David Wolf · Project Use Case
AI SECURITY · PRODUCT SECURITY · FOREX TRADING PLATFORM
Forex trading platform
Caya Forex PCI DSS Level 3 Compliance
PCI DSS Level 3 scoping, gap analysis, and compliance program delivery for a forex trading and payment processing platform.
Delivered a PCI DSS Level 3 compliance engagement for Caya, a forex trading and payment processing platform. Work covered scoping, cardholder data environment (CDE) analysis, gap assessment against the PCI DSS 1.x/2.0...
Client
Forex trading platform
Engagement Type
consulting
Period
2010
Role
PCI DSS Compliance Consultant
Focus Areas
Caya, Forex, PCI DSS, Level 3
The Research Narrative
Strategic Problem
Forex platforms present non-standard PCI DSS scoping challenges: cardholder data flows may intersect with trading infrastructure, multi-currency systems, third-party payment gateways, and international...
What David Did
Scoped the cardholder data environment (CDE) across the Caya forex platform, including payment pipelines, third-party integrations, and network zones.
What Became Clearer
Completed PCI DSS Level 3 scoping and gap analysis for the Caya forex platform.
Consulting Proof
This is evidence of turning messy security telemetry into explainable dashboards, alert-quality improvements, and executive-ready operating views.
The Context
PCI DSS Level 3 applies to merchants processing between 20,000 and 1 million Visa or Mastercard e-commerce transactions per year. The Caya forex platform required scoping and gap analysis of the full payment processing pipeline, including cardholder data flows, network segmentation, access controls, logging, encryption, and vulnerability management. The engagement was conducted at a time when PCI DSS 1.x and the transition to 2.0 were reshaping compliance expectations for mid-tier merchants.
The Challenge
Forex platforms present non-standard PCI DSS scoping challenges: cardholder data flows may intersect with trading infrastructure, multi-currency systems, third-party payment gateways, and international processing paths. Clearly defining the CDE boundary, identifying all data flows, and mapping them to PCI DSS control requirements required close collaboration with platform engineers, operations, and third-party payment partners. Remediation prioritization had to balance compliance timelines with operational risk in a live trading environment.
What I Did
- •Scoped the cardholder data environment (CDE) across the Caya forex platform, including payment pipelines, third-party integrations, and network zones
- •Conducted cardholder data flow analysis to identify where card data was accepted, transmitted, processed, and stored
- •Assessed network segmentation controls to validate CDE isolation from out-of-scope systems
- •Performed a structured PCI DSS gap assessment against Level 3 requirements, including all twelve PCI DSS requirement domains
- •Mapped existing security controls to PCI DSS requirements and identified gaps, deficiencies, and compensating control opportunities
- •Developed a prioritized remediation roadmap scoped to Level 3 validation timelines and platform risk profile
- •Advised on encryption, tokenization, and key management practices for cardholder data at rest and in transit
- •Reviewed logging, monitoring, alerting, and audit trail capabilities against PCI DSS log management requirements
The Outcome
Completed PCI DSS Level 3 scoping and gap analysis for the Caya forex platform.
Research Outcomes
Signal Quality
Improved the trustworthiness of operational security signals
Operational Clarity
Translated complex security data into clearer operating views
Stakeholder Visibility
Made technical risk and status easier to explain
Operational Impact
Turned raw telemetry into actionable security intelligence
Capabilities Demonstrated
IAM / Access Control
Identity telemetry and access insights
Security Analytics
Signal investigation and event analysis
SIEM Alert Debugging
Noise reduction and signal validation
Dashboard Development
Operational and executive views
Executive Reporting
Security data translated for leadership
Telemetry Normalization
Consistent and trusted data
Operational Reporting
Actionable views for security operations
Public-Safe Evidence
Shareable insights without sensitive data
Key Deliverables
- •PCI DSS Level 3 scoping document
- •Cardholder data flow analysis
- •Network segmentation and CDE boundary assessment
- •PCI DSS gap assessment against all twelve requirement domains
- •Prioritized remediation roadmap
- •Encryption and key management advisory
- •Log management and audit trail review
- •Vulnerability management program assessment
Tools & Technologies
Consulting Translation
The reusable pattern is not Disney-specific: normalize fragmented security telemetry, debug low-signal alert behavior, build trusted operating views, and give leadership evidence they can act on without exposing sensitive systems.