If you accept payment with credit cards or transmit or store any cardholder data, then the Payment Card Industry Data Security Standard (PCI DSS) applies to you. PCI DSS is a set of requirements designed to ensure that all companies that process, store or transmit credit card information maintain a secure environment. PCI DSS requirements apply to any credit, debit or pre-paid card transaction whether it’s online, via phone or in person. So PCI DSS compliance pretty much applies almost every merchant doing business.

For small and medium-size businesses, PCI DSS compliance can be confusing and expensive to implement. Worse yet, PCI DSS requirements often appear subjective in their enforcement and interpretation.

So, why bother?

Failure to comply can lead to stiff penalties from the major credit card companies, including American Express, Discover, JCB, MasterCard and Visa International. Even if you haven’t been breached, noncompliant organizations can face substantial fines and even have their payment card privileges revoked. The results can be devastating, irredeemably destroying your credibility, customer loyalty, and ultimately, your business.

Which merchant level am I?

Qualification: You’re a small business processing less than 20,000 eCommerce transactions and less than 1 million other transactions each year.

  • Requirements: You need to complete an annual risk assessment using the appropriate PCI Self-Assessment Questionnaire (SAQ). Quarterly PCI scans, administered by an approved scanning vendor, may also be required.

Qualification: You’re a midsize company processing 20,000 to 1 million transactions annually.

  • Requirements: An annual risk assessment using the appropriate SAQ. Quarterly PCI scans, administered by an approved scanning vendor, may also be required.

Qualification: You’re a mid- to large-size company processing between 1 and 6 million transactions annually.

  • Requirements: An annual risk assessment using the appropriate SAQ. Quarterly PCI scans, administered by an approved scanning vendor, may also be required.

Qualification: You’re a major or very large organization processing 6 million transactions or more per year.

  • Requirements: An annual internal audit conducted by a qualified PCI auditor. Quarterly PCI scans, administered by an approved scanning vendor, may also be required.

38North consultants have assessed organizations from numerous industries against all PCI DSS compliance requirements, and routinely conduct a variety of internal and external vulnerability assessments to identify security weaknesses.

Our PCI DSS services include:

PCI DSS Gap Analysis:

This is perfect for organizations new to PCI DSS that don’t know where to begin. Our PCI DSS gap analysis educates you on the process while examining your information security and privacy programs to see how they stack up against PCI DSS requirements. We also determine the cost to attain PCI DSS compliance, identify any risks and/or challenges and help you focus on the most critical action items.

PCI DSS Self-Assessment.

The Self-Assessment Questionnaire (SAQ) is a required PCI DSS deliverable that may be undertaken internally depending on your comfort level and experience. If you need it, we can complete this assessment for you using the appropriate SAQ for your business, including the Attestation of Compliance.

PCI DSS Remediation Support:

Once you have an unbiased view of your compliance posture, you need to plan, develop and implement remedial measures. This may be in the form of new technologies, policies, plans and procedures or training.

Jeremiah Thompson

Director of Cloud Security Architecture

Jeremiah Thompson is 38North’s Director of Cloud Security Architecture. He leads 38North’s technical teams as they tackle engineering challenges and design secure, compliant cloud security architectures.

For over 18 years Jeremiah has helped clients in the commercial, defense and federal civilian sectors engineer secure solutions to modern cyber challenges. Prior to 38North, he served as a Director at Coalfire, one of the nation’s preeminent Third-Party Assessment Organizations (3PAOs). At Coalfire he led FedRAMP and DoD FedRAMP+ assessments supporting Fortune 500 organizations. He was also a Lead Information Security Compliance Auditor supporting the National Cancer Institute, and an Information Security Compliance Auditor at IBM.

Jeremiah currently holds CISSP, CISM, CAP, C|EH, Security+, Network+, CCSK and MCP certifications.

Andy Davidson

Senior Director of Cloud Security

Andy Davidson is Senior Director of Cloud Security at 38North. He leads 38North Senior Advisors as they prepare IaaS, PaaS and SaaS providers for the rigors of FedRAMP authorization. One of the nation’s most experienced FedRAMP practitioners, Andy has been supporting FedRAMP assessment and consulting efforts since the initial FedRAMP pilot project. He specializes in helping hyperscale Cloud Service Providers (CSPs) navigate FedRAMP requirements and successfully achieve Provisional Authorities to Operate (P-ATO).

Prior to 38North, Andy was Senior Director of FedRAMP and Assessment Services at Coalfire, one of the leading Third-Party Assessment Organizations (3PAOs). At Coalfire, he was responsible for growing the 3PAO practice and managing assessor teams in the execution of high profile assessments for Fortune 500 CSPs. He also helped start Veris Group’s 3PAO practice. Prior to Veris, Andy was an IT security consultant at Booz Allen Hamilton, supporting security assessments and engineering efforts across the federal government.

Linda Morales

Senior Director of Global Compliance

Linda Morales is the Senior Director of Global Compliance at 38North Security. She leads assessments for customers in the healthcare, federal and commercial spaces. She specializes in helping organizations prepare for and complete FISMA, FedRAMP and HIPAA assessments. She is adept at leading teams to deliver efficient, accurate security reviews that withstand scrutiny from federal regulators. Linda is also a recognized expert in Healthcare security, helping Health-IT providers secure and defend Protected Health Information (PHI).

Prior to 38North, Linda served as a Director at Endeavor Systems, where she played a key role growing the federal security services practice. She also served as Security Manager for the Federal Aviation Administration’s (FAA) enterprise-wide assessment program, with responsibility for 150+ systems across FAA.

Linda earned a BS in Computer Science and a Masters in Engineering Management, with a focus in Information Security, both from The George Washington University. She is also a Certified Information Systems Security Professional (CISSP), Project Management Professional (PMP), and a Registered Practitioner with the Cybersecurity Maturity Model Certification Advisory Board (CMMC-AB).

Spence Witten

Senior Advisor and Director of Business Development

Spence Witten is a 38North Senior Advisor and Director of Business Development. He serves as a trusted security advisor to 38North’s clients in the cloud services, healthcare, financial, defense and critical infrastructure communities.

Prior to 38North, Spence was Vice President of Global Sales at Lunarline. Spence led sales and marketing across ten cybersecurity business units, culminating in Lunarline’s acquisition by Motorola Solutions. Prior to becoming VP of Global Sales, Spence ran Lunarline’s US Federal Security Services practice, overseeing Lunarline’s defense, intelligence and federal civilian portfolio. He was also an early employee of Endeavor Systems. He played a key role in Endeavor’s rapid expansion in the federal, civilian, defense, and research and development markets, through to Endeavor’s successful acquisition.

An Adjunct Professor at Cleveland-Marshall College of Law, Spence serves on the Board of Directors for the Center for Cybersecurity and Privacy Protection at Cleveland State University. He is also a member of CyberOhio, the official cybersecurity advisory board for the Governor of Ohio.

Virginia Suazo

Senior Director of Cloud Security Advisory

Virginia Suazo is 38North’s Senior Director of Cloud Security Advisory. She is responsible for leading 38North’s cloud security and compliance efforts, with a speciality in helping global CSPs juggle multiple overlapping regulatory frameworks.

Before joining 38North, Virginia worked at a tech startup supporting the first and only Red Hat OpenStack Platform that is FedRAMP-authorized. She played a vital role in successfully obtaining FedRAMP Moderate and High authorizations for IaaS, PaaS, and SaaS systems, while supporting other certifications including DoD IL4/5, PCI DSS, HIPAA and HITECH. Her 15 years of cybersecurity experience also includes several tours supporting US federal agencies, including State Department, Department of Justice, Health and Human Services, Food and Drug Administration, General Services Administration and Department of Transportation.

Matt Earley


Matt Earley is 38North’s founder and President. He started 38North – the premier cloud security advisory company, in the US and internationally – to solve complex security challenges while developing trusted relationships with an elite client base.

For over 20 years Matt Earley has designed and implemented security solutions for the US and Australian federal governments, critical infrastructure, utilities, and for global finance and healthcare organizations. He focuses on lean security architecture design and prioritizing security efforts based on the critical needs of his clients.

Prior to founding 38North, Matt was the director of federal services at Endeavor Systems, where he was responsible for Endeavor’s largest business unit, serving the Federal Aviation Administration, Department of Homeland Security and some of the world’s largest security operations centers. He was also a Senior Manager in the Australian Department of Defense, where he represented Australasia on the Common Criteria Management Board.

Matt has a Bachelor of Engineering in computer engineering from the University of Canberra in Australia, and a Master’s in engineering management from George Washington University. He also is a Certified Information Systems Security Professional (CISSP) and Project Management Professional (PMP).