PCI DSS 4.0.1 Transition for a Payments Processor
Cardholder data environment cut by 61%, and every future-dated requirement in place before the deadline.
Client name withheld by agreement- Client
- Payment processor, 2B+ transactions a year
- Region
- U.S. Southwest
- Year
- 2025
- Duration
- 18 weeks
- Scope
- 1,100 in-scope systems · 9 data flows
- Practice
- Financial Services
The challenge
What was at stake.
A payment processor handling more than two billion transactions a year faced the PCI DSS 4.0.1 future-dated requirements with a cardholder data environment that had grown by acquisition. Nobody could say with confidence where card data lived.
Every extra system in scope meant more cost, more evidence and more risk. The CFO wanted scope smaller. The CISO wanted it right.
What we did
The approach, step by step.
- 01
Find every card number
Automated card-data discovery across databases, file shares, logs and cloud storage, validated by hand, produced the first trustworthy data-flow map in years.
- 02
Shrink the environment
Tokenization at two ingestion points and new segmentation between legacy and modern platforms took entire networks out of scope.
- 03
Future-dated requirements, done early
Targeted risk analyses, authenticated internal scanning, payment-page script control and phishing-resistant MFA were designed, implemented and evidenced.
- 04
Assessor-ready evidence
Every requirement mapped to an owner, a control and a dated artifact, organized the way an assessor reads it.
Outcomes
What changed, in numbers.
- 61%
- reduction in the cardholder data environment
- 1,100
- in-scope systems reviewed
- 9
- card data flows documented and validated
- 0
- future-dated requirements outstanding at deadline
Our scope went down, our evidence went up, and our assessment was the calmest one we have had.
Services delivered
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