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Case Study

15,000 Employees. Millions of Cardholders. A US Bank's Path to PCI DSS 4.0 Compliance.

How Encryption Consulting assessed a leading US retail bank’s cryptographic infrastructure, uncovered critical compliance gaps, and delivered a remediation roadmap that reduced data breach risk by 58% — achieving PCI DSS 4.0 alignment.
15,000 Employees. Millions of Cardholders. A US Bank’s Path to PCI DSS 4.0 Compliance.

Customer Profile

A prominent US retail bank with 15,000+ employees, a nationwide network of branches and ATMs, and millions of customers. It offers personal banking, credit cards, loans, and wealth management, with a decade of rapid growth driven by digital innovation — mobile banking, 24/7 support, and automated loan processing.

Industry

Financial Services — Retail Banking

Engagement Type

PCI DSS 4.0 Encryption Assessment & Compliance Remediation Roadmap

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At a Glance Outcome

58%

Data breach risk reduced

PCI 4.0

Compliance alignment delivered

TLS 1.2+

Minimum protocol enforced

HMAC

Keyed hashing + tokenization

The Enterprise

Challenges

With a high volume of daily transactions and sensitive cardholder data across multi-cloud and on-premises environments, the bank needed a thorough assessment of its cryptographic infrastructure. PCI DSS 4.0's stricter requirements exposed gaps the existing setup couldn't address — three were the most material.

Outdated hashing without keying or salting

Cardholder data was stored using plain one-way hashing with no keying or salting, leaving it open to brute-force and precomputed attacks and short of PCI DSS 4.0’s cryptographic requirements.
01 Cryptography

Obsolete encryption protocols in active use

Systems still relied on SSL and older TLS (1.0 and 1.1) with weak algorithms — MD5, RC4, SHA-1 — exposing data in transit to man-in-the-middle interception and breach.
02 Encryption

Encryption keys stored alongside protected data

Keys were stored in the same database or server as the data they protected, so a single compromise handed attackers both the keys and the cardholder data — violating PCI DSS key management requirements.
03 Key Management
The gaps weren’t theoretical: outdated hashing, obsolete protocols, co-located keys, and non-compliant vendors created a compounding risk profile that PCI DSS 4.0 was specifically designed to eliminate.

Encryption Consulting

Engagement Summary · Encryption Consulting · Compliance Services

Our Offered

Solutions

Four workstreams addressed the full scope of the bank's PCI DSS gaps — assessment and data-flow mapping, cryptographic controls uplift, authentication and access hardening, and vendor and data-retention remediation. Every recommendation was compiled into a remediation roadmap, with tactical and strategic options for each use case in scope.

Capability 01

Assessment, Data Flow Mapping & Gap Analysis

Reviewed cryptographic policies and procedures through stakeholder workshops, mapped sensitive data flows ingress to egress, and scoped use cases. A PCI DSS 4.0 gap analysis produced a report of risks and a remediation roadmap.

Capability 02

Cryptographic Controls Uplift

HMAC keyed hashing replaced plain one-way hashing, TLS 1.2+ replaced SSL and older TLS, and vault-based tokenization substituted cardholder data with tokens. A dedicated KMS with HSMs isolates keys from protected data, with regular rotation.

Capability 03

Authentication, Access & Password Hardening

Updated PCI DSS 4.0 password policies and required MFA across all CDE access, with double authentication at remote login and the CDE entry point. RBAC was strengthened and FIDO biometric / smart-card auth added at higher-risk points.

Capability 04

Vendor Compliance & Data Retention Remediation

Reviewed third-party vendors and required risk assessments, audits, contractual PCI DSS adherence, and continuous monitoring. SAD — CVV, PIN, PIN blocks, magnetic stripe — is now automatically deleted or masked after authorization.
The result is a cryptographic environment aligned to PCI DSS 4.0 — modern hashing, upgraded protocols, isolated key management, hardened authentication, compliant vendors, and automated data-retention enforcement across the entire banking infrastructure.

Encryption Consulting

Engagement Summary · Encryption Consulting · Compliance Services

The Overall

Business Outcome

The remediation roadmap gave the bank a clear path to PCI DSS 4.0 compliance — strengthening cardholder data protection, reducing breach risk by 58%, and establishing governance to maintain compliance as standards evolve.

01

Data protection transformed

TLS 1.2+, HMAC hashing, vault-based tokenization, and isolated KMS with HSM key storage replaced outdated protocols — sharply strengthening cardholder data protection at rest and in transit and cutting brute-force and man-in-the-middle exposure.
02

Breach risk cut 58%

Automated SAD deletion, account lockout, vendor compliance enforcement, and streamlined audits cut breach likelihood by 58%, replacing manual intervention with a repeatable, efficient compliance cycle.
03

Trust and future-readiness reinforced

PCI DSS 4.0 compliance reinforced the bank’s commitment to protecting customer data — a key factor in retention and acquisition — and laid the foundation for a future-ready infrastructure as requirements evolve.

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