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Erfan Shadabi l Feb 20, 2025 l PCI DSS, Compliance

PCI DSS 4.0 at Scale: Enterprise Strategies for Multi-Region Compliance

As the deadline for PCI DSS 4.0 compliance nears, many organizations face a twin headache. Not only must they meet the strict set of requirements mandated by the standard. Many must also ensure they do so across multiple regions, business units, and potentially payment systems.

The data security standard is global. But within many large enterprises, operations are siloed and localized. What is needed is a scalable, data-centric approach that streamlines PCI DSS 4.0 compliance without compromising on security.

The challenges of transnational PCI DSS compliance

PCI DSS 4.0 applies to any organization that stores, processes, or transmits cardholder data. At one end of the spectrum, this could mean small, local retailers. But at the other, sit multi-national financial services firms. It is here that the complexities of running a cross-border business begin to emerge. The challenges associated with formulating a PCI DSS multi-region strategy could include:

Regulatory issues: Multi-nationals may find themselves subject to multiple data protection laws (eg GDPR) which overlap with PCI DSS, adding complexity and nuance. Some may even require data to be stored within sovereign borders, complicating data flows and management. And although the Payment Card Industry Security Standards Council (PCI SSC) has tried to create a standardized set of requirements, in some regions there may be different interpretations of PCI DSS itself, which could cause confusion.

Cultural barriers: Multi-nationals must ensure PCI DSS documentation and staff training are translated into local languages and resonate culturally. Coordination of activities across time zones may also be challenging.

Technology: Larger enterprises are also likely to run heterogeneous tech stacks and globally dispersed networks. They’ll have at least some legacy IT infrastructure in place, which may even cause compatibility issues with PCI DSS 4.0. All of which makes consistency of data protection and identification of compliance scope more complex.

Attack surface: Large transnational companies are likely to have a broader digital attack surface to protect. Assessing and continuously improving security posture across all of these assets while monitoring continuously for breaches and incidents is a significant undertaking.

Third parties: An extra layer of complexity comes with maintaining oversight of local partners, suppliers and others who handle cardholder data.

Auditing: Multinationals must find Qualified Security Assessors (QSAs) with local expertise and coordinate their work across multiple regions.

A PCI DSS multi-region strategy

Consistency is the key to global PCI DSS 4.0 compliance. But that is a challenge, with so much potential diversity across different regional businesses—from language and culture to local regulations, IT and partners.

However, to maintain as much standardization as possible, organizations should try to:

  • Build a centralized platform for compliance management and security monitoring
  • Build a centralized compliance team that receives input from regional subordinates
  • Ensure that each member of the team, and their reporting lines, know their roles and responsibilities
  • Consolidate onto fewer tech vendors, which have a global reach
  • Standardize their PCI DSS 4.0 policies and procedures across all international operations
  • Provide training to all regional employees, customized for local language and culture
  • Apply security controls consistently across borders
  • Nurture an environment of communication and collaboration across borders
  • Try to automate as much as possible to reduce the security and compliance burden on teams

How comforte can help

This may all seem like a tall order, especially given the costs involved, the complexity of many global business operations and the paucity of skills in key roles. However, technology can be a powerful ally when building out PCI DSS 4.0 enterprise compliance across borders. This is where comforte can ease the burden for multi-national customers thanks to its:

Cloud-based approach, which makes it easier to deploy across multiple regions.

Data-centric approach, which focuses on protecting the data first, wherever it resides, rather than the infrastructure surrounding it. Through the use of format-preserving encryption or tokenization, customers can therefore create a unified security layer across multiple IT systems in different regions—mitigate risk across a broad attack surface.

Tokenization for PCI compliance, which helps to reduce the scope and costs associated with compliance, by replacing sensitive data elements like primary account numbers (PANs) with unique tokens.

Multilingual support, for customers operating across the globe.

Global reach, via offices in APAC, Europe and North America. Five hundreds of the largest organizations in the world trust comforte solutions to protect their sensitive data.


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