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> Lying is not an embellishment or puffery, it's a lie. Engaging a company for a 3 day pen test that's totally insufficient, that would be an embellishment.
I agree, but if the RFP question was phrased "have you done penetration testing?" then that leaves a lot of room for embellishment. If the question is "do you have SOC2 certification?" and you answer "yes" untruthfully, then that is a lie. If they ask for the SOC2 or pentest report and you give them a falsified document, that's where you're (probably) committing fraud.
> One of the most important part of pen tests is that they are external.
AWS/Google/etc have internal security teams doing their pen tests, so no, this isn't true.
> Just doing your job as an engineer and looking for bugs is not a pen test.
What about an engineer spending an afternoon running ZAP[0]?
> It's like saying, "what is an audit really? We have accountants and they check our books for anomalies."
Yeah, which is why you don't just ask a company "do you keep track of your finances?" if you're investing in them, you request external auditors.
[0] https://www.zaproxy.org/