ICMC: FIPS and FUD

Ray Potter, CEO, Safelogic.

Mr. Potter has seen lots of vendors jumping into the FIPS-140 bandwagon when they see another vendor claiming FIPS-140 certification, without understanding what that meant.  That other vendor may have simply gotten an algorithm certificate for just one algorithm, for example.

FIPS-140 is important - it provides a measure of confidence and a measure of trust.  A third party is validating your claims.  FIPS-140 is open and everyone in the world can read the standard and the IG and implement based on these and understand what it means to be validated. Most importantly, FIPS-140 is required by the US Government and desired by other industries (medical/financial/etc).

Having this validation shows that you've correctly implemented your algorithms and you are offering secure algorithms.

See claims like the module has been "designed for compliance to FIPS 140-2", or "it will be submitted" or "a third party has verified this" or "we have an algorithm certificate" or "we have implemented all of the requirements for FIPS-140" - none of these is truly FIPS-140-2 validated.

Once you have a certificate in hand from the CMVP, then you're validated.

But even when the vendor has done the right thing for some products, sales can just get this wrong - too eager to tell the customer that everything is then validated.

So, Mr. Potter has encountered honest mistakes, but he's also seen sales/vendors outright lie about this, because it simply takes too long and is too expensive to do this.  Why do this? Make the sale - hope your in process evaluation completes before the sale.

Issues that exacerbate the situation: unpredictable CMVP queues, new Implementation Guidance (IG) that is sometimes retroactive, and uneven application across the government.  Some government agencies may accept different phases (in validation) - where others require a certificate in hand.

Vendors get frustrated when they are in the queue for months, then get some retroactive IG that requires code changes - they don't see this as worth the effort.

We can help: educate your customers on the value of FIPS-140 validations and what it really means to be validated, only use validated modules and follow strict guidelines for claims.

There are some people that will take another FIPS-140 validated implementation, repackage it and get their own certificate for the same underlying module but with their name as the vendor on the cert.

I asked about why some vendors are doing validations of their crypto consumers, when they've already got a validation for the underlying consumer.  Mr. Potter noted that some people might do this because they need to cover the key management aspects that the consumer is doing that weren't covered in the other evaluation, or that the consumer may actually have some if it's own internal crypto in addition to what they are getting from the underlying module, or that they simply are trying to make a very important customer happy.

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