This morning Trustwave announced their acquisition of Breach Security, the web application firewall vendor.

Trustwave’s been on an acquisition streak for a while now, picking up companies such as Mirage (NAC), Vericept (DLP), BitArmor (encryption), and Intellitactics (log management/SIEM). Notice any trends? All these products have a strong PCI angles, none of the companies were seeing strong sales (Trustwave doesn’t do acquisitions for large multiples of sales), and all were more mid-market focused.

Adding a WAF to the mix makes perfect sense, especially since Trustwave also has web application testing (both controls meet PCI requirement 6.6). Trustwave is clearly looking to become a one-stop shop for PCI compliance. Especially since they hold the largest share of the PCI assessment market.

To be honest, there are concerns about Trustwave and other PCI assessment firms offering both the assessment and remediation services. You know, the old fox guarding the henhouse thing. There’s a reason regulations prohibit financial auditors from offering other services to their clients – the conflicts of interest are extremely difficult to eliminate or even keep under control. When the person making sure you are compliant also sells you tools to help become compliant, we should always be skeptical.

We all know how this goes down. Sales folks will do whatever it takes to hit their numbers (you know, they have BMW payments to make), and few of them have any qualms about telling a client they will be compliant if they buy both their assessment services and a nice package of security tools and implementation services. They’ll use words like “partners” and “holistic” to seem all warm and fuzzy.

We can’t really blame Trustwave and other firms for jumping all over this opportunity. The PCI Council shows no interest in controlling conflicts of interest, and when a breach does happen the investigation in the kangaroo court will show the company wasn’t compliant anyway.

But there is also an upside. We also know that every single client of every single PCI assessment, consulting, or product firm merely wants them to make PCI “go away”, especially in the mid-market. Having firms with a complete package of services is compelling, and companies with big security product portfolios like Symantec, McAfee, and IBM aren’t well positioned to provide a full PCI-related portfolio, even though they have many of the pieces.

If Trustwave can pull all these acquisitions together, make them good enough, and hit the right price point, the odds are they will make a killing in the market. They face three major challenges in this process:

  1. Failing to properly manage the conflicts of interest could become a liability. Unhappy customers could lead to either bad press and word of mouth, or even changes in PCI code to remove the conflicts, which they want to avoid at all costs. The actual assessors and consultants are reasonably well walled off, but they will need to aggressively manage their own sales forces to avoid problems. Ideally account execs will only sell one side of the product line, which could help manage the potential issues.
  2. Customers won’t understand that PCI compliance isn’t the same as general security. Trustwave may get the blame for non-PCI security breaches (never mind the real cardholder data breaches), especially given the PCI Council’s history of playing Tuesday morning QB and saying no breached organization could possibly be compliant (even if they passed their assessment).
  3. Packaging all this together at the right price point for the mid-market won’t be easy. Products need real integration, including leveraging a central management console and reporting engine. This is where the real leverage is – not merely services-based integration, which is not good enough for the mid-market.

So the Breach acquisition is a smart move for Trustwave, and might be good for the market. But as an assessor, Trustwave needs to carefully manage their acquisition strategy in ways mere product mashup shops don’t need to worry about.