CLIENT CHALLENGE A US based retailer with over 700 locations internationally, engages Coalfire annually to audit and verify its compliance with PCI DSS requirements for its cardholder data environment (CDE). Coalfire reports demonstrate that the company has a strong PCI compliance program, but the company wisely wanted to evaluate its overall exposure to cyber risk. To do so, the Chief Legal Officer commissioned an assessment and penetration test of the corporate environment. That report highlighted an inconvenient reality: the company had significant risk exposure and rated well below its industry peers. APPROACH In order to reduce risk exposure and better align with industry peers, executive leadership engaged outside legal counsel for guidance. This guidance led to the

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