💳PCI DSS 3.5Rule: PCI-3-5critical

PAN Protection

Description

Primary Account Number (PAN) must be protected wherever stored using strong cryptography (encryption, truncation, tokenization, or hashing).

⚠️ Risk Impact

Stored PAN is the highest-value target in the CDE. PCI specifically requires PAN to be unreadable; reading-allowed storage is immediate fail.

🔍 How EchelonGraph Detects This

PCI-3-5Automated scanner rule

EchelonGraph's Tier 1 Cloud Scanner automatically checks for this condition across all connected cloud accounts. Violations are flagged as critical-severity findings with remediation guidance.

🔧 Remediation

Tokenize PANs at ingress. Use cloud-managed KMS for encryption. Never log raw PAN. Truncate to first-6 + last-4 for display. Audit all PAN storage locations.

💀 Real-World Attack Scenario

A payment processor logged full PAN in their application logs 'for debugging'. The logs were shipped to a centralized SIEM. A SIEM-admin's credentials were phished; the attacker downloaded 8 months of logs containing millions of full PANs. Notification cost: $145/record × 2.4M records = $348M.

💰 Cost of Non-Compliance

Average PAN-exposure breach: $115-$200/record (varies by region + brand). 2.4M-record breach: $276M-$480M.

📋 Audit Questions

  • 1.Where is PAN stored?
  • 2.Is PAN tokenized at ingress?
  • 3.What truncation/encryption is applied at storage?
  • 4.Does any log file contain full PAN?

🎯 MITRE ATT&CK Mapping

T1530 — Data from Cloud StorageT1567 — Exfiltration Over Web Service

⚡ Common Pitfalls

  • Full PAN logged 'for debugging' + log files retained indefinitely
  • Tokenization vendor's tokens stored alongside the tokenization key
  • Truncation to first-6 + last-4 stored in same column as full PAN

📈 Business Value

Tokenization eliminates PAN exposure entirely + reduces PCI audit scope.

⏱️ Effort Estimate

Manual

60-120 hours tokenization rollout per system

With EchelonGraph

EchelonGraph scans for PAN patterns in logs + storage

🔗 Cross-Framework References

SOC2-CC6.7ISO27001-A.10.1.1

Automate PCI DSS 3.5 compliance

EchelonGraph continuously monitors this control across all your cloud accounts.

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