Why it matters
The keys at the top of the hierarchy must never be known by any one person:
- HSM master keys;
- ZMKs with partners;
- ATM master keys;
- BDKs.
Split knowledge (no one knows the whole key) and dual control (no one can act alone) are required by PCI PIN and by every network for these keys. Developers build the tooling; testers and custodians run the ceremonies.