The following specifies what you can and can't do with FTP (Link is from the 
PCI SSC site - FAQ section):

http://selfservice.talisma.com/display/2n/index.aspx?c=58&cpc=MSdA03B2IfY15uvLEKtr40R5a5pV2lnCUb4i1Qj2q2g&cid=81&cat=&catURL=&r=0.577978789806366

Is it permissible to use FTP if proper security measures are implemented?

PCI DSS requirement 1.1.7 states that any risky protocols such as FTP must have 
documentation in place that defines the business justification for use and that 
appropriate security measures must be implemented. For example, secure FTP 
should be used, and FTP passwords and TELNET passwords used for non-console 
administrative access should be encrypted in transmission and in storage as 
prescribed in PCI DSS requirement 8.4 and 2.3 respectively. The documentation 
as well as implemented security measures should be reviewed by a Qualified 
Security Assessor (QSA) to ensure full effectiveness. The QSA will determine, 
among other things, that the selected approach is robust enough to withstand 
common attacks. For questions about whether a specific implementation is 
consistent with the standard or is "compliant" with a requirement, please 
contact a Qualified Security Assessor (QSA). A list of QSAs can be found at 
www.pcisecuritystandards.org/pdfs/pci_qsa_list.pdf<http://www.pcisecuritystandards.org/pdfs/pci_qsa_list.pdf>.


As Rob Schramm noted, FTP is called out in the PCI DSS 1.2.1 Standard:

Requirement 1.1.5, and Test 1.1.5b

1.1.5.b Identify insecure services, protocols, and ports allowed; and verify 
they are necessary and that security features are documented and implemented by 
examining firewall and router configuration standards and settings for each 
service. An example of an insecure service, protocol, or port is FTP, which 
passes user credentials in clear-text.

Requirement 2.2.2 and Test 2.2.2

2.2.2 For a sample of system components, inspect enabled system services, 
daemons, and protocols. Verify that unnecessary or insecure services or 
protocols are not enabled, or are justified and documented as to appropriate 
use of the service. For example, FTP is not used, or is encrypted via SSH or 
other technology.

More generally however, its ALL of Requirement 4 of the standard applies: 
Requirement 4: Encrypt transmission of cardholder data across open, public 
networks

e.g. Requirement 4.1 and Test 4.1.a

4.1.a Verify the use of encryption (for example, SSL/TLS or IPSEC) wherever 
cardholder data is transmitted or received over open, public networks

 *   Verify that strong encryption is used during data transmission
 *   For SSL implementations:
*         Verify that the server supports the latest patched versions.
*         Verify that HTTPS appears as a part of the browser Universal Record 
Locator (URL).
*         Verify that no cardholder data is required when HTTPS does not appear 
in the URL.

 *   Select a sample of transactions as they are received and observe 
transactions as they occur to verify that cardholder data is encrypted during 
transit.
 *   Verify that only trusted SSL/TLS keys/certificates are accepted.
 *   Verify that the proper encryption strength is implemented for the 
encryption methodology in use.

(Check vendor recommendations/best practices.)
--
...phsiii

Phil Smith III
p...@voltage.com
Voltage Security, Inc.
www.voltage.com
(703) 476-4511 (home office)
(703) 568-6662 (cell)

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