I too was wondering how much of a boon 6.6 would be to the WAF vendors and/or 
the companies that do security code reviews. That is, until 4/22, when the PCI 
SSC issued a press release 
(https://www.pcisecuritystandards.org/pdfs/04-22-08.pdf) announcing an 
information supplement clarifying requirement 6.6 
(https://www.pcisecuritystandards.org/pdfs/infosupp_6_6_applicationfirewalls_codereviews.pdf).

Clearly, completing security code reviews on all of those web applications 
and/or protecting them with those expensive "magic pizza boxes,"  which, last 
time that I checked (almost 2 years ago now) were running about $35K to start, 
wasn't going to happen any time soon. 

The good news from that "information supplement" is that the PCI Security 
Standards Council defined what they mean by an application firewall and 
specified what it is supposed to do; the less good news is that they specified 
4 alternative methods for satisfying the code review option: 1. manual security 
code review, 2. automated security code review, 3. manual web application 
vulnerability scan, and 4. automated web application vulnerability scan. While 
I think automation of code reviews and vulnerability scans is essential, I also 
believe that none of the automated tools are yet sufficient (completeness-wise) 
without some additional manual effort.

So, unfortunately for the WAF vendors, people can just use a static source code 
analysis tool or a web application vulnerability scanner instead of purchasing 
and deploying a WAF.

Michael

> Date: Mon, 30 Jun 2008 09:17:34 -0500
> From: [EMAIL PROTECTED]
> To: [EMAIL PROTECTED]
> CC: SC-L@securecoding.org
> Subject: Re: [SC-L] InternetNews Realtime IT News - Merchants Cope With PCI 
> Compliance
> 
> for the vast majority of the profession - slamming the magic pizza box in a 
> rack 
> is more preferable than talking to developers. in many cases the biggest 
> barrier 
> to getting better security in companies is the so-called information security 
> group. it has very little to do with technology, its a people problem.
> 
> -gp
> 
> Kenneth Van Wyk wrote:
> > Happy PCI-DSS 6.6 day, everyone.  (Wow, that's a sentence you don't hear 
> > often.)
> > 
> > http://www.internetnews.com/ec-news/article.php/3755916
> > 
> > In talking with my customers over the past several months, I always find 
> > it interesting that the vast majority would sooner have root canal than 
> > submit their source code to anyone for external review.  I'm betting PCI 
> > 6.6 has been a boon for the web application firewall (WAF) world.
> > 
> > 
> > Cheers,
> > 
> > Ken
> > 
> > -----
> > Kenneth R. van Wyk
> > SC-L Moderator
> > KRvW Associates, LLC
> > http://www.KRvW.com
> > 
> > 
> > 
> > 
> > ------------------------------------------------------------------------
> > 
> > _______________________________________________
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