Tuesday, March 22, 2016

ICMC16: Interested in FIPS? Register now!

I'm giving two talks this year, one on random number generation and the other on backdoors, and how they are relevant to FIPS 140 validations, at the International Cryptographic Module Conference in May 2016.  The conference this year will be up in Ottawa, Canada, which is pretty exciting for me, as I've never been there!

If you work for a validation lab or consulting firm, you're probably already registered - but this conference is particularly important for developers who are trying to pass a validation now or sometime in the future.  I know the conference organizers would love to see more real world users of FIPS 140-2 validated software and hardware as well, so if that's you - come check it out this year!

And the conference goes well beyond simply discussing FIPS 140-2/ISO 19790 - I've seen talks on new algorithms, hardware security,  general cryptography and entropy, and various attacks.

As an added bonus for you, you can register at 20% off using my speaker code: SPDI. Register soon, while early bird rates are still in effect, for added savings.

hope to see you there!


Tuesday, January 26, 2016

Book Review: Florentine Deception

The Florentine DeceptionThe Florentine Deception by Carey Nachenberg
My rating: 5 of 5 stars

Amazing technical thriller that was technically realistic! Hard to impress a computer security nerd like myself, but he did it! Written by a computer security expert, all the technical stuff seemed accurate without being dry. With the recent news out of Juniper, you realize that this book is not so far away from reality at all. The author wrote what he knew, and kept me on the edge of my seat. Excellent!

View all my reviews

Monday, January 4, 2016

2015 Wrap Up

Inspired by Cate Huston and @femengineer - instead of focusing on what I didn't finish in 2015 that I had wanted to, I'm going to do a wrap up of what I did accomplish. This is by no means complete, but this is a great time of year for introspection.

For work:
  • Increased my team's size and the scope of the work we're doing, though the work still seems to add up faster than I can grow the team.
  • People on my team have taken over leading areas, so I can do other things. This is good - they are smarter than I am, and they will make sure the right thing happens at the right time.
  • Dusted off my C coding skills and learned the new processes for: using virtual test boxes in our internal cloud, building the gate with the new "lullaby" process, and all the new rules for testing, code review, etc.  I integrated two changesets - one was minor - a few lines.  The other was over 5000 lines  - mostly removal. 
    • I've learned: 
      • My team will 100% criticize my code, it doesn't matter that I'm their manager.  And they were right, despite the fear and anger from some other senior engineers.
      • Coding while managing a large team meant lots of nights and weekends.
      • Senior engineers do NOT like to see managers integrate code. They told me so.  But, some of us still do little things.  Then again, we don't usually have time and our team will do it better.
  • Crypto Week 2015! I organized an internal crypto themed conference for about 60 people, including folks from our partner companies. This is where we do our big planning and discussions.
  • Continued to co-chair the PKCS#11 Technical Committee, which is fun and also a lot of work.
  • Spoke at the International Cryptographic Module Conference and the Grace Hopper Celebration of Women in Computing. 
  • Co-chaired the Grace Hopper Communities Committee, with more than 100 volunteers writing blogs, video blogging, note taking, speed mentoring, and leading lunch time table topics.  The conference had 12,000 attendees. We started working on this last spring for an October conference.  It was madness, amazing, inspiring and exhausting.
  • Led Oracle's participation in the OASIS PKCS#11 Interop booth for RSA. Tons of fun meeting real customers face to face!
  • Attended my first BlackHat. This was weird, because I attended 10 or so DefCons (starting with DefCon 2), but only possible thanks to my friend Runa, who gave me a pass :-) 
  • Started leading another FIPS 140-2 validation for Solaris 11.3, because I am a glutton for punishment - but also because I think there is merit in these validations. Our algorithms will be better for it.
  • Built a gorgeous, drought tolerant, demonstration garden with my husband in our front yard. Our grass is gone. In one bed, we have California poppies (which have now spread EVERYWHERE) and a city tree (Chinese Pistache). The next, roses that did beautifully in the hot, dry summer. The next: peppers (bell, jalapeno, serano, pepperocini, poblano, banana, etc etc), tomatoes, herbs and squash. In the arbor we have roses, daisies, and other plants. In pots, we have things like "hot lips" that the hummingbirds LOVE.  Strange old ladies would walk the path in our yard and bring their tripod and take pictures. Pretty cool - and VERY low maintenance.
    • Failed to take pictures, but did do a video... but need to post it. :-)
  • Went home and took care of my parents when my dad had unexpected urgent surgery. My mom is disabled, so we needed all hands on deck. They are both, thankfully, doing well now.
  • Read 29 books. Goodreads thinks I read 30, but one book is on there twice.
  • Narrated 5 novels for Learning Ally, for people with dyslexia, blindness or other reading disorders.  That's over 45 hours of final recorded material.  Many more hours in the studio.  They are awesome - please give them money.
  • Did a dream vacation with my husband and two friends from NYC to Italy! We visited Serrento, Rome and Florence. We took day trips to the Amalfi Coast, Mount Vesuvius, Pompeii, Lucca, Pisa and a Tuscan villa to learn how to make amazing pizza.  At the end, we stopped by England to see husband's family and friends.  We flew first class on air miles.  We used VRBO and saved a ton of money on lodging, had kitchens and washing machines!
    • Hot tip: You need to book first class trips about 10 months in advance, to take advantage of "super saver" rates and must be flexible on dates. We were a little late (only about 8 months out) so we had to pick weird dates/times, and could not get direct home.  We also had to pay tax, which was about as much as buying economy tickets. But, first class was amazing on British Airways' A380. Not so much on the smaller plane back to Philly. 
  • Found out my cat has allergies like me. She now takes the same allergy pill I do, but in half the dose. Well, sometimes she takes it. Other times, it's found hours later somewhere else in the house.  Sometimes we crush it into her food. Sometimes she falls for it. She's 14 and climbing all over my desk now as I write this.
  • I had a few odd health issues this year, that meant I lost use of one hand for nearly 3 months.  That sucked. No, not RSI. No, I did not crash my bike. Yes, I am doing better. I had to use voice recognition software. It was awful. The worst. It believed I had a thick East Asian accent, and could not be convinced otherwise. Customer support was the worst.  This is the "best" software on the market. HATED IT. 
    • But, it helped me to prioritize and focus.  Sorry if your email wasn't answered, but I get hundreds a day and I just couldn't get to them all.
  • I lost friends, due to reasons. I found new ones, or good old ones. This is sad and awesome.  Support came from unexpected places, and I am so incredibly thankful for every one of you that called, texted, and hung out.  My anxiety levels have gone down. I no longer have to do everything for another person, just right, for fear of being ostracized. My husband was amazing, as always.  I am not perfect, and thank you to those that understand. I know you aren't either, and I like you that way.
  • I managed to ride my bike 65 miles in the Marin Century in August! I want to do it again!
  • I raised nearly $1600 in one week for the Valley Fire Victims as a part of the Levi's Grand Fondo. I couldn't do that hard ride, so I served free beer to thousands of thirsty cyclists.
  • I was appointed as the official alternate for the Mountain View Bicycle/Pedestrian Advisory Committee - if a vacancy occurs before the next major recruitment process.  I attend nearly every meeting, and I'm getting positive changes done for bicyclists and walkers in Mountain View on a regular basis. This is awesome!
Not too shabby!

Best wishes to you all for 2016!


Thursday, November 19, 2015

OWL: Bias in the Workplace

Professor Joan C. Williams, Hastings Foundation Chair; Director, Center for WorkLife Law; University of California, Hastings College of the Law.

I had read Joan's book - What Works for Women at Work - and LOVED it, so I was so happy to see Oracle brought her onsite! Her book was well researched and science based, and gives lots of great everyday strategies for women in today's workplace.

She interviewed more than 100 successful women, and did additional research. Ninety-six percent of all women interviewed had experienced  at least one type of bias at work.

She wrote an article for Harvard Business Review, "Why We Hate Our Offices: And how to build a workspace that you can love".

The first type of bias is "Prove it Again!" syndrome, experienced by 68% of the business women and scientists she interviewed.

One gentleman she interviewed had transitioned from being a woman, and stayed in the same field of science. He overheard people, who were confused about who the female was with the same last name, that "his work s so much better than his sister's". He doesn't have a sister - that was his work, published when he was a man.

There is the "stolen idea" syndrome - you expect great ideas to come from men, so don't hear it when it comes from a woman.

Women's and men's mistakes are remembered differently, and many of these same biases also apply across racial lines. For example, people were asked to review a legal memo - the same memo, with the same errors - but when reviewers thought they were reviewing a document by a black man - they found more errors.

What's the most important factor in determining networks?  Similarity, attractiveness and location.

How does this play out in the workplace? In an org where people on top are a certain demographic, they are going to sponsor people who are like them (A sponsor is a mentor that is willing to spend their political capital to help their mentee's career).  Men tend to be judged on their potential, women on their results. This gets them stuck in the "prove it again" loop.

Women of color trigger two sets of negative stereotypes: gender and race.

When they interviewed scientists they were surprised that women of Asian descent reported the "prove it again" strategy more often then white women, even though we thought their was a stereotype that Asians were good at science. Apparently the women in this group were exempt from that positive stereotype.

So, how to get out of it? Well, prove it again - but try not to burn out. Keep careful, real-time records that track your accomplishments.  When you get compliments? Forward the email to your sponsor and manager.

How can manager's level the playing field for women?  Look around - who are you sponsoring. Is there a certain patter? do you need to widen out the group.  Male managers sometimes worry that taking a woman out to lunch or coffee would look "weird" - it doesn't. If you would do it with the men you were sponsoring, then it should be appropriate for women. Now, if you do a lot of your bonding in the men's locker room... then you need to think about doing this in ways where it wouldn't matter if you were sponsoring a man or a woman (mentoring, etc0.

Imagine you are sitting in a meeting and you see the stolen idea occur. How do you intervene? Lot's of ideas, but saying something is better than nothing. Something like, "thanks, Paul, for going back to that, I've been pondering that ever since Pam brought it up"

What if you are sitting in a meeting and you see men being judged on their potential; women on their performance - how would you intervene? This happens a lot when it comes to promotions, women are often already doing the job before they get the promotion.  One idea for getting around this: suggest evaluating the engineers first by their accomplishments, then by potential. Another: Are we being consistent here?  Or, now that we know what we're looking for, let's go back to the top of the pile and re-review everyone.

Often the most savvy way to call out bias is not to mention that's what you're doing :-)

What works for organizational prove-it again: set up precommitment to what is important (for promotion, for example), and when someone varies from there they need to have justification.

Women are expected to be nice and communal - and nice. Men are expected to competent and "agentic" (assertive, direct, competitive and ambitious).  Nobody thinks of a strong leader as "nice", so women often aren't even considered for leadership positions.

This varies by culture - US/Canada and UK believe a leader should be independent, risk takers, direct and focus on tasks. It's opposite in India/China/Japan: Interdependent, certainty, indirect and have a focus on relationships.

Ben Barres, the transgendered scientist, noted that "by far, the biggest difference is people treat me with respect. I'm interrupted less" since becoming a man.

How you stand and sit telegraphs power or submission. To demonstrate authority, stand with feet apart - stable.

Ellen Pao was described as both as "passive, too quiet at meetings" and "entitled, demanding".

Women get pressure to be deferential or play the office mom - always deliver, but never threaten. Women are pressured to do the office housework: planning parties, getting gifts, note taking, scheduling meetings, mentoring, and do the undervalued work (paperwork, etc).

But, if you're stern or say no - you're not modest or nice. You become the "B" word.

As a women, you need to claim your seat at the table and practice power poses. You need to learn how to get a word in edgewise - learn how to politely interrupt: "Oh, I'm sorry, I thought you were done."

What works for one woman won't work for another. You need to be authentic, and no when to say no (and how!).

Managers - how to handle "office housework"?  Don't ask for volunteers - women will be  under gender stereotype to volunteer. Assign true admin and housework to admins or true support personnel.  Possibly, for things like minutes, do a rotation.

Spread the load and set norms. For example, everyone does one "citizenship task" - sitting on committees, and everyone does their own ordering, billing, etc.

There was a non peer reviewed study on performance evaluations. Men got specific feedback. Women got things like "bossy, abrasive, strident, aggressive, emotional, irrational" - very strong prescriptive gender bias.

Women also are impacted by maternity bias - mothers are 79% less likely to be hired, are held to higher standards for punctuality, offered lower starting salaries and promoted less.

Indisputably competent and committed mothers are seen as LESS likable, particularly by women.

Mothers are not offered stretch positions because people assume she's busy with kids. Managers: don't assume! If she's the best person, offer it - and let her know that similar positions will be available in the future if now is not a good time.

There is this false sense that only one woman can get promoted, get an award, etc - so they will compete with each other, instead of working together.

A study found that not one female legal secretary expressed preference to work with a female lawyer as a boss.  "Females are harder on their female assistants, more detail oriented, and they have to try harder to prove themselves, so they put that on you."

Older women in the workplace discourage younger mothers from working part time after maternity leave, because "I worked full time right away and my kids are fine". That is, "I did it the hard way, why can't you."

One study found that women without children work more unpaid hours of overtime than anyone else in the workplace, seen as a pathetic spinster - so why can't you work these hours?

To get organizational change: do a "4 patterns assessment" - is bias playing out in everyday work interactions? Then develop an objective metric to test whether what women think is happening is, and make adjustments.

Example: given the study of performance reviews, companies should be reviewing their reviews for this language and see if it's mentioning bias based negative personality traits? Look at objective metric: promotion rates.  Interrupt: have someone trained to spot bias read all performance evaluations (or use an app), and redesign evaluations and provide workshops for your managers.

We all have unconscious bias. This is usually not malicious. But if you are ignorant, who's fault is that? We need to be aware and take action to counteract it.

Friday, November 6, 2015

ICMC15: Importance of Open Source to the Cryptographic Module Community

Chris Brych, Senior Principal Security Analyst, Oracle

Chris's talk will focus primarily on OpenSSL's history and potential future

The OpenSSL project has it's roots back to 1995 to the SSLeay project (Tim Hudson and Eric Young). In 1998, Tim and Eric joined RSA and started a new life and career in crypto development. There were still a lot of followers, Ben Laurie and Dr. Stephen Henson took over maintenance and changed the name to OpenSSL. In January 1999, 0.9.1 was released. Mostly maintained by volunteers. Today, we're at 1.0.2d.

There are 15 people around he world that work on OpenSSL, most are volunteers. There are 2 full time paid employees with plans to hire 2 m ore. No direct source of funding, they are relying on some private contributions and some donations.  Considering there are 7,098,576 web servers use OpenSSL (0.9.7 -> 1.0.2). This does not include application uses of OpenSSL, either, like routers.

In 2003 Steve Marquess, working for US DoD, embarked on a FIPS 140 project to validate a cryptographic toolkit derived from an OpenSSL distribution to get around exorbitant licensing fees from 3rd party toolkit vendors.  Needed a more cost effective solution.

There was a fork created in OpenSSL distribution to isolate the FIPS crypto into it's own distribution. There is a build process that is repeatable to build the exact same module that has already been validated. The hash was calculated over the fipscanister.o and verifying it with a hash published in the FIPS security Policy Document guaranteed that the same code that was validated could be used to build the FOM. Contiguous boundary created in memory that allowed for integrity checking.

This was based on the 0.9.7e distribution.  But, the DoD still wanted to make some changes to make it eve more secure.

The community saw value in someone else doing this work and started picking this up and then making contributions upstream to make it more secure.

Why use this? Well - it's free!  (subject to license restrictions).  If you're a small company, you can't afford the cost of 3rd party toolkits with FIPS support.

There's also low internal maintenance, because OpenSSL does it for you. Engineering can focus on new development features, new updates can be picked up and easily integrated and build on existing code base.

Since this was so widely accepted by many companies, many vendors stopped making their own crypto libraries. Many people, beyond the 15 core volunteers, contribute fixes.

There are disadvantages....

For example, if a bug has been publicly identified, it is out of your control - you have to wait for OpenSSL to create a fix.  You may need to wait on OpenSSL to re-certify itself, slowing down your business.  OpenSSL is not for everybody - the 80/20 rule applies here.

0.9.8 and 1.0.0 OpenSSL distributions will be EOL on December 31, 2015.  The FIPS Object Module version 1.2.4 (Cert #1051) will no longer be supported.

1.0.1 is EOL December 31, 2016 - so start thinking abou going to 1.0.2. FIPS Object Module cert #1747 is still supported by 1.0.2

But, 1.0.2 will only be around until December 31, 2019. Seems a long way out, but it will be here before we know  it. Then, we won't have anything to use #1747 with anymore.

NIST just published a draft of SPF 800-131A, r1 in July 2015, speifies non-compliant DH, ECDH and RSA in 2018.  the FIPS Object Module is not fully compliant with NIST SP 800-56A/B key agreemen. So only primitives testing for ECDH completed, KDF not tested. DH not tested as part of NIST SP 800-56A and RSA not compliant with SP 800-56B and OpenSSL does not plan to do this development.

1.1.0 is plan to be released in April/May 2016, which will include an API change. It will not be compatible with FOM 2.0.10.  That is, we lose our FIPS module!

This means that if organizations need FIPS and are now relying on OpenSSL, they will have to hire to complete this. Will have to make modifications of a code base containing over 500,000 lines of code - risky. What if they introduce other vulnerabilities?  Many vendors will have an OpenSSL validation - but they won't be the same. Confusing for end users.

Money won't solve the problem. OpenSSL is not interested, even if some vendor offered them money.

How can we solve this? if you're interested, please participate in the CMUF. We will have to get input from CMVP and the US Government needs to be involved.

Post by Valerie Fenwick, syndicated from Security, Beer, Theater and Biking!

ICMC15: Collateral Damage—Vendor and Customer Impact of Frequent Policy Changes

Joshua Brickman, Director, Security Evaluations, Oracle; Glenn Brunette, Senior Director and Chief Technologist, Cybersecurity, Oracle

Glenn started the talk.

Oracle is a big company, nearly 40 years old. Originally started with one products, but no has 1,000s of products with 400,000 customers across 145 countries.  This is a lot of variance, which makes doing FIPS 140-2 at Oracle a challenge.

Many of our products and delivered systems cannot change frequently, for example products used in medical trials.

Oracle has developed many products for FIPS 140: Solaris Cryptographic Framework, StorageTek, Java Cards, Acme Packet Session Border Controller, etc.  Also leverage third-party validated modules ("FIPS Inside") like RSA BSAFE Crypto J and OpenSSL.

It's not even simple when you talk about one product. For example, our Database interacts with several different crypto modules.

We do our best to educate our customers and internal developers, try to figure out how to compare apples and oranges and figure out operational decisions.

FIPS 140 can be easy to understand in one breath, and complicated to understand in the second. Is it approved or not?  Validated vs approved?  What modes and key lengths are you validated against?

We need to be more specific.  Marketing and product documentation might say: "We're FIPS validated! We're Encrypted" - but our customers want and need more details. Even saying a product uses AES may not be sufficient, as they need to know modes supported.

Module vs product validation.  Is "Oracle Weblogic" FIPS 140 validated?  What about Oracle Solaris? It could have multiple libraries and modules under the covers.

But, if you use "FIPS Inside" approach, you won't be listed on the CMVP website, so customer doubts vendor's sincerity.  Would be nice  if there was an official place to list folks leveraging FIPS Inside strategy.

Module versioning is not consistent with product versioning.  You can get away with very vague versioning schemes, makes it challenging for customers.

How do you map a product's cryptography to modules?  The big product, like an OS, may not validate every cryptographic module included in the system. Even if the OS vendor works really hard, they might only get 80%. How does your customer know if they are using one of the non validated uses cases?

Many times products do not ship with FIPS 140 on by default, so there is a challenge to even get it turned on. Then, customers layer products - particularly in the cloud space.

The NIST website can be very clear about when you should use FIPS, yet customers don't interpret this correctly. They may only be concerned with TLS, but actually using more.  They've sometimes done the horrible workaround to drop crypto, because they don't have a validated solution.  Some customers get this, others do not.

Lack of understanding at the customer site leads to a lot of problems. We need to plan for this when making future standards, so folks aren't taking the shortest path (which is usually the wrong approach).

Josh thinks there's a lot of hope, he sees progress coming around the corner.

It's clear that NIST/CMVP want the strongest crypto NOW for their customers. Vendors want the strongest crypto for their customers, with the least performance impact. Customers WANT this, but for a low price.

Remember the critical Shampoo algorithm: lather, rinse, repeat! This should apply to the CMVP process.

Vendors face big challenges, like: AES-GCM IV Generation.  In 2007 NIST issued SP 800-38D published, with two IG's.  In 2009 IG A.5 Key/IV pair uniqueness requirements  inside the physical boundary. In 2015 IG A.5 was overhauled, based on the discovery of 1 vendor's bad application that used all zeros for their IV - so we're all punished. Change came in August 2015, no grandfathering.

When we saw the new IG draft, we stopped all ongoing work to analyze the new IG. Oracle wrote up a proposal to mitigate the impact of the new IG while still meeting the spirit of the IG and sent it to CMVP.  Whiel waiting for a response, CMVP issued another IG. On August 5, still not responding to Oracle's comments, A.5 came out. How is that working with the vendors?

IG 7.15 published in August, again no grandfathering, and we found a project that got it's entropy from a 3rd party and we could not prove it.  the third party treated this as intellectual property, so they did not want to work with CMVP.  Oracle volunteered everything we did know to CMVP, and begged for a waiver. How do you build a business around that model?  Did everyone get a waiver?  Will our next project get a waiver?

How do we get out of that cycle?

Could form a technical community (CMUF working with CMVP). Take a page from NIAP and work together to solve problems. Take advantage of the fast resources of industry!  Create one for IGs, one for FIPS 140-4, etc.  Instead of throwing IG's over the wall, work together to come up with consensus.

We need time  to react - there MUST be time to transition. Every reactive response to IG is less time for industry to build product and fix bugs. [Note: by panicking to react, we may end up introducing worse issues.]

NIAP and NIST need to go back to being a partnership - see Entropy!

Negotiate with other crypto schemes to see if any mutual recognition can be negotiated.

We can do better by working together, so let's do that :-)

Post by Valerie Fenwick, syndicated from Security, Beer, Theater and Biking!

ICMC15: FIPS is FIPS, Real World is Real World and Never the Twain Shall Meet?

Ashit Vora, Co-Founder and Laboratory Director, Acumen Security

Ashit's journey has taken him from a Lab, then to a Vendor, and now back to a Lab.  He's seen the experience from both sides.  He's been working with FIPS 140-2 since 2003. The world has changed greatly since then, but the standard has not.

FIPS 140-2 has been approved since May 2001. It was very hardware focused, as that's what was common in the marketplace. There was only a small handful of approved algorithms.

There is a requirement that the standard is supposed to be updated every 5 years, so there was a draft of FIPS 140-3 in September 2005... a draft.  As of now, we *might* get FIPS 140-3 in May 2016, if it's delayed even a little bit it will turn into a long delay, as the standard has to be signed off by the Secretary of Department of Commerce - a political appointee, which will change when there is a new US President.

FIPS 140-2 is an open commercial project. The standard itself is 69 pages. Many vendors read that only and say, "I've read and understand the standard and we're ready!"  There are 127 pages of Derived Test Requirements, and 63 pages of implementation guidance.  IG was originally supposed to be an FAQ, but it has evolved to really be the new rules.

There are 287 requirements for FIPS, 50% of them are documentation requirements. More than 50% of the requirements are orthogonal to crypto.

OpenSSL has had 5 vulns in 2013, 22 in 2014 and 26 in 2015, but how many times has their FIPS module changed since 2013? Zero.

CMVP believes FIPS is a solutions, vendors think it's a means to an end (to sell to the government), and to the federal agencies it is merely a checkbox.

What is it really? A bit of everything and a bit of nothing. Ensures what is claimed has been implemented correctly - that's a good thing! At levels 1 and 2 little more assurance than the product implements crypto as per spec. FIPS validation does not mean the overall "cryptographic posture" of the system is secure.

The standard was developed with the best intentions, but it has not been able to change with our fast changing industry.  There have been a few improvements, like the changes for CRNG relaxation and possible relaxation on integrity checks.

COTS product - easy to buy a produce and open at your own leisure. Causes vendors to downgrade to level 1 or design prupose built "opacity shields". Tamper labels in a similar vein add nothing to security posture of the product. Products are rarely deployed with the opacity shields and tamper labels in place, they just don't fit on the rack. Plus, end users need to make modifications.

Real world: Key Management - possible to have a module FIPS validated w/out including key management at all. In fact MOST software libraries do not include key management.  This is a direct result of crypto boundaries shrinking!

Password requirements are rudimentary at best. No consideration for password complexity, frequency, etc.

Real World: OpenSSL. It is the MOST widely used cryptographic library in the world.  ost prevalent in networking products, but also showing up in IoT, etc. Many products gain FIPS compliance just by including OpenSSL.  That validation, however, does not cover TLS, key management - etc. Hence, the small boundary.

FCC/FSM and configuration management requirements do NOT add security.  The FSM (Finite State Machine) is almost always created AFTER the product is completed.

We have a test on software firmware load test, it checks that it's valid, but there is no root of trust.  A self signed cert gets you through this check.

Should follow the CC direction: use the standard as a base/toolkit and provide technology specific requirements (that map back to the standard).

Do not tie validations to specific versions. Allow for minor changes/bug fixes. Validations take a long time (12-18 months), but vendors tend to push fixes every month. Often very minor. Yes, there may be that one corner case where one vendor screws this up and makes a critical change - but why punish all vendors for one person's mistake?

Due to this, vendors are making VERY small boundaries, which means we're actually looking at a tiny portion of the security relevant system. Need to encourage larger boundaries, but that's only possible if engineers can fix small bugs.

Spend time on the most important sections: Section 1, Section 5 and Section 7.

Focus on key life cycle! Make those requirements more all-encompassing. Implementing crypto algorithms is easy (?!?), but key management is hard. [NOTE: it's all hard :-)]

Question what about making physical security optional?  Maybe, but it should be tied to the expected deployment environment. For example, a publicly accessible wifi access point might need to be more strict than a router buried in the bowels of a government building.

Randy Easter recommended just doing Level 1 for physical security, but Ashit noted that if they do everything else to Level 2 they will end up with a Level 1 overall validation. Randy noted that this is a matter of informing end customers - easier said than done!

Randy also wants to know how CMVP has relaxed rules w/out notifying the Secretary of Commerce?  Ashit noted that "that ship has sailed" with the Implementation Guidance.

Post by Valerie Fenwick, syndicated from Security, Beer, Theater and Biking!