[email protected] (Charles Mills) writes:
> I think much of the problem is with credit card numbers
> themselves. There are only ~10**16 possible credit card numbers --
> many fewer if you allow for the fact that only certain combinations
> are valid. A credit card number is easier to brute-force guess than
> its encryption key, format-preserving or not.

trivia/background

long ago and far away we got called as consultants to small
client/server startup that wanted to do payment transactions on their
server, they had also invented this technology called "SSL" they wanted
to use; the result is now sometimes called "electronic commerce".

Then somewhat having done "electronic commerce", in the mid-90s we were
asked to participate in the (financial industry) x9a10 standards working
group which had been given the requirement to preserve the integrity of
the financial infrastructure for all retail payments (not just internet,
*ALL*, point-of-sale, attended, unattended, credit, debit, ACH,
i.e. *ALL*).

part of this is we did end-to-end threat analysis and attetmpted to use
a number of metaphors to characterize the existing paradigm:

dual-use ... since information from previous transactions can be used
for fraudulent transactions, that information has to be kept totally
confidential and never divulged. at the same time the same information
is required in dozens of business processes at millions of locations
around the world. we've periodically commented that even if the planet
was buried under miles of information hiding encryption, it still
wouldn't stop leakage

security proportional to risk ... the value of the transaction
information to the merchants is the profit on the transactions, which
can be a couple dollars (and a couple cents for the transaction
processor) ... the value of the information to the crooks is the account
balance and/or credit limit ... as a result the crooks can afford to
outspend the defenders by a factor of 100 times.

...

the x9a10 financial standard working group came up with a transaction
standard that eliminated the "dual-use" characteristic of the account
number ... which met that it no longer needed to be kept hidden (and the
earlier work we did on "electronic commerce" was the major use of "SSL"
for hiding the account number ... which in the new transaction standard
was no longer necessary).

Later we were tangentially involved in the cal. state data breach
notification law. A lot of the participants were heavily involved in
privacy issues and had done detailed, in-depth public surveys. The #1
issue was identity theft, primarily of the form of fraudulent financial
transactions as the result of breaches and there was little or nothing
being done about the breaches. An issue is typically an
entity/institution takes security measures in self protection, In the
case of the breaches, the institution wasn't at risk ... it was their
customers. It was hoped that the publicity from the breach notifications
would prompt breach countermeasures.

Note in the years since the cal. state breach notification act there
have been numerous federal (state preemption) acts introduced ... about
evenly divided between those similar to the cal. act and those that
would effectively eliminate any requirement for notification (frequently
ingeniously disguised as criteria on when notification was
required). The PCI DSS specification came out after the appearance of
the cal. state data breach notification and referenced by federal
legislation attempting to eliminate notification requirements
... "because the industry was addressing the problem". Early jokes about
the PCI DSS certification was that it was relatively straight-forward
... but everybody with PCI DSS certification that had a breach would
have their certification revoked.

-- 
virtualization experience starting Jan1968, online at home since Mar1970

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