minimum log contents include date and time, object name/identifier, purpose, name of individual(s) involved, signature or electronic capture (e.g., badge) of individual involved, and if applicable, tamper-evident package number(s) and serial number(s) of device(s) involved. Electronic logging e.g., using bar codes is acceptable for device tracking.

Modified p. 183 → 184

29-1.1 Examine documented procedures to verify controls are defined to protect POI ~~devices,~~ and other SCDs from unauthorized access up to point of deployment.

29-1.1 Examine documented procedures to verify controls are defined to protect POI devices and other SCDs from unauthorized access up to point of deployment.

Modified p. 183 → 184

Documented procedures reviewed: <Report Findings Here> 29-1.1.1 Access to all POI ~~devices,~~ and other SCDs is documented, defined, logged, and controlled such that unauthorized individuals cannot access, modify, or substitute any device without detection.

Documented procedures reviewed: <Report Findings Here> 29-1.1.1 Access to all POI devices and other SCDs is documented, defined, logged, and controlled such that unauthorized individuals cannot access, modify, or substitute any device without detection. The minimum log contents include date and time, object name/identifier, purpose, name of individual(s) involved, signature or electronic capture (e.g., badge) of individual involved and, if applicable, tamper-evident package number(s) and serial number(s) of device(s) involved. Electronic logging⎯e.g., using bar codes⎯is acceptable for device tracking.

Modified p. 183 → 184

29-1.1.1.a Examine access-control documentation and device configurations to verify that access to all POI devices and ~~key~~ injection/loading devices is defined and documented.

29-1.1.1.a Examine access-control documentation and device configurations to verify that access to all POI devices and key- injection/loading devices is defined and documented.

Removed p. 184

Sample of POI device types and other SCDs reviewed:

Modified p. 184 → 185

• All personnel with access to POI devices and other SCDs are ~~documented in a formal list~~ authorized by management in an auditable manner.

• All personnel with access to POI devices and other SCDs are authorized by management in an auditable manner.

Modified p. 185 → 186

~~Documented procedures~~ reviewed: <Report Findings Here> 29-1.2.b Observe implemented processes and interview personnel to verify that default keys or passwords are not used.

Documentation reviewed: <Report Findings Here> 29-1.2.b Observe implemented processes and interview personnel to verify that default keys or passwords are not used.

Modified p. 185 → 186

~~Responsible personnel interviewed:~~ <Report Findings Here> 29-2 Not used in ~~EMS~~

<Report Findings Here> 29-2 Not used in DMS

Removed p. 186

29-3.a Examine documented procedures to verify they require physical protection of devices from the manufacturer’s facility up to the point of key-insertion and deployment, through one or more of the defined methods.

Modified p. 186 → 187

• Physically secure and trackable packaging (e.g., pre-serialized, counterfeit-resistant, tamper-evident packaging) is ~~used.~~ The devices are then stored in such packaging, or in secure storage, until key-insertion occurs.

• Physically secure and trackable packaging (e.g., pre-serialized, counterfeit-resistant, tamper-evident packaging) is in use. The devices are then stored in such packaging, or in secure storage, until key-insertion occurs.

Modified p. 186 → 187

Note: Unauthorized access includes that by customs officials. o Devices incorporate self-tests to ensure their correct operation. Devices must not be re-installed unless there is assurance they have not been tampered with or compromised.

Note: Unauthorized access includes that by customs officials. o Devices incorporate self-tests to ensure their correct operation. Devices must not be re-installed unless there is assurance they have not been tampered with or compromised. (Note: this control must be used in conjunction with one of the other methods.) o Controls exist and are in use to ensure that all physical and logical controls and anti-tamper mechanisms used are not modified or removed.

Modified p. 186 → 187

~~Documented procedures reviewed:~~ <Report Findings Here>

Responsible personnel interviewed: <Report Findings Here>

Removed p. 187

Identify the P2PE Assessor who physically verified the dual-control mechanism used to prevent substitution or tampering of HSMs

•both in service and spare or back-up devices

Modified p. 187 → 188

Responsible personnel interviewed: <Report Findings Here> ~~29-4 Dual-control mechanisms must exist~~ to prevent substitution or tampering of HSMs •both deployed and spare or backup devices

•throughout their lifecycle. Procedural controls, which may be a combination of physical barriers and logical controls, may exist to support the prevention and detection of substituted HSMs, but cannot supplant the implementation of dual-control mechanisms.

Responsible personnel interviewed: <Report Findings Here> Identify the P2PE Assessor who physically verified the dual-control mechanism used to prevent substitution or tampering of HSMs

Modified p. 187 → 188

29-4.a Examine documented procedures to ~~verify~~ that dual-control mechanisms exist to prevent substitution or tampering of HSMs

•both deployed and spare or back-up devices

•throughout their life cycle.

29-4.a Examine documented procedures to confirm that dual-control mechanisms exist to prevent substitution or tampering of HSMs

•both deployed and spare or back-up devices

•throughout their life cycle.

Modified p. 187 → 188

Documented procedures ~~examined:~~ <Report Findings Here> 29-4.b Interview responsible personnel and physically verify the dual-control mechanism used to prevent substitution or tampering of HSMs

•both in service and spare or back-up devices

•throughout their life cycle.

Documented procedures reviewed: <Report Findings Here> 29-4.b Interview responsible personnel and physically verify the dual-control mechanism used to prevent substitution or tampering of HSMs

•both in- service and spare or back-up devices

•throughout their life cycle.

Modified p. 187 → 188

• ~~throughout~~ their life cycle:

• both in service and spare or back-up devices

•throughout their life cycle:

Removed p. 188

Documented procedures examined: <Report Findings Here> 29-4.1.b For a sample of received devices, examine sender documentation sent by a different communication channel than the device’s shipment (e.g., the manufacturer’s invoice or similar documentation) used to verify device serial numbers. Examine the record of serial- number validations to confirm the serial number for the received device was verified to match that documented by the sender.

Modified p. 188

Note: Documents used for this process must be received via a different communication channel•i.e., the control document used must not have arrived with the equipment. An example of how serial numbers may be documented by the sender includes but is not limited to manufacturer’s invoice or similar document.

Note: Documents used for this process must be received via a different communication channel•i.e., the control document used must not have arrived with the equipment. An example of how serial numbers may be documented by the sender includes but is not limited to the manufacturer’s invoice or similar document.

Modified p. 188

Sample of received devices: <Report Findings Here> Sender documentation/record of ~~serial~~ number validations reviewed:

Sample of received devices: <Report Findings Here> Sender documentation/record of serial- number validations reviewed:

Modified p. 189

29-4.2.a Obtain and ~~examine~~ the defined security policy to be enforced by the HSM.

29-4.2.a Obtain and review the defined security policy to be enforced by the HSM.

Modified p. 189

Documented security policy ~~examined:~~ <Report Findings Here> 29-4.2.b Examine documentation of the HSM configuration settings ~~from past commissioning events~~ to determine that the functions and ~~commands~~ enabled are in accordance with the security policy.

Documented security policy reviewed: <Report Findings Here> 29-4.2.b Examine documentation of the HSM configuration settings to determine that the functions and command authorized to be enabled are in accordance with the security policy.

Modified p. 189

HSM configuration settings documentation ~~examined:~~

HSM configuration settings documentation reviewed:

Modified p. 189

<Report Findings Here> 29-4.2.c For a sample of HSMs, ~~examine~~ the configuration settings to determine that only authorized functions are enabled.

<Report Findings Here> 29-4.2.c For a sample of HSMs, review the configuration settings to determine that only authorized functions are enabled.

Modified p. 189

<Report Findings Here> 29-4.2.d Not used in P2PE 29-4.2.e Not used in P2PE

<Report Findings Here> 29-4.2.d Not used in P2PE 29-4.2.e Not used in P2PE 29-4.2.f Examine documentation to verify:

Removed p. 190

Documentation examined: <Report Findings Here> 29-4.3 When HSMs are connected to online systems, controls are in place to prevent the use of an HSM to perform privileged or sensitive functions that are not available during routine HSM operations.

Note: Examples of sensitive functions include but are not limited to: loading of key components, outputting clear-text key components, and altering HSM configuration.

29-4.3 Examine HSM configurations and observe processes to verify that HSMs are not enabled in a sensitive state when connected to online systems.

Describe how the HSM configurations examined and processes observed verified that HSMs are not enabled in a sensitive state when connected to online systems:

<Report Findings Here> 29-4.4 Inspect and test all HSMs

•either new or retrieved from secure storage

•prior to installation to verify devices have not been tampered with or compromised.

Modified p. 190 → 189

Documented procedures ~~examined:~~ <Report Findings Here>

Documented procedures reviewed: <Report Findings Here>

Modified p. 190

Processes must ~~include :~~

Processes must include:

Modified p. 190

~~29-4.4.Examine~~ documented procedures to verify they require inspection and testing of HSMs prior to installation to verify the integrity of the device and include requirements specified at 29-4.4.1 through 29-4.4.4 below.

29-4.4 Examine documented procedures to verify they require inspection and testing of HSMs prior to installation to verify the integrity of the device and include requirements specified at 29-4.4.1 through 29-4.4.4 below.

Modified p. 191 → 190

~~29-.4.4.1~~ Examine records of device inspections and test results to verify that self-tests are run on devices to ensure the correct operation of the device.

Documented procedures reviewed: <Report Findings Here> 29-4.4.1 Running self-tests to ensure the correct operation of the device 29-4.4.1 Examine records of device inspections and test results to verify that self-tests are run on devices to ensure the correct operation of the device.

Modified p. 191 → 190

Records of device inspections ~~examined:~~ <Report Findings Here> Describe how ~~the~~ records of device inspections and test results ~~examined~~ verified that ~~self- tests~~ are run on devices to ensure the correct operation of the device:

Records of device inspections reviewed: <Report Findings Here> Describe how records of device inspections and test results verified that self-tests are run on devices to ensure the correct operation of the device:

Modified p. 191 → 190

<Report Findings Here> 29-4.4.2 Installing (or re-installing) devices only after confirming that the device has not been tampered with or compromised.

<Report Findings Here> 29-4.4.2 Installing (or re-installing) devices only after confirming that the device has not been tampered with or compromised 29-4.4.2 Observe inspection processes and interview responsible personnel to verify that devices are installed, or reinstalled, only after confirming that the device has not been tampered with or compromised.

Removed p. 192

Documented procedures examined: <Report Findings Here> 29-5.b Observe a sample of received devices to verify they are maintained in tamper-evident packaging until ready for installation.

Modified p. 192 → 191

29-4.4.4.a Examine records of inspections and interview responsible personnel to verify records of the tests and inspections are maintained.

<Report Findings Here> 29-4.4.4 Maintaining records of the tests and inspections, and retaining records for at least one year 29-4.4.4.a Examine records of inspections and interview responsible personnel to verify records of the tests and inspections are maintained.

Modified p. 192 → 191

Records of inspections examined: <Report Findings Here> 29-5 Maintain HSMs in tamper-evident packaging or in secure storage until ready for installation.

Records of inspections examined: <Report Findings Here> 29-5 Maintain HSMs in tamper-evident packaging or in secure storage until ready for installation 29-5.a Examine documented procedures to verify they require devices be maintained in tamper-evident packaging until ready for installation.

Modified p. 192 → 191

~~29-5.a Examine documented~~ procedures to verify they ~~require devices be~~ maintained in tamper-evident packaging until ready for installation.

Documented procedures reviewed: <Report Findings Here> 29-5.b Observe a sample of received devices to verify they are maintained in tamper-evident packaging until ready for installation.

Modified p. 192 → 191

Sample of received devices reviewed: <Report Findings Here> 30-1 Not used in P2PE 30-2 Not used in P2PE

Sample of received devices reviewed: <Report Findings Here> 30-1 Not used in P2PE 30-2 Not used in P2PE 30-3 Not used in DMS

Removed p. 193

• are not intercepted or used in an unauthorized manner, including rendering all secret and private keys, key material, and account data stored within the device irrecoverable.

• Procedures require that all secret and private keys, key material, and all account data stored within the device be securely destroyed.

• Procedures cover all devices removed from service permanently or for repair.

Modified p. 193 → 192

~~Documented procedures examined:~~ <Report Findings Here>

Modified p. 193 → 192

• Procedures require that all secret and private ~~keys,~~ key ~~material, and all account data~~ stored within the device be securely destroyed.

• Procedures require that all secret and private keys and key material stored within the device be securely destroyed.

Modified p. 193 → 192

• Procedures cover all devices removed from service ~~permanently~~ or for repair.

• Procedures cover all devices removed from service or for repair.

Modified p. 193 → 192

• Procedures cover requirements at 31-1.1 through ~~31- 1.6~~ below.

• Procedures cover requirements at 31-1.1 through 31-1.6 below.

Removed p. 194

<Report Findings Here> 31-1.2 Keys and account data are rendered irrecoverable (e.g., zeroized) for SCDs. If data cannot be rendered irrecoverable, devices must be physically destroyed under dual control to prevent the disclosure of any sensitive data or keys.

Modified p. 194 → 192

31-1.1.a Examine documented procedures for removing ~~HSMs~~ from service to verify that dual control is implemented for all critical decommissioning processes.

31-1.1.a Examine documented procedures for removing HSM from service to verify that dual control is implemented for all critical decommissioning processes.

Modified p. 194 → 192

Documented procedures ~~examined:~~ <Report Findings Here> 31-1.1.b Interview personnel and observe demonstration (if HSM is available) of processes for removing ~~HSMs~~ from service to verify that dual control is implemented for all critical decommissioning processes.

Documented procedures reviewed: <Report Findings Here> 31-1.1.b Interview personnel and observe demonstration (if HSM is available) of processes for removing HSM from service to verify that dual control is implemented for all critical decommissioning processes.

Modified p. 194 → 192

Personnel interviewed: <Report Findings Here> Describe how the demonstration ~~observed~~ verified that dual control is implemented for all critical decommissioning ~~processes.~~

Personnel interviewed: <Report Findings Here> Describe how the demonstration verified that dual control is implemented for all critical decommissioning processes:

Modified p. 194 → 193

31-1.2 Interview personnel and observe demonstration of processes for removing SCDs from service to verify that all keying material ~~and account data are~~ rendered irrecoverable (e.g., zeroized), or that devices are physically destroyed under dual control to prevent the disclosure of any sensitive data or keys.

31-1.2 Interview personnel and observe demonstration of processes for removing SCDs from service to verify that all keying material is rendered irrecoverable (e.g., zeroized), or that devices are physically destroyed under dual control to prevent the disclosure of any sensitive data or keys.

Modified p. 194 → 193

Personnel interviewed: <Report Findings Here> Describe how the demonstration verified that all keying material and account data ~~are~~ rendered irrecoverable, or that devices are physically destroyed under dual control to prevent the disclosure of any sensitive data or keys:

Personnel interviewed: <Report Findings Here> Describe how the demonstration verified that all keying material and account data is rendered irrecoverable, or that devices are physically destroyed under dual control to prevent the disclosure of any sensitive data or keys:

Modified p. 195 → 193

31-1.3 Interview personnel and observe processes for removing SCDs from service to verify that tests and inspections of devices are performed to confirm that keys ~~and account data~~ have been rendered ~~irrecoverable.~~

31-1.3 Interview personnel and observe processes for removing SCDs from service to verify that tests and inspections of devices are performed to confirm that keys have been rendered irrecoverable or the devices are physically destroyed.

Removed p. 196

Personnel interviewed: <Report Findings Here> Records of testing examined: <Report Findings Here> 32-1 For HSMs and other SCDs used for the generation or loading of cryptographic keys for use in POI devices, or for signing applications and/or whitelists to be loaded into POI devices, procedures must be documented and implemented to protect against unauthorized access and use.

Required procedures and processes include the following:

32-1.a Examine documented procedures to confirm that they specify protection against unauthorized access and use for HSMs and other devices used for the generation or loading of cryptographic keys for use in POI devices, or for signing applications and/or whitelists to be loaded into POI devices.

Documented procedures reviewed: <Report Findings Here> 32-1.b Verify that documented procedures cover requirements 32-1.1 through 32-1.5 below.

Removed p. 197

Note: Dual control consists of logical and/or physical characteristics. For example, dual control may be implemented for logical access via two individuals with two different passwords/authentication codes (at least five characters in length), or for physical access via a physical lock that requires two individuals each with a different high-security key.

For devices that do not support two or more passwords/authentication codes, this may be achieved by splitting the single password used by the device into two halves, each half controlled by a separate authorized custodian. Each half must be a minimum of five characters.

Physical keys, authorization codes, passwords/authentication codes, or other enablers must be managed so that no one person can use both the enabler(s) and the device, which can create cryptograms of known keys or key components under a key-encipherment key used in production.

32-1.1 Observe dual-control mechanisms and device- authorization processes to confirm that logical and/or physical characteristics are …

Removed p. 198

• To enable any manual key-encryption functions and any key-encryption functions that occur outside of normal transaction processing;

• To enable application-signing functions;

• To place the device into a state that allows for the input or output of clear-text key components;

• For all access to key-loading devices (KLDs) and authenticated application-signing devices.

32-1.3 Examine dual-control mechanisms and observe authorized personnel performing the defined activities to confirm that dual control is implemented for the following:

• To enable any manual key-encryption functions, and any key-encryption functions that occur outside of normal transaction processing

• To enable any manual key-encryption functions, and any key-encryption functions that occur outside of normal transaction processing

• To enable application-signing functions

• To enable application-signing functions

• To place the device into a state that allows for the input or output of clear-text key components

• To place the device into a state that allows for the input or output of clear-text key components

• …

Removed p. 199

32-1.4.a Examine password policies and documented procedures to confirm default passwords/authentication codes must not be used for HSMs, KLDs, and other SCDs used to generate or load cryptographic keys, or to sign applications or whitelists.

Documented procedures and password policies reviewed:

<Report Findings Here> 32-1.4.b Observe device configurations and interview device administrators to verify that HSMs, KLDs and other SCDs used to generate or load cryptographic keys, or to sign applications or whitelists, do not use default passwords /authentication codes.

Device administrators interviewed: <Report Findings Here> Describe how the device configurations observed verified that HSMs, KLDs and other SCDs used to generate or load cryptographic keys, or to sign applications or whitelists, do not use default passwords:

Removed p. 200

• Locked in a secure cabinet and/or sealed in tamper-evident packaging, or

• Under the continuous supervision of at least two authorized people who ensure that any unauthorized use of the device would be detected.

Note: For key-injection facilities, or applicable entities providing key-management services, POI devices may be secured by storage in the dual-control access key injection room.

32-1.5.a Examine and confirm documented procedures require devices are within a secure room and are either:

• Locked in a secure cabinet and/or sealed in tamper- evident packaging at all times, or

• Locked in a secure cabinet and/or sealed in tamper- evident packaging at all times, or

Removed p. 200

Documented procedures reviewed: <Report Findings Here> 32-1.5.b Interview responsible personnel and observe devices and processes to confirm that devices are at all times within a secure room and either:

Responsible personnel interviewed: <Report Findings Here> Describe how devices are at all times within a secure room and either:

• Locked in a secure cabinet and/or sealed in tamper-evident packaging at all times, or

<Report Findings Here> 32-2 Not used in EMS 32-3 Not used in EMS 32-4 Not used in EMS 32-5 Not used in EMS 32-6 Not used in EMS 32-7 Not used in EMS

Removed p. 201

Documented procedures examined: <Report Findings Here> 33-1.b Verify that written records exist for the tests and inspections performed on devices before they are placed into service, as well as devices being decommissioned.

Modified p. 201 → 195

33-1.a Examine documented procedures/processes and interview responsible personnel to verify that all affected parties are aware of required processes and are provided suitable guidance on procedures for ~~account-data processing~~ devices placed into service, initialized, deployed, used, and decommissioned.

33-1.a Examine documented procedures/processes and interview responsible personnel to verify that all affected parties are aware of required processes and are provided suitable guidance on procedures for devices placed into service, initialized, deployed, used, and decommissioned, Documented procedures reviewed: <Report Findings Here> Responsible personnel interviewed: <Report Findings Here> 33-1.b Verify that written records exist for the tests and inspections performed on devices before they are placed into service, as well as devices being decommissioned.

Modified p. 203 → 196

• Crypto-periods are based on industry best practices and guidelines (e.g., NIST Special Publication ~~800- 57).~~

• Crypto-periods are based on industry best practices and guidelines (e.g., NIST Special Publication 800-57).

Modified p. 203 → 196

• Cryptographic key changes are implemented whenever a key reaches the end of its defined ~~crypto- period.~~

• Cryptographic key changes are implemented whenever a key reaches the end of its defined crypto-period.

Modified p. 203 → 196

<Report Findings Here> 5A-1.2.b Through observation of key-management operations and inspection of SCDs, verify that ~~crypto- periods~~ are defined for every type of key in use.

<Report Findings Here> 5A-1.2.b Through observation of key-management operations and inspection of SCDs, verify that crypto-periods are defined for every type of key in use.

Modified p. 204 → 197

5A-1.3.a Verify documentation exists describing the architecture (including all participating devices and cryptographic protocols), set-up and operation of the ~~key- management~~ solution.

5A-1.3.a Verify documentation exists describing the architecture (including all participating devices and cryptographic protocols), set-up and operation of the key-management solution.

Modified p. 206 → 198

• Key-destruction method Documentation reviewed: <Report Findings Here> Personnel interviewed: <Report Findings Here> ~~5A-1.3.2 Maintain a list of all devices used to generate keys or key components managed as part of the P2PE solution, including:~~

• Key-destruction method Documentation reviewed: <Report Findings Here> Personnel interviewed: <Report Findings Here>

Removed p. 207

<Report Findings Here> 5H-1 Not used in EMS 5I-1 Not used in EMS

Modified p. 207 → 199

• Approved key-generation function (PTS, FIPS, or other approved per NIST SP800-22) Documentation reviewed: <Report Findings Here> Personnel interviewed:

• Approved key-generation function (PTS, FIPS, or other approved per NIST SP800-22) Documentation reviewed: <Report Findings Here> Personnel interviewed: <Report Findings Here>

Document Comparison

Content Changes