The singular focus on card-level fraud leaves a key gap in today’s EMV implementations. EMV does not address merchant-specific risks such as the interception of card numbers in transmission on the merchant network or attacks against repositories of card information within the merchant, acquirer, processor, network or issuer environment. The PCI Security Standards Council notes: “in EMV environments, the PAN [primary account number] is not kept confidential at any point in the transaction.”4 The largest breaches of card information in the U.S. have come from vulnerabilities within the merchant or processor environment that EMV does not address.
Currently, in the majority of both EMV and non-EMV transactions, payment card information is sent from the point-of-capture to the acquirer/processor “in the clear,” i.e., in an unencrypted form. Historically, when the majority of transactions traversed private phone lines, this was less problematic. However, as more and more terminals and point-of-sale systems have begun using Internet technology for data transmission, the ability to capture that data “in flight” has been exploited by criminals to steal millions of card numbers from unsuspecting merchants. While a dynamic cryptogram provides some level of protection, the payment card information still travels in the clear and could theoretically be counterfeited onto a magnetic stripe or used in a card-not-present environment. The primary method of eliminating this form of attack is to encrypt the payment card information at the point-of-capture, rendering the data unusable to thieves.
Another key point of exposure is that many merchants retain payment card data after the transaction in long-term data stores. Small merchants hold hundreds of card numbers on their terminals or in their point-of-sale systems. Large retailers have data warehouses containing hundreds of millions of card numbers that they use for marketing and analysis of customer purchasing behavior. The massive volume and value of this information makes these data stores a prime target for criminals.