All Your Virtualized PCI Compliance Are Belong To Us…
Another interesting example I use in my VirtSec presentations when discussing the challenges of what I describe as Phase 2 of virtualization — virtualizing critical applications and things like Internet-facing infrastructure in DMZ’s — is the notion of compliance failures based on existing and upcoming revisions to regulatory requirements.
Specifically, I use PCI/DSS to illustrate that in many cases were one to take a highly-segmented and stratified "defense-in-depth" architecture that is today "PCI compliant" and virtualize it given presently available options, you’d likely find yourself out of compliance given the current state of technology solutions and auditing standards used to assess against.
Then again, you might just pass with flying colors while being totally insecure.
Here’s a fantastic example from Eric Siebert over at the TechTarget Virtualization blog. Check this out, it’s a doozie!
Having just survived another annual PCI compliance audit, I was again surprised that the strict standards for securing servers that must be followed contain nothing specific concerning virtual hosts and networks. Our auditor focused on guest virtual machines (VMs), ensuring they had up-to-date patches, locked-down security settings and current anti-virus definitions. But ironically, the host server that the virtual machines were running on went completely ignored. If the host server was compromised, it wouldn’t matter how secure the VMs were because they could be easily accessed. Host servers should always be securely locked down to protect the VMs which are running on them.
It seems that much of the IT industry has yet to react to the virtualization trend, having been slow in changing procedures to adjust to some of the unconventional concepts that virtualization introduces. When I told our auditor that the servers were virtual, the only thing he wanted to see was some documentation stating that the remote console sessions to the VMs were secure. It’s probably just a matter of time before specific requirements for virtual servers are introduced. In fact, a recent webinar takes up this issue of whether or not virtualized servers can be considered compliant, addressing section 2.2.1 of the PCI DSS which states, “Implement only one primary function per server”; that is to say, web servers, database servers and DNS should be implemented on separate servers. Virtual servers typically have many functions running on a single physical server, which would make them noncompliant.
So let’s assume that what Eric talks about in section 2.2.1 of PCI/DSS holds true, that basically means two things: (1) PCI/DSS intimates that virtualization cannot provide the same level of security as non-virtualized infrastructure and (2) you won’t be able to virtualize infrastructure governed by PCI/DSS if you expect to be compliant.
Now, this goes toward the stuff Mogull and I were talking about in terms of assessing risk and using the notion of "zone defense" for asset segmentation in virtualized infrastructure.
Here’s a snippet from my VirtSec preso on the point:
Further, as I mentioned in my post titled "Risky Business — The Next Audit Cycle: Bellweather Test for Critical Production Virtualized Infrastructure," this next audit cycle is going to be interesting for many companies…