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Created October 13, 2025 13:09
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PCI DSS + HSM Compliance Checklist
# Requirement Verified? (Y/N) Notes
1 HSM is FIPS 140-2 Level 3 (or FIPS 140-3 Level 3) validated Check NIST CMVP list
2 Cryptographic keys for CHD never exist outside HSM in plaintext Confirm via architecture review
3 All key management (generation, storage, rotation, destruction) occurs within HSM
4 HSM access is restricted via strong authentication (MFA recommended) PCI DSS Req 8
5 Role separation enforced (e.g., SO vs. Crypto User vs. Auditor) PCI DSS Req 7
6 All HSM operations logged; logs sent to SIEM PCI DSS Req 10
7 HSM physically secured (if on-prem) or in compliant cloud environment PCI DSS Req 9
8 HSM firmware/software kept up to date PCI DSS Req 6
9 HSM included in annual PCI DSS assessment scope Document in ROC/SAQ
10 If used in P2PE or PIN processing, solution is PCI-listed or validated Check PCI SSC website
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