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Compliance Framework Example: Payment Processing (PCI-DSS)

Context: An internet payment processor (similar to Stripe) must comply with PCI-DSS, SOC 2, GDPR, and various regional financial regulations. The API governance platform becomes a critical compliance control point.

PCI-DSS Specific Requirements

Requirement 1 & 2: Network Security & Secure Configurations

API Governance Implementation:

• All APIs handling cardholder data (CHD) designated as “Highly Restricted” classification
• Network segmentation enforced: payment APIs isolated in PCI-compliant zones, only accessible via Gateway
• Gateway deployed in DMZ with strict firewall rules: inbound only from authenticated services, outbound only to PCI backend
• Service configurations managed as code, immutable infrastructure prevents configuration drift
• Quarterly vulnerability scans of Gateway and payment APIs, automated patching for critical CVEs

Evidence for Auditors:

• Network diagrams generated from infrastructure-as-code showing segmentation
• Firewall rules exported from cloud providers showing Gateway-only access
• Scan reports from approved scanning vendors (ASV)

Requirement 3 & 4: Protect Cardholder Data & Encrypt Transmission

API Governance Implementation:

• Cardholder data never stored in logs; Gateway automatically redacts card numbers, CVVs from all logs
• Tokenization services integrated with Gateway: raw CHD converted to tokens before reaching most backend services
• Only PCI-compliant vault services handle raw CHD; all others work with tokens
• TLS 1.3 enforced for all cardholder data transmission
• mTLS required for services directly accessing vault or payment processor integrations
• Key rotation managed centrally by platform team; services don’t handle encryption keys

Evidence for Auditors:

• Data flow diagrams showing tokenization at Gateway ingress
• Encryption configuration exports showing TLS versions, cipher suites
• Key rotation logs from secrets management system
• Sample logs demonstrating redaction of CHD

Requirement 6: Secure Development & Vulnerability Management

API Governance Implementation:

• API Review Panel includes security specialist who reviews all payment-related APIs
• Automated SAST/DAST scanning in CI/CD pipeline for all API changes
• Breaking changes to payment APIs require cryptographic signature of approval from security team
• API specifications scanned for PCI-DSS anti-patterns: CHD in query params, GET requests, unencrypted storage
• Immutable deployment pipeline: no manual changes in production; all changes via reviewed, tested deployments

Evidence for Auditors:

• Review records from API Review Panel with security sign-offs
• SAST/DAST scan results for payment APIs
• CI/CD pipeline configurations showing security gates
• Change logs showing all deployments with approval audit trails

Requirement 7 & 8: Access Control & Authentication

API Governance Implementation:

• Subscription-based access enforces need-to-know: only payment processing services can access CHD APIs
• Role-based access control (RBAC) layered on subscriptions: different endpoints require different roles
• Multi-factor authentication required for any human access to production payment APIs (even read-only)
• Service accounts use certificate-based authentication, not passwords
• Credential rotation enforced: OAuth tokens expire within 1 hour, refresh tokens within 24 hours
• Principle of least privilege: subscriptions scoped to minimum necessary endpoints and operations

Evidence for Auditors:

• Registry exports showing subscription scoping and role assignments
• Authentication policy configurations from identity provider
• Certificate lifecycle management logs
• Access reviews showing periodic validation of who has access to what

Requirement 9: Physical Security

API Governance Implementation:

• Gateway and platform services deployed in PCI-compliant cloud regions or colocations
• API metadata and subscription data encrypted at rest with FIPS 140-2 validated encryption modules
• Physical access to platform infrastructure controlled by cloud provider SOC reports

Evidence for Auditors:

• Cloud provider attestations (SOC 2 Type II, PCI-DSS AOC)
• Encryption configuration showing FIPS compliance

Requirement 10: Logging & Monitoring

API Governance Implementation:

• Centralized, tamper-proof audit logs capturing all CHD access:
  • Every request to payment APIs logged with full metadata (who, what, when, where, why)
  • User identity tracked: which merchant, which end-customer, which employee for admin actions
  • Field-level access logging: which specific payment methods or transactions were accessed
  • Logs written to immutable storage with cryptographic integrity protection
• Real-time monitoring & alerting:
  • Security Information and Event Management (SIEM) integration consumes Gateway logs
  • Alerts on suspicious patterns: unusual access times, volume anomalies, failed auth attempts
  • Daily automated reports summarize CHD access by user, service, purpose
• Log retention: 1 year online, 7 years archived (exceeds PCI-DSS minimum of 1 year)
• Time synchronization: All Gateway and Auditor components sync with NTP; timestamps in logs auditable

Evidence for Auditors:

• Audit log samples showing required fields (user ID, timestamp, action, resource, outcome)
• SIEM configuration showing alerting rules for security events
• Log retention policy documentation and storage verification
• NTP configuration and drift monitoring

Requirement 11: Security Testing

API Governance Implementation:

• Quarterly penetration testing of Gateway and payment APIs by external firm
• Automated vulnerability scanning weekly; critical/high findings must be remediated within 30 days
• Bug bounty program encourages responsible disclosure of API security issues
• Gateway bypass testing: quarterly internal tests attempt direct API calls to verify network segmentation

Evidence for Auditors:

• Penetration test reports with findings and remediation proof
• Vulnerability scan reports showing scanning frequency and remediation timelines
• Bug bounty program documentation and resolved issues

Requirement 12: Information Security Policy

API Governance Implementation:

• API security standards documented and versioned in platform wiki/handbook
• Annual security awareness training for all engineers covers API security best practices
• Incident response playbook includes API-specific scenarios (credential leak, data breach via API)
• Quarterly risk assessments of API ecosystem identify high-risk APIs for additional controls

Evidence for Auditors:

• API security standards documentation
• Training completion records for engineering staff
• Incident response procedures and test exercise results
• Risk assessment reports and risk register

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GDPR Compliance Through API Governance

Right to Access (Article 15):

• Special /privacy/user/{id}/data API consolidated view of personal data across all internal APIs
• Audit logs track which APIs were queried to fulfill access request
• Response includes data sources, processing purposes, retention periods

Right to Erasure / Right to be Forgotten (Article 17):

• Subscription metadata tracks which APIs process personal data for which purposes
• Data deletion request triggers automated calls to all subscribed APIs handling user’s data
• Audit trail proves deletion completed across all systems within mandated timeframe (typically 30 days)
• Tombstone records prevent re-creation of deleted data

Data Minimization (Article 5):

• API specifications reviewed for necessity: does this endpoint need to return full data or can it be scoped?
• Gateway enforces field filtering: consumers only receive fields relevant to their purpose
• Review panel challenges data models that expose excessive personal data

Purpose Limitation (Article 5):

• Subscription requests require usage_description explaining why consumer needs data
• Gateway logs include purpose of access from subscription metadata
• Auditor can generate reports: “Which services accessed customer data for marketing purposes?”

Data Portability (Article 20):

• Standardized export formats (JSON, CSV) for personal data enforced through API standards
• Export APIs required for all services handling significant personal data
• Machine-readable format makes portability to competitors feasible

Breach Notification (Article 33-34):

• Security monitoring detects potential breaches (unusual data access, exfiltration patterns)
• Audit logs provide evidence for breach scope: exactly which records were accessed, by whom, when
• Automated breach report generation from Auditor data: affected individuals, data types exposed, timeline
• 72-hour notification deadline trackable through incident timestamps in audit logs

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SOC 2 Type II Compliance

Security (Trust Service Criteria):

• Access controls (CC6.1): Subscription-based authorization, least privilege enforced by Gateway
• Logical access (CC6.2): Authentication, MFA, credential lifecycle management via platform
• Security monitoring (CC7.2): Real-time SIEM integration, anomaly detection, incident response

Availability (Trust Service Criteria):

• SLO monitoring (A1.2): Auditor tracks API availability per SLO commitments
• Capacity management (A1.3): Consumer-level metrics enable capacity planning and scaling

Processing Integrity (Trust Service Criteria):

• Data validation (PI1.4): API specifications define data contracts; Gateway validates inbound requests
• Error handling (PI1.5): Standardized error responses, consumer-specific error tracking for diagnosis

Confidentiality (Trust Service Criteria):

• Data classification (C1.1): APIs declare sensitivity level, controls enforced accordingly
• Encryption (C1.2): TLS for all, mTLS for confidential data, field-level encryption for highly sensitive data

Privacy (Trust Service Criteria):

• Consent management (P3.2): Subscription approval can require end-user consent validation
• Data disposal (P5.2): Retention policies enforced, deletion requests tracked through audit logs

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Regional Financial Regulations

Open Banking (PSD2 in Europe, similar in UK, Australia):

• Third-party provider (TPP) access to customer financial data via APIs
• Strong Customer Authentication (SCA) enforced at Gateway for payment initiation
• TPP registration and certification tracked in Registry; only certified TPPs get subscriptions
• Audit logs prove consent flow: customer authorized TPP access, which data was shared, when consent expires

Anti-Money Laundering (AML) & Know Your Customer (KYC):

• Transaction monitoring APIs integrate with AML engines
• Audit logs provide transaction reconstruction for regulatory investigations
• API access controls ensure only authorized fraud/AML teams can query sensitive transaction data
• Immutable logs prevent tampering with evidence needed for compliance or law enforcement

California Consumer Privacy Act (CCPA):

• Similar to GDPR: access, deletion, opt-out rights
• API governance platform provides same mechanisms as GDPR compliance
• Audit logs track California residents’ data access separately for CCPA-specific reporting

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