Attestation of Compliance
In the context of cybersecurity, an Attestation of Compliance (AOC) is a formal document or a written statement that an organization has successfully met all the requirements of a specific security standard or regulation. It serves as a declaration by a qualified third party or a senior officer of the organization that a self-assessment or audit has been completed and that the organization's security controls are in place and are effective.
For standards like the Payment Card Industry Data Security Standard (PCI DSS), an AOC is the official proof of compliance. It is signed by a Qualified Security Assessor (QSA) after a formal audit, or by a senior executive of the company (if they are a smaller merchant performing a Self-Assessment Questionnaire, or SAQ). The AOC is a critical piece of evidence that demonstrates to business partners, card brands, and other stakeholders that the organization has implemented the necessary security measures to protect sensitive data, such as payment card information.
The document typically includes:
A summary of the organization’s CDE (Cardholder Data Environment) and its scope.
The version of the security standard that the organization is attesting to.
A declaration of the compliance status (e.g., compliant, non-compliant, or compliant with a plan of action).
The signature of the authorized party confirms the accuracy of the information provided.
The AOC is the final step in a compliance validation process. It provides a definitive statement of an organization's security posture against a recognized standard, offering a level of assurance that the organization has taken appropriate steps to mitigate cybersecurity risks.
ThreatNG, an all-in-one solution for external attack surface management, digital risk protection, and security ratings, can significantly help organizations produce a credible and defensible Attestation of Compliance (AOC). While ThreatNG does not generate the AOC document itself, it provides the critical, continuous, and attacker-centric intelligence that empowers a QSA to confidently attest that a client has met all PCI DSS requirements.
External Discovery & Continuous Monitoring
The AOC is a formal declaration that the CDE (Cardholder Data Environment) is secure, and its validity hinges on having a complete and accurate scope. ThreatNG's external discovery and continuous monitoring capabilities are crucial for ensuring that nothing is missed.
ThreatNG performs purely external, unauthenticated discovery, identifying assets and risks from an attacker's perspective without needing connectors. This helps organizations discover unknown or rogue assets, or "shadow IT", that may inadvertently fall within the PCI DSS scope. This capability directly enhances the accuracy of the inventory required by PCI DSS Requirement 1.4.2.
ThreatNG continuously monitors an organization's external attack surface, digital risk, and security ratings. This ensures that new exposures or changes to existing assets that could impact compliance are immediately identified and brought into the scope of the AOC, preventing a "snapshot-in-time" assessment from becoming outdated.
ThreatNG's external assessment capabilities provide a broad, attacker-centric evaluation of an organization's security posture, giving a QSA the evidence needed to back up the claims made in an AOC.
Web Application Hijack Susceptibility: ThreatNG analyzes external web applications to identify potential entry points for attackers. This helps validate a client's compliance with PCI DSS Requirement 6.4.3 (protecting public-facing applications). For example, if ThreatNG finds that a subdomain is "Missing Content Security Policy", it signals a vulnerability that could facilitate malware injection via XSS. This finding provides a QSA with concrete evidence to validate whether a client's application security controls are genuinely adequate.
Cloud and SaaS Exposure: ThreatNG evaluates cloud and Software-as-a-Service (SaaS) solutions for misconfigurations. Discovering "Files in Open Cloud Buckets" directly validates a security gap impacting PCI DSS requirements, such as 3.1.1 (data retention) and 7.2.1 (restricting access). A QSA can use this finding to challenge a client's compliance claims and ensure these critical risks are addressed before signing the AOC.
Breach & Ransomware Susceptibility: ThreatNG calculates susceptibility based on external intelligence, including "Ransomware Events" and "Compromised Credentials". This intelligence provides a QSA with a realistic view of a client’s preparedness, allowing them to assess if the incident response plan (PCI DSS 12.10.5) is truly ready for "real-world, current threats".
ThreatNG's reports are specifically designed to aid in the compliance process, making them invaluable for a QSA.
ThreatNG provides "External GRC Assessment Mappings (e.g., PCI DSS)", which directly translates external findings into relevant compliance requirements. This feature saves a QSA from the manual effort of mapping risks to controls, streamlining the audit process.
Reports also include "Security Ratings" and "Positive Security Indicators". A QSA can use these to validate the presence and effectiveness of a client's security controls (e.g., WAFs or multi-factor authentication) from an external perspective, providing objective evidence to support the AOC.
Investigation Modules & Intelligence Repositories
These deep-dive capabilities provide the tangible evidence needed to either support or challenge a client's compliance claims.
Sensitive Code Exposure: ThreatNG identifies "Code Secrets Found," including API keys and credentials, in public code repositories. The discovery of such an exposure provides a QSA with a critical finding that would directly undermine claims of compliance with PCI DSS 6.6 (secure web applications) and 3.2 (not storing sensitive authentication data).
Dark Web Presence: ThreatNG’s Dark Web intelligence includes "Compromised Credentials (DarCache Rupture)" and "Ransomware Groups and Activities (DarCache Ransomware)". A QSA can leverage this intelligence to verify that a client's security policies and access controls (PCI DSS 8.3.1) are robust and that their incident response plan (PCI DSS 12.10.5) is adequate to handle a real-world credential breach.
Vulnerability Intelligence (DarCache Vulnerability): This repository goes beyond a basic CVSS score by integrating EPSS and KEV data. This allows a QSA to verify that a client's vulnerability management program is not just compliant on paper but is actively prioritizing and remediating the vulnerabilities that are most likely to be exploited, which is the true goal of PCI DSS Requirement 6.2.3.
Working with Complementary Solutions
ThreatNG's frictionless, external intelligence can be integrated with a client's existing security solutions to create a more robust security program that genuinely supports the claims made in an AOC.
Vulnerability Management (VM) Platforms: ThreatNG can flag an exposed web application with a critical vulnerability. This finding can be pushed to a VM platform to initiate a deeper, authenticated scan of the application's internal components. This combined approach ensures all vulnerabilities that could expose the CDE are identified and remediated, providing a more thorough basis for the AOC.
Security Information and Event Management (SIEM) Systems: ThreatNG's findings, such as "Admin Page References" or "Custom Port Scan" results, can be fed into a client's SIEM. The SIEM can then correlate these external insights with internal log data to detect suspicious access attempts, supporting compliance with PCI DSS 10.2.1 and 10.6.1.
ThreatNG serves as a powerful and indispensable partner for QSAs. It provides the continuous, real-world intelligence needed to move beyond a "check-the-box" audit and produce a more accurate, defensible, and credible Attestation of Compliance. By using ThreatNG, a QSA can mitigate their own "reputational risk" by ensuring that their client's external posture genuinely aligns with the security they are attesting to.
