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Thread-Topic: Managing aglorithms  RE: [saag] TCP-AO MAC algorithms
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References: <98FA6BE8-0825-41F6-8DAA-1A5706D974A9@cisco.com><20080101020627.CBFAE5081A@romeo.rtfm.com><CE992CC7-302C-45ED-8325-646D4E026619@cisco.com>
	<20080105004455.9577F5081A@romeo.rtfm.com>
From: "Hallam-Baker, Phillip" <pbaker@verisign.com>
To: "Eric Rescorla" <ekr@networkresonance.com>, "Brian Weis" <bew@cisco.com>
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To tie a number of threads together here I think it would help =
enormously if we had some sort of cross IETF statement of the set of =
algorithms that are currently the consensus recommendations for support.
=20
I don't think that there is a lot of disagreement on the important =
points, e.g. :
=20
* If you are designing an entirely new protocol that requires block =
encryption specify AES-128 and AES-256 as MUST
=20
* The use of 3DES, HMAC-SHA1, should be avoided in entirely new =
protocols but is not cause for concern in deployed protocols.
=20
* Use of SHA1 should be avoided except in deployed protocols where there =
has been careful analysis that demonstrates use in that application is =
not cause for concern.
=20
* Use of MD5, ciphers with a strength of 56 bits or less should be =
avoided in almost all circumstances. Use of ciphers with key sizes of 64 =
bits or less should be discontinued as soon as is practicable.
=20
* If someone wants to specify vanity crypto, give them the necessary URI =
or OID and tell them to use it at their own discretion.
=20
=20
I don't think we should have this discussion in every individual working =
group.=20
=20
I especially don't want to have to have the discussion on how to use ECC =
with each individual IETF spec in turn. Or worse have extended =
discussions over the optimal choice of group etc. so that we end up with =
different choices across the IETF. If the specifications are well =
designed we should have all the information necessary to specify how to =
use algorithms across the board.
=20
As things stand I think we are going to end up with more crypto =
configurations in IETF protocols than we have crypto people. And that =
would be a bad thing when there is a pretty strong consensus on =
preferred algorithms in the field.

________________________________

From: saag-bounces@mit.edu on behalf of Eric Rescorla
Sent: Fri 04/01/2008 7:44 PM
To: Brian Weis
Cc: saag@mit.edu
Subject: Re: [saag] TCP-AO MAC algorithms



At Fri, 4 Jan 2008 15:06:59 -0800,
Brian Weis wrote:
>
>
> On Dec 31, 2007, at 6:06 PM, Eric Rescorla wrote:
>
> > At Tue, 18 Dec 2007 16:23:51 -0800,
> > Brian Weis wrote:
> >>
> >> Greetings,
> >>
> >> The TCPM WG seeks advice from SAAG on which MACs to include as
> >> required MACs for the TCP Authentication Option =
(draft-ietf-tcpm-tcp-
> >> auth-opt-00).
> >
> > I would note that TLS has one MTI MAC (HMAC-SHA1) and based on RFC
> > 4835, so does ESP/AH (HMAC-SHA1-96). What's the rationale for why
> > TCP-AO should have stricter MTI requirements than we have for
> > our dedicated security protocols?
>
> The rationale is simply that two methods with differing internal=20
> constructions implies that the standard is better prepared for the=20
> future (if one of the two MACs is perceived to be broken).

Yes, this strikes me as massive overkill, given that typical
MAC constructions are designed with some kind of reduction
to the primitive they are based on. If, for instance, SHA-256
is broken badly enough that it implicates HMAC, it seems
likely that we're going to have so many other cryptographic
problems that the remaining security of TCP-AO will be the
least of our worries.


> >> Two MACs with differing internal constructions are
> >> desired.
> >
> > I don't understand this either. Most modern MACs are constructed =
from
> > two pieces:
> >
> > - An underlying cryptographic function
> > - A composition operation
> >
> > Thus, for instance, HMAC-SHA1 is constructed by using the HMAC
> > composition operation with SHA-1. In general, the security =
properties
> > of the composition operations are well understood (often with some
> > kind of reduction proof) where the security properties of the
> > underlying function are unproven. So, while it might make sense
> > to have two different base cryptographic functions (e.g.,
> > SHA-1 and SHA-256), it's not at all clear that it's of that
> > much value to have two different constructions.
>
> Agreed that if two RTI MACs are chosen that the MACs must be=20
> significantly different. That's why the proposed set includes one of=20
> SHA-1 using HMAC (a Wegman-Carter MAC), and another of AES using CMAC=20
> (a cipher block chaining mode intended for authentication).

I'm not sure why you say "agreed". As I said, I don't agree with this.

On the contrary, I don't see much value in using different
constructions. There's no reason to believe there's anything wrong
with HMAC, the issue (to the extent to which there is any) is purely
with the digests used by HMAC. If, for some reason, there is a perceived
need to specify two functions HMAC with two different (potentially
unrelated) digests seems fine.

-Ekr



_______________________________________________
saag mailing list
saag@mit.edu
http://mailman.mit.edu/mailman/listinfo/saag



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<HTML dir=3Dltr><HEAD><TITLE>Re: [saag] TCP-AO MAC algorithms</TITLE>=0A=
<META http-equiv=3DContent-Type content=3D"text/html; charset=3Dunicode">=0A=
<META content=3D"MSHTML 6.00.6000.16609" name=3DGENERATOR></HEAD>=0A=
<BODY>=0A=
<DIV id=3DidOWAReplyText85547 dir=3Dltr>=0A=
<DIV dir=3Dltr><FONT face=3DArial color=3D#000000 size=3D2>To tie a =
number of threads together here I think it would help enormously if we =
had some sort of cross IETF statement of the set of algorithms that are =
currently the consensus recommendations for support.</FONT></DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2>I don't think that there is a =
lot of disagreement on the important points, e.g. :</FONT></DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2>* If you are designing an =
entirely new protocol that requires block encryption specify AES-128 and =
AES-256 as MUST</FONT></DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2>* The use of 3DES, HMAC-SHA1, =
should be avoided in entirely new protocols but is not cause for concern =
in deployed&nbsp;protocols.</FONT></DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2>* Use of SHA1 should be =
avoided except in deployed protocols where there has been careful =
analysis that demonstrates use in that application is not cause for =
concern.</FONT></DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2>* Use of MD5, ciphers with a =
strength of 56 bits or less should be avoided in almost all =
circumstances. Use of ciphers with key sizes of 64 bits or less should =
be discontinued as soon as is practicable.</FONT></DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2>* If someone wants to specify =
vanity crypto, give them the necessary URI or OID and tell them to use =
it at their own discretion.</FONT></DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2>I don't think we should have =
this discussion in every individual working group. </FONT></DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2>I especially don't want to =
have to have the discussion on how to use ECC with each individual IETF =
spec in turn. Or worse have extended discussions over the optimal choice =
of group etc. so that we end up with different choices across the IETF. =
If the specifications are well designed we should have all the =
information necessary to specify how to use algorithms across the =
board.</FONT></DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2></FONT>&nbsp;</DIV>=0A=
<DIV dir=3Dltr><FONT face=3DArial size=3D2>As things stand I think we =
are going to end up with more crypto configurations in IETF protocols =
than we have crypto people. And that would be a bad thing when there is =
a pretty strong consensus on preferred algorithms in the =
field.</FONT></DIV></DIV>=0A=
<DIV dir=3Dltr><BR>=0A=
<HR tabIndex=3D-1>=0A=
<FONT face=3DTahoma size=3D2><B>From:</B> saag-bounces@mit.edu on behalf =
of Eric Rescorla<BR><B>Sent:</B> Fri 04/01/2008 7:44 PM<BR><B>To:</B> =
Brian Weis<BR><B>Cc:</B> saag@mit.edu<BR><B>Subject:</B> Re: [saag] =
TCP-AO MAC algorithms<BR></FONT><BR></DIV>=0A=
<DIV>=0A=
<P><FONT size=3D2>At Fri, 4 Jan 2008 15:06:59 -0800,<BR>Brian Weis =
wrote:<BR>&gt;<BR>&gt;<BR>&gt; On Dec 31, 2007, at 6:06 PM, Eric =
Rescorla wrote:<BR>&gt;<BR>&gt; &gt; At Tue, 18 Dec 2007 16:23:51 =
-0800,<BR>&gt; &gt; Brian Weis wrote:<BR>&gt; &gt;&gt;<BR>&gt; &gt;&gt; =
Greetings,<BR>&gt; &gt;&gt;<BR>&gt; &gt;&gt; The TCPM WG seeks advice =
from SAAG on which MACs to include as<BR>&gt; &gt;&gt; required MACs for =
the TCP Authentication Option (draft-ietf-tcpm-tcp-<BR>&gt; &gt;&gt; =
auth-opt-00).<BR>&gt; &gt;<BR>&gt; &gt; I would note that TLS has one =
MTI MAC (HMAC-SHA1) and based on RFC<BR>&gt; &gt; 4835, so does ESP/AH =
(HMAC-SHA1-96). What's the rationale for why<BR>&gt; &gt; TCP-AO should =
have stricter MTI requirements than we have for<BR>&gt; &gt; our =
dedicated security protocols?<BR>&gt;<BR>&gt; The rationale is simply =
that two methods with differing internal&nbsp;<BR>&gt; constructions =
implies that the standard is better prepared for the&nbsp;<BR>&gt; =
future (if one of the two MACs is perceived to be broken).<BR><BR>Yes, =
this strikes me as massive overkill, given that typical<BR>MAC =
constructions are designed with some kind of reduction<BR>to the =
primitive they are based on. If, for instance, SHA-256<BR>is broken =
badly enough that it implicates HMAC, it seems<BR>likely that we're =
going to have so many other cryptographic<BR>problems that the remaining =
security of TCP-AO will be the<BR>least of our worries.<BR><BR><BR>&gt; =
&gt;&gt; Two MACs with differing internal constructions are<BR>&gt; =
&gt;&gt; desired.<BR>&gt; &gt;<BR>&gt; &gt; I don't understand this =
either. Most modern MACs are constructed from<BR>&gt; &gt; two =
pieces:<BR>&gt; &gt;<BR>&gt; &gt; - An underlying cryptographic =
function<BR>&gt; &gt; - A composition operation<BR>&gt; &gt;<BR>&gt; =
&gt; Thus, for instance, HMAC-SHA1 is constructed by using the =
HMAC<BR>&gt; &gt; composition operation with SHA-1. In general, the =
security properties<BR>&gt; &gt; of the composition operations are well =
understood (often with some<BR>&gt; &gt; kind of reduction proof) where =
the security properties of the<BR>&gt; &gt; underlying function are =
unproven. So, while it might make sense<BR>&gt; &gt; to have two =
different base cryptographic functions (e.g.,<BR>&gt; &gt; SHA-1 and =
SHA-256), it's not at all clear that it's of that<BR>&gt; &gt; much =
value to have two different constructions.<BR>&gt;<BR>&gt; Agreed that =
if two RTI MACs are chosen that the MACs must be&nbsp;<BR>&gt; =
significantly different. That's why the proposed set includes one =
of&nbsp;<BR>&gt; SHA-1 using HMAC (a Wegman-Carter MAC), and another of =
AES using CMAC&nbsp;<BR>&gt; (a cipher block chaining mode intended for =
authentication).<BR><BR>I'm not sure why you say "agreed". As I said, I =
don't agree with this.<BR><BR>On the contrary, I don't see much value in =
using different<BR>constructions. There's no reason to believe there's =
anything wrong<BR>with HMAC, the issue (to the extent to which there is =
any) is purely<BR>with the digests used by HMAC. If, for some reason, =
there is a perceived<BR>need to specify two functions HMAC with two =
different (potentially<BR>unrelated) digests seems =
fine.<BR><BR>-Ekr<BR><BR><BR><BR>________________________________________=
_______<BR>saag mailing list<BR>saag@mit.edu<BR><A =
href=3D"http://mailman.mit.edu/mailman/listinfo/saag">http://mailman.mit.=
edu/mailman/listinfo/saag</A><BR></FONT></P></DIV></BODY></HTML>
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From vishwas.ietf@gmail.com Fri Feb 15 12:49:55 2008
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From: "Vishwas Manral" <vishwas.ietf@gmail.com>
To: "Hallam-Baker, Phillip" <pbaker@verisign.com>
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Hi Phillip,

I agree we probably could have some document talking about generic
recommendations like those you suggest. However I would feel every
application may have its own set of requirements which may overlap but
not necessarily be the same. Not all applications require the same
level of security.

That said I would think the TCP-AO draft should follow the
recommendations of RFC4835 like Eric mentioned earlier.

Thanks,
Vishwas

2008/2/14 Hallam-Baker, Phillip <pbaker@verisign.com>:
>
>
>
> To tie a number of threads together here I think it would help enormously if
> we had some sort of cross IETF statement of the set of algorithms that are
> currently the consensus recommendations for support.
>
> I don't think that there is a lot of disagreement on the important points,
> e.g. :
>
> * If you are designing an entirely new protocol that requires block
> encryption specify AES-128 and AES-256 as MUST
>
> * The use of 3DES, HMAC-SHA1, should be avoided in entirely new protocols
> but is not cause for concern in deployed protocols.
>
> * Use of SHA1 should be avoided except in deployed protocols where there has
> been careful analysis that demonstrates use in that application is not cause
> for concern.
>
> * Use of MD5, ciphers with a strength of 56 bits or less should be avoided
> in almost all circumstances. Use of ciphers with key sizes of 64 bits or
> less should be discontinued as soon as is practicable.
>
> * If someone wants to specify vanity crypto, give them the necessary URI or
> OID and tell them to use it at their own discretion.
>
>
> I don't think we should have this discussion in every individual working
> group.
>
> I especially don't want to have to have the discussion on how to use ECC
> with each individual IETF spec in turn. Or worse have extended discussions
> over the optimal choice of group etc. so that we end up with different
> choices across the IETF. If the specifications are well designed we should
> have all the information necessary to specify how to use algorithms across
> the board.
>
> As things stand I think we are going to end up with more crypto
> configurations in IETF protocols than we have crypto people. And that would
> be a bad thing when there is a pretty strong consensus on preferred
> algorithms in the field.
>
>  ________________________________
>  From: saag-bounces@mit.edu on behalf of Eric Rescorla
> Sent: Fri 04/01/2008 7:44 PM
> To: Brian Weis
> Cc: saag@mit.edu
> Subject: Re: [saag] TCP-AO MAC algorithms
>
>
>
>
> At Fri, 4 Jan 2008 15:06:59 -0800,
> Brian Weis wrote:
> >
> >
> > On Dec 31, 2007, at 6:06 PM, Eric Rescorla wrote:
> >
> > > At Tue, 18 Dec 2007 16:23:51 -0800,
> > > Brian Weis wrote:
> > >>
> > >> Greetings,
> > >>
> > >> The TCPM WG seeks advice from SAAG on which MACs to include as
> > >> required MACs for the TCP Authentication Option (draft-ietf-tcpm-tcp-
> > >> auth-opt-00).
> > >
> > > I would note that TLS has one MTI MAC (HMAC-SHA1) and based on RFC
> > > 4835, so does ESP/AH (HMAC-SHA1-96). What's the rationale for why
> > > TCP-AO should have stricter MTI requirements than we have for
> > > our dedicated security protocols?
> >
> > The rationale is simply that two methods with differing internal
> > constructions implies that the standard is better prepared for the
> > future (if one of the two MACs is perceived to be broken).
>
> Yes, this strikes me as massive overkill, given that typical
> MAC constructions are designed with some kind of reduction
> to the primitive they are based on. If, for instance, SHA-256
> is broken badly enough that it implicates HMAC, it seems
> likely that we're going to have so many other cryptographic
> problems that the remaining security of TCP-AO will be the
> least of our worries.
>
>
> > >> Two MACs with differing internal constructions are
> > >> desired.
> > >
> > > I don't understand this either. Most modern MACs are constructed from
> > > two pieces:
> > >
> > > - An underlying cryptographic function
> > > - A composition operation
> > >
> > > Thus, for instance, HMAC-SHA1 is constructed by using the HMAC
> > > composition operation with SHA-1. In general, the security properties
> > > of the composition operations are well understood (often with some
> > > kind of reduction proof) where the security properties of the
> > > underlying function are unproven. So, while it might make sense
> > > to have two different base cryptographic functions (e.g.,
> > > SHA-1 and SHA-256), it's not at all clear that it's of that
> > > much value to have two different constructions.
> >
> > Agreed that if two RTI MACs are chosen that the MACs must be
> > significantly different. That's why the proposed set includes one of
> > SHA-1 using HMAC (a Wegman-Carter MAC), and another of AES using CMAC
> > (a cipher block chaining mode intended for authentication).
>
> I'm not sure why you say "agreed". As I said, I don't agree with this.
>
> On the contrary, I don't see much value in using different
> constructions. There's no reason to believe there's anything wrong
> with HMAC, the issue (to the extent to which there is any) is purely
> with the digests used by HMAC. If, for some reason, there is a perceived
> need to specify two functions HMAC with two different (potentially
> unrelated) digests seems fine.
>
> -Ekr
>
>
>
> _______________________________________________
> saag mailing list
> saag@mit.edu
> http://mailman.mit.edu/mailman/listinfo/saag
>
> _______________________________________________
>  saag mailing list
>  saag@mit.edu
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>

From rja@extremenetworks.com Sat Feb 16 18:43:27 2008
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From: Randall Atkinson <rja@extremenetworks.com>
To: "saag@mit.edu" <saag@mit.edu>
Date: Sat, 16 Feb 2008 15:42:57 -0800
Thread-Topic: Algorithms/modes requested by users/customers
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Earlier, someone said:
% I think it would help enormously if we had some sort of
% cross IETF statement of the set of algorithms that are
% currently the consensus recommendations for support.

I will answer a slightly different question.  For the question:
     "What algorithms/modes are most paying customers asking for ?"
the answers turn out to be:

1) NIST FIPS-140 conforming algorithms/modes.
and
2) Suite-B conforming algorithms/modes.

Approximately speaking, (2) above is a subset of (1) above.

The IETF might make some different decision than those,
but equipment vendors will have to implement (1) or (2)
to please most commercial users (e.g. banks, insurance firms,
stock brokerages/markets, top international commercial
firms in other areas).  So whether or not these are specified
by IETF on the standards-track, there is interoperability value
in having open specifications (e.g. Informational RFC would
do quite nicely) for (1) and (2) for nearly any Internet-related
protocol using cryptography.

This seems to be driven externally by insurance firms that tell
their customers to only use equipment whose cryptographic
subsystems/modules have been (or are going to be) evaluated
formally under FIPS-140.

And I'll note that this are not really driven particularly by US firms.
European, Asia/Pacific, and Latin American firms are making the
exact same requests for FIPS-140 of their equipment vendors.

Yours,

Ran
rja@extremenetworks.com




From paul.hoffman@vpnc.org Sun Feb 17 12:48:54 2008
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At 3:42 PM -0800 2/16/08, Randall Atkinson wrote:
>1) NIST FIPS-140 conforming algorithms/modes.
>and
>2) Suite-B conforming algorithms/modes.

This seems reasonable, and similar to what I hear from VPNC members. 
(Sadly, these same members ship new equipment defaulting to 
algorithms not in that list, but that's a different thread...)

>This seems to be driven externally by insurance firms that tell
>their customers to only use equipment whose cryptographic
>subsystems/modules have been (or are going to be) evaluated
>formally under FIPS-140.

That is unreasonable. The ratio of "number of systems that use 
crypto" to "number of systems that have been or are going to be 
evaluated formally under FIPS-140" is incredibly high. The FIPS 140 
evaluation process is horribly broken on a number of axes, and all 
the vendors in the field know it and complain privately about it.

If you had instead said "have been (or at least could be) evaluated", 
I would agree with you. Buyers want to know that, if pressed hard, 
they can say "well, it is like that other system over there that got 
certified", and to do that, the uncertified system has to at least 
support all the right crypto. There is a noticeable but 
non-quantifiable preference for systems with a FIPS 140 certificate, 
but (outside the USGovt, of course) nearly no hard demand.

>And I'll note that this are not really driven particularly by US firms.
>European, Asia/Pacific, and Latin American firms are making the
>exact same requests for FIPS-140 of their equipment vendors.

I have heard that as well from VPNC members. But note the use of the 
term "requests".

It would be a mistake for the IETF to look like we support the FIPS 
140 certification process, even though it makes good sense for us to 
use the algorithms in that process as the basis for a suggested 
cross-IETF algorithm suite.

--Paul Hoffman, Director
--VPN Consortium

From rja@extremenetworks.com Sun Feb 17 20:07:54 2008
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Earlier Paul Hoffman said:
% If you had instead said "have been (or at least could be) evaluated",
% I would agree with you. Buyers want to know that, if pressed hard,
% they can say "well, it is like that other system over there that got
% certified", and to do that, the uncertified system has to at least
% support all the right crypto. There is a noticeable but
% non-quantifiable preference for systems with a FIPS 140 certificate,
% but (outside the USGovt, of course) nearly no hard demand.

It seems that what you are hearing and what I am hearing
differ somewhat in this area.

As an example, I've had multiple large non-US commercial firms
in the City of London tell me that they require FIPS-140 approvals
for cryptographic equipment they will purchase -- and that this
was originally the idea of their insurers.   These same firms have
very substantial networking deployments at present and purchase
equipment in large quantities.

Separately, several governments other than the USA are requiring
FIPS-140 approvals in equipment that they purchase.  These
other countries include places in Europe and Asia/Pacific and
other continents/regions.  Again, the volume of such systems is
both non-trivial and quantifiable.

% It would be a mistake for the IETF to look like we support
% the FIPS 140 certification process,

So far as I am aware, your comments above are the first suggestion
of that.  Certainly I did NOT suggest that and don't suggest it now.

% even though it makes good sense for us to use the algorithms in
% that process as the basis for a suggested cross-IETF algorithm suite.

That is farther than I went.  I simply suggested that there ought to
be open specifications for how to use FIPS-conformant algorithms
and modes with Internet protocols.  An "open specification" could be
an Informational status RFC, for example.  That way users who
do care about FIPS approvals would have a reasonable shot at
being able to  purchase interoperable equipment from multiple vendors
-- and implementers would have a clear specification to work with.

I did not (and do not now) advocate that the IETF standards track
ought to do any particular thing with respect to cryptographic
algorithms/modes.

Yours,

Ran Atkinson
rja@extremenetworks.com





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At 9:47 AM -0800 2/17/08, Paul Hoffman wrote:
>...
>>This seems to be driven externally by insurance firms that tell
>>their customers to only use equipment whose cryptographic
>>subsystems/modules have been (or are going to be) evaluated
>>formally under FIPS-140.
>
>That is unreasonable. The ratio of "number of systems that use
>crypto" to "number of systems that have been or are going to be
>evaluated formally under FIPS-140" is incredibly high. The FIPS 140
>evaluation process is horribly broken on a number of axes, and all
>the vendors in the field know it and complain privately about it.
>
>If you had instead said "have been (or at least could be) evaluated",
>I would agree with you. Buyers want to know that, if pressed hard,
>they can say "well, it is like that other system over there that got
>certified", and to do that, the uncertified system has to at least
>support all the right crypto. There is a noticeable but
>non-quantifiable preference for systems with a FIPS 140 certificate,
>but (outside the USGovt, of course) nearly no hard demand.

Paul,

Can you share the reasons cited by vendors to support the notion that 
the FIPS 140 process is broken.  Compared to other security 
evaluation criteria, e.g. CC or the old Organge Book, most security 
folks I know view the FIPS 140 evaluation program as well managed and 
not very onerous.

Also, if buyers believe that a device that "could be evaluated" is 
good enough, they are being rather naive.  Experience with the FIPS 
140 program has shown that a significant fraction of of products 
submitted for evaluation fail the process. Presumably a vendor 
submitting a product for evaluation believes that the product is 
ready, and will pass, otherwise the vendor is wasting money on the 
evaluation effort. The fact that many products fail evaluation (for 
good security reasons), tells me that a vendor's claim that a product 
"could be evaluated" is not much of an assurance.

Steve

From rja@extremenetworks.com Tue Feb 19 10:35:40 2008
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Earlier, Steve Kent wrote:
% Also, if buyers believe that a device that "could be evaluated" is
% good enough, they are being rather naive.  Experience with the
% FIPS 140 program has shown that a significant fraction of of
% products submitted for evaluation fail the process.

The quoted text above is fully consistent with my information
(and my very limited personal experience) on this topic.

% Presumably a vendor submitting a product for evaluation
% believes that the product is ready, and will pass, otherwise the
% vendor is wasting money on the evaluation effort.

Some purchasers, including some US DoD components, do not
require that a product actually be FIPS-140 certified in order
for the purchaser to buy the product.  Instead, some purchasers,
including some US DoD components, only require that a product
be "in evaluation" on the NIST web site in order to bid/sell that
product.

This can incent some vendors to submit products for FIPS-140
evaluation in order to bid/sell the product -- even if the vendor
is unsure whether the product will pass that evaluation at that
point in time.  This last is a business decision based on various
business factors, and is not necessarily a technical decision.

Separately, there is substantial documentation required to pass a
FIPS-140 evaluation, and it is not crystal clear upfront what level
of detail on which topics is required to pass the evaluation.  So,
separate from the question of whether the product itself is ready,
there is usually substantial documentation work required of the
submitter after the formal FIPS-140 evaluation commences.

The one area where I have heard concerns expressed by many
implementers is that it can be difficult/time-consuming/expensive
to "RAMP" an approved product so that a later version is
approved formally under FIPS-140.  I don't know if this is an
actual process issue or merely a perceived issue.  At least one
implementer has commented to me that their latest FIPS-approved
firmware has known-bugs fixed in subsequent non-FIPS-approved
firmware because of (real or perceived) "RAMP" process issues.

% The fact that  many products fail evaluation (for good security
% reasons), tells me that a vendor's claim that a product
% "could be evaluated" is not much of an assurance.

Agreed.  And this point has been made to me by several different
commercial/financial firms.  It is not a coincidence that the
encryptor I use at my home has an actual FIPS-140 certificate,
nor that I use that system in FIPS mode.

(And at this point, I seem a bit far from the charter of the SAAG
list, but I'm not sure where followups should go.   My apologies
to any who viewed this as excessively off-topic.)

Yours,

Ran
rja@extremenetworks.com

DISCLAIMER:  I am employed by Extreme Networks, but I am never
authorised to speak for my employer.  The text from me above
is my own personal views/understanding, and must not be taken
as a position held by my employer.





From paul.hoffman@vpnc.org Tue Feb 19 11:19:18 2008
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Date: Tue, 19 Feb 2008 08:18:24 -0800
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At 10:15 AM -0500 2/19/08, Stephen Kent wrote:
>Can you share the reasons cited by vendors to support the notion 
>that the FIPS 140 process is broken.

Sure.

- It takes way too long from submission of system to validation, even 
if no problems are found.

- If problems are found during evaluation, the restart time is too long.

- Some of the tests are fairly subjective, and it becomes a game of 
fixing code to please the testing service, not to make the product 
more secure.

- An evaluated product cannot have its core firmware updated without 
losing the validation. For example, if a customer asks for a new 
feature that might touch the crypto, the vendor has to choose between 
losing the validation (and paying for a new one, and waiting for the 
results) or keeping the customer happy.

- The validation doesn't even check for on-the-wire interoperability, 
which is what the customers care about most.

- The test process is too expensive for many low-end devices that 
would be very useful in USGovt offices.

- The system introduces silly modes that make the systems more complicated.

These are the top complaints I hear from both large and small 
vendors. There are certainly others. "Oh, don't get me started" is 
commonly heard when discussing FIPS 140 testing.

>   Compared to other security evaluation criteria, e.g. CC or the old 
>Organge Book, most security folks I know view the FIPS 140 
>evaluation program as well managed and not very onerous.

"Security folks" are not good evaluators on how some processes affect 
the market.

>Also, if buyers believe that a device that "could be evaluated" is 
>good enough, they are being rather naive.

Maybe. If a buyer cares about "does this box support the needed 
crypto in an interoperable fashion", then the perception is fine. If 
they care about all the details that FIPS 140 testing covers, then of 
course it is naive.

>Experience with the FIPS 140 program has shown that a significant 
>fraction of of products submitted for evaluation fail the process.

This statement is usually bandied about without any quantification of 
what failures were found, as it is here. As someone who creates test 
suites, I can assure you that I can make a few picky rules for 
systems that would cause some of those systems to fail, but most end 
users who understood those few rules would say that those rules were 
silly. Of course, different end users have different requirements. It 
is generally felt by vendors that some/many of the rules for FIPS 140 
are silly and unneeded; on the other hand, it is likely that at least 
a few USGovt customers would really want some of those rules for 
particular reasons.

>Presumably a vendor submitting a product for evaluation believes 
>that the product is ready, and will pass, otherwise the vendor is 
>wasting money on the evaluation effort.

Wrong, very wrong. You cannot tell what the testing agency might try 
to knock you down on ahead of time. Of course, you cover what you 
can, but you also know that there is a good chance they'll just whack 
you a bit because it makes them look good.

>The fact that many products fail evaluation (for good security 
>reasons), tells me that a vendor's claim that a product "could be 
>evaluated" is not much of an assurance.

If you believe in the testing regime, that's fine. Others don't, and 
I believe for very good reasons in their own use scenarios.

--Paul Hoffman, Director
--VPN Consortium

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Date: Tue, 19 Feb 2008 10:04:12 -0800
To: "Santosh Chokhani" <SChokhani@cygnacom.com>, "Stephen Kent" <kent@bbn.com>
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At 11:49 AM -0500 2/19/08, Santosh Chokhani wrote:
>On the issue of restart, that is misunderstanding on Paul's part.  There
>is no restart.

Ahem. I am reporting what the members of VPNC report to me. They are 
the vendors in the testing, not me. I have heard this from multiple 
vendors. If I was not clear that I was reporting what others said, I 
apologize.

>Generally, problem is fixed and you pick up that point.

Not to be too picky, but how can you say "generally" without seeing 
every test that was stopped? Maybe you have not had this problem, but 
others say they have.

>Subjective tests seems to be misunderstanding on Paul's part.  Having
>been in the Orange Book, CC and FIPS process, I as validator, tester,
>and certifier as well as vendor generally rue about rigidness of the
>standard and lack of subjective judgment on the part of the tester or
>lack of subjective latitude to vendors.

If you, as a tester, feel that there are no subjective parts of the 
test process, that's fine. Some/many people who are being tested 
disagree with you.

>FIPS 140 has specific guidelines on how to deal with minor incremental
>changes that helps reduce cost and calendar time.

Great! It does not seem to have gotten through to the vendors 
themselves as "inexpensive enough" or "fast enough". As a tester, you 
may have a different view.

>The standard is NOT a protocol standard.  It does verify the algorithm
>implementations and thus, FIPS validated algorithms can interoperate.

Quite true.

>In terms of low end devices, 20-30K for level 1 testing amortized over
>devices does not seem too onerous.

...to you. Others disagree, both on the financial cost, and 
particularly on the cost of elapsed time before customers can use the 
latest release from a vendor.

>I do not understand what Paul refers to as silly modes.  The module
>being FIPS validated must use FIPS validated or recognized algorithms
>for a given crypto service.  That seems like a good thing to me.

That is a good thing; it is also not what I was talking about. There 
is disagreement about what needs to be in a "FIPS mode", and whether 
the shipped product needs to allow "FIPS mode" to be enabled, and if 
so, how.

Again: I am reporting what I hear from many VPNC members over many 
years. You as a single vendor and/or tester might feel differently; 
your feeling does not invalidate the views of others.

--Paul Hoffman, Director
--VPN Consortium

From lloyd@randombit.net Tue Feb 19 13:10:45 2008
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On Tue, Feb 19, 2008 at 08:18:24AM -0800, Paul Hoffman wrote:

> - Some of the tests are fairly subjective, and it becomes a game of 
> fixing code to please the testing service, not to make the product 
> more secure.
[...]
> - The system introduces silly modes that make the systems more complicated.

I have no experience with the purchasing side, but in my experience
doing FIPS 140 validations, we often had to ask vendors to include
hooks for testing that, from any objective standpoint, made the system
less secure. And because the tests must be made on the same
firmware/software as the as-shipped one (not in a special test/debug
mode), that increased the attack surface of some of these devices
greatly. I will fondly remember the validation where I found several
exploitable buffer overflows in an HSM that had already passed two
previous validations - all the holes were found in the hooks used for
FIPS-140 testing.

The tests that require the RNG be able to seeded with fixed data
always seeemed particularly troublesome/dangerous to me.

Obvious disclaimer: Anecdotes are not data - I just thought a
relatively concrete example might be relevant to the discussion at
hand.

-Jack

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At 1:13 PM -0500 2/19/08, Santosh Chokhani wrote:
>My general observation is that vendors do not assign their engineers to
>these efforts and there is a dearth of qualified testers, resulting in
>blind leading the blind.

That is a fairly damning criticism of the process, of course.

It would not be bad if this were a voluntary logo program like VPNC 
or ICSA Labs has; when it prevents a large customer (many large 
customers, according to Ran) from buying up-to-date equipment that 
meets their security needs, it has serious implications for the 
security of the purchasers.

--Paul Hoffman, Director
--VPN Consortium

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Hi Ran,

Winston Churchill said that democracy is the worst form of government,
except for all of the others.  I think that the same is true for the
FIPS-140 cryptomodule validation process ;-)

I agree with you that there is good value in having open specs for FIPS-140
and Suite-B versions of Internet protocols (even though I also agree with
many of the criticisms of the validation process made on this thread).   I
expect that the choice of which algorithm(s) should be
mandatory-to-implement will continue to be made on the basis of technical
(well, mostly technical) discussions in the WGs.

Best,

David


On 2/16/08 3:42 PM, "Randall Atkinson" <rja@extremenetworks.com> wrote:

> Earlier, someone said:
> % I think it would help enormously if we had some sort of
> % cross IETF statement of the set of algorithms that are
> % currently the consensus recommendations for support.
> 
> I will answer a slightly different question.  For the question:
>      "What algorithms/modes are most paying customers asking for ?"
> the answers turn out to be:
> 
> 1) NIST FIPS-140 conforming algorithms/modes.
> and
> 2) Suite-B conforming algorithms/modes.
> 
> Approximately speaking, (2) above is a subset of (1) above.
> 
> The IETF might make some different decision than those,
> but equipment vendors will have to implement (1) or (2)
> to please most commercial users (e.g. banks, insurance firms,
> stock brokerages/markets, top international commercial
> firms in other areas).  So whether or not these are specified
> by IETF on the standards-track, there is interoperability value
> in having open specifications (e.g. Informational RFC would
> do quite nicely) for (1) and (2) for nearly any Internet-related
> protocol using cryptography.
> 
> This seems to be driven externally by insurance firms that tell
> their customers to only use equipment whose cryptographic
> subsystems/modules have been (or are going to be) evaluated
> formally under FIPS-140.
> 
> And I'll note that this are not really driven particularly by US firms.
> European, Asia/Pacific, and Latin American firms are making the
> exact same requests for FIPS-140 of their equipment vendors.
> 
> Yours,
> 
> Ran
> rja@extremenetworks.com
> 
> 
> 
> _______________________________________________
> saag mailing list
> saag@mit.edu
> http://mailman.mit.edu/mailman/listinfo/saag


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At 8:18 AM -0800 2/19/08, Paul Hoffman wrote:
>At 10:15 AM -0500 2/19/08, Stephen Kent wrote:
>>Can you share the reasons cited by vendors to support the notion 
>>that the FIPS 140 process is broken.
>
>Sure.
>
>- It takes way too long from submission of system to validation, 
>even if no problems are found.

I have gone through a level 3 eval and compared to ALL other security 
criteria evaluations, the time to perform the eval is much, much 
better. So, my guess is that anyone complaining about this has no 
experience with evals for things like CC.

>- If problems are found during evaluation, the restart time is too long.

ibid.

>- Some of the tests are fairly subjective, and it becomes a game of 
>fixing code to please the testing service, not to make the product 
>more secure.

It is true that some test criteria are not completely cut and dried. 
That is a problem with every one of these secruity eval criteria. My 
experience is that FIPS 40 is better i this regard than all the 
others.

>- An evaluated product cannot have its core firmware updated without 
>losing the validation. For example, if a customer asks for a new 
>feature that might touch the crypto, the vendor has to choose 
>between losing the validation (and paying for a new one, and waiting 
>for the results) or keeping the customer happy.

Absolutely right, and it should be that way! To expect otherwise is 
to fail to understand what a security eval is al about. However, the 
representation above is silly. The old product with the old feature 
set is still validated. It's the new version that cannot yet be sold 
as evaluated. When we had a level 3 device, we also sold a version 
that was not yet evaluated, but had nifty new features, and explained 
the situation to clients, some of who opted for the old version until 
the new version was evaluated.

>- The validation doesn't even check for on-the-wire 
>interoperability, which is what the customers care about most.

It's a crypto security eval criteria, not a protocol compliance eval 
criteria. The labs are not testers of IPsec or TLS; they are testers 
of crypto module functions, period. a buyer who doesn't understand 
that is misinformed.

>- The test process is too expensive for many low-end devices that 
>would be very useful in USGovt offices.
>
>- The system introduces silly modes that make the systems more complicated.

e.g., ?

>These are the top complaints I hear from both large and small 
>vendors. There are certainly others. "Oh, don't get me started" is 
>commonly heard when discussing FIPS 140 testing.

Whiners :-).

>>   Compared to other security evaluation criteria, e.g. CC or the 
>>old Organge Book, most security folks I know view the FIPS 140 
>>evaluation program as well managed and not very onerous.
>
>"Security folks" are not good evaluators on how some processes 
>affect the market.

But we are experienced with various security eval criteria, and one 
ought to judge such criteria in context. In that context FIPS 140 is 
viewed as having a great track record.

>
>>Also, if buyers believe that a device that "could be evaluated" is 
>>good enough, they are being rather naive.
>
>Maybe. If a buyer cares about "does this box support the needed 
>crypto in an interoperable fashion", then the perception is fine. If 
>they care about all the details that FIPS 140 testing covers, then 
>of course it is naive.

Your statement seems to conflate two very separate issues.  if a 
buyer is concerned primarily with interoperability or (non-crypto) 
standards compliance, then FIPS 140 is irrelevant.  if they care 
about whether a product that purports to use crypto for security does 
so securely, then FIPS 140 eval is a solid prerequisite.  I think a 
client who cares more about interoperability of a crypto-based 
security product than the security of the product is naive.

>
>>Experience with the FIPS 140 program has shown that a significant 
>>fraction of of products submitted for evaluation fail the process.
>
>This statement is usually bandied about without any quantification 
>of what failures were found, as it is here. As someone who creates 
>test suites, I can assure you that I can make a few picky rules for 
>systems that would cause some of those systems to fail, but most end 
>users who understood those few rules would say that those rules were 
>silly. Of course, different end users have different requirements. 
>It is generally felt by vendors that some/many of the rules for FIPS 
>140 are silly and unneeded; on the other hand, it is likely that at 
>least a few USGovt customers would really want some of those rules 
>for particular reasons.

I have served several terms on an committee operated by the National 
Academy of Sciences that provides an external review for the NIST 
Security Lab. In our review meetings I have seen the figures for the 
pas/fail rate, and have seen descriptions of the reasons for 
failures, some of which are hilariously bad. I is not only US 
Givernment clients who care about most of the "picky rules."  The 
banking community has mandated FIPS evaluation for years. However, if 
a client is more concerned about the performance of a VPN appliance 
than the security of the device, FIPS 140 is not a good criteria for 
that client.

>
>>Presumably a vendor submitting a product for evaluation believes 
>>that the product is ready, and will pass, otherwise the vendor is 
>>wasting money on the evaluation effort.
>
>Wrong, very wrong. You cannot tell what the testing agency might try 
>to knock you down on ahead of time. Of course, you cover what you 
>can, but you also know that there is a good chance they'll just 
>whack you a bit because it makes them look good.

Nonsense, utter nonsense (says the guy who went trough this process, 
as opposed to the guy who is relating what he has been told by 
others). The criteria are complemented by guidelines for eval labs, 
and these guidelines are available to vendors. So, a smart vendor 
would study the criteria and the guidelines before designing a 
product that will be evaluated. A smart vendor will discuss the 
criteria with the lad it chooses, to minimize uncertainty.

>>The fact that many products fail evaluation (for good security 
>>reasons), tells me that a vendor's claim that a product "could be 
>>evaluated" is not much of an assurance.
>
>If you believe in the testing regime, that's fine. Others don't, and 
>I believe for very good reasons in their own use scenarios.

What I said is true, irrespective of whether one believes in the 
criteria or the testing methodology. The reality is the products 
fail, and many  (not all) of the failures are demonstrably due to 
serious security problems. So, given this experience, one really 
ought not believe a vendor (whose goal is to sell products) who says 
"oh yeah, our product would pass evaluation, but we don't think it's 
worth the investment." A client who believes this argument should buy 
a used car without a warranty or an inspection by a mechanic. The 
likelihood of a good outcome is similar.

Steve

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-----BEGIN PGP SIGNED MESSAGE-----
Hash: SHA1

At 1:13 PM -0500 2/19/08, Santosh Chokhani wrote:
> My general observation is that vendors do not assign their engineers  
> to
> these efforts and there is a dearth of qualified testers, resulting in
> blind leading the blind.

I want to agree with Paul Hoffman that FIPS 140 is unnecessarily  
painful. I think I will also agree with Stephen Kent and say that FIPS  
is to CC as laparoscopic surgery is to open heart.

Santosh also gets a big +1 from me, and I'll tell how even this dark  
cloud has a silver lining.

When PGP first went through FIPS 140, we assigned a dedicated engineer  
to the process. Shepherding software through FIPS 140 was so painful,  
so mind-numbing, so annoying that he quit the company, quit  
cryptography, and quit computer security altogether. He took a job  
with a company that produced MP3 music software. That company was  
bought out by Apple, and the software turned into what we now know as  
iTunes. He is at Apple to this day as the lead of iTunes.

So the next time you listen to an iPod, think about FIPS 140, and  
thank the horrible process.

	Jon


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Paul Hoffman <paul.hoffman@vpnc.org> writes:

Some quick notes on the consequences of three of these which may not be
immediately obvious:

>- It takes way too long from submission of system to validation, even if no
>problems are found.

Corollary: Users have the option of running a current, up-to-date non-
evaluated version or an obsolete evaluated version.  This becomes particularly
critical if there's a security advisory issued for the old version, because
you can't close the hole without losing the eval.  So you get the choice of
running an insecure FIPS 140-blessed version or a secure (well, as far as
anyone knows) non-FIPS 140-blessed version.  For some reason this doesn't seem
to go down well with customers.

>- Some of the tests are fairly subjective, and it becomes a game of fixing
>code to please the testing service, not to make the product more secure.

Corollary: You can get completely different results depending on how you
submit your product, and who to, and when.  I've heard of vendors doing the
equivalent of jury-shopping in order to ease the evaluation process.

>- The validation doesn't even check for on-the-wire interoperability, which
>is what the customers care about most.

Corollary: An ability to perform a TLS connect to Amazon (if the product is in
this case a TLS crypto system) tells the customer more than the FIPS 140 eval
ever can, since much of the TLS functionality is orthogonal to what FIPS 140
tests.

>"Oh, don't get me started" is commonly heard when discussing FIPS 140
>testing.

That's why I've tried to keep out of this so far :-).  Ask enough people and
you can get a very long list.  This and CC do make for good conversation
starters among security geeks though.

Peter.



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From: pgut001@cs.auckland.ac.nz (Peter Gutmann)
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mcgrew <mcgrew@cisco.com> writes:

>Winston Churchill said that democracy is the worst form of government, except
>for all of the others.  I think that the same is true for the FIPS-140
>cryptomodule validation process ;-)

I think it's more a case of the Politician's Fallacy:

1. Something must be done.
2. This is something.
3. This must be done.

It'd be interesting to see a study of the effectiveness in terms of finding
security and interop problems of:

A. A FIPS 140 eval.

B. Running the code through Fortify/Coverity/whatever and completing a crypto
   exchange with a peer (TLS, S/MIME, PGP, whatever the underlying crypto is
   that's being used).

in particular in terms of return for effort-involved.

Peter.

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From: "Steven M. Bellovin" <smb@cs.columbia.edu>
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On Thu, 21 Feb 2008 00:36:39 +1300
pgut001@cs.auckland.ac.nz (Peter Gutmann) wrote:

> mcgrew <mcgrew@cisco.com> writes:
> 
> >Winston Churchill said that democracy is the worst form of
> >government, except for all of the others.  I think that the same is
> >true for the FIPS-140 cryptomodule validation process ;-)
> 
> I think it's more a case of the Politician's Fallacy:
> 
> 1. Something must be done.
> 2. This is something.
> 3. This must be done.
> 
> It'd be interesting to see a study of the effectiveness in terms of
> finding security and interop problems of:
> 
> A. A FIPS 140 eval.
> 
> B. Running the code through Fortify/Coverity/whatever and completing
> a crypto exchange with a peer (TLS, S/MIME, PGP, whatever the
> underlying crypto is that's being used).
> 
> in particular in terms of return for effort-involved.

Right.  But here's the problem with this choice: FIPS-140 is mostly
about assurance of security, and not just correctness of the crypto.
Given the really bad mistakes we've all seen -- things that would be
caught by any decent outside evaluation -- what is the alternative?
What is the *assurance* a customer has that the product is adequately
secured?

		--Steve Bellovin, http://www.cs.columbia.edu/~smb

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"Steven M. Bellovin" <smb@cs.columbia.edu> writes:

>FIPS-140 is mostly about assurance of security, and not just correctness of
>the crypto.

Is it about assurance of security, or assurance of production of paperwork
showing the certification conditions have been met?  There have been plenty of
security advisories issued for CC and FIPS-140 evaluated products (and even
more not publicised but silently fixed in a certification-voiding manner).

>Given the really bad mistakes we've all seen -- things that would be caught
>by any decent outside evaluation -- what is the alternative? What is the
>*assurance* a customer has that the product is adequately secured?

Politician's Fallacy again: Is FIPS 140 really the best way to spend your
money?  If FIPS 140 is the answer now, why wasn't the Orange Book the answer
then?  What about giving the money to (picking a random name) Cigital and
saying "make sure this code is OK"?  What about giving the money to Dan
Bernstein and saying "implement this and make it secure"?  What about having
the code written by Germans and pen-tested by the French? [0].  We have no
hard data either way (although I'd put my money on Cigital and Dan to produce
the more secure product :-).  But simply saying "We must use FIPS 140...
just... well, just because!" is hardly a scientific approach to solving the
problem.

Peter.

[0] A very much under-exploited strategy in security evaluation.

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On the issue of it takes too long, the FIPS process is the envy of other
schemes.  One could always be faster.

On the issue of restart, that is misunderstanding on Paul's part.  There
is no restart.  Generally, problem is fixed and you pick up that point.
This is generally a vendor problem.  Depending on the nature of
problem/failure, other aspects of the testing can continue without loss
of calendar time.

Subjective tests seems to be misunderstanding on Paul's part.  Having
been in the Orange Book, CC and FIPS process, I as validator, tester,
and certifier as well as vendor generally rue about rigidness of the
standard and lack of subjective judgment on the part of the tester or
lack of subjective latitude to vendors.

FIPS 140 has specific guidelines on how to deal with minor incremental
changes that helps reduce cost and calendar time.

The standard is NOT a protocol standard.  It does verify the algorithm
implementations and thus, FIPS validated algorithms can interoperate.

In terms of low end devices, 20-30K for level 1 testing amortized over
devices does not seem too onerous.

I do not understand what Paul refers to as silly modes.  The module
being FIPS validated must use FIPS validated or recognized algorithms
for a given crypto service.  That seems like a good thing to me.



-----Original Message-----
From: saag-bounces@mit.edu [mailto:saag-bounces@mit.edu] On Behalf Of
Paul Hoffman
Sent: Tuesday, February 19, 2008 11:18 AM
To: Stephen Kent
Cc: saag@mit.edu; Randall Atkinson
Subject: Re: [saag] Algorithms/modes requested by users/customers

At 10:15 AM -0500 2/19/08, Stephen Kent wrote:
>Can you share the reasons cited by vendors to support the notion 
>that the FIPS 140 process is broken.

Sure.

- It takes way too long from submission of system to validation, even 
if no problems are found.

- If problems are found during evaluation, the restart time is too long.

- Some of the tests are fairly subjective, and it becomes a game of 
fixing code to please the testing service, not to make the product 
more secure.

- An evaluated product cannot have its core firmware updated without 
losing the validation. For example, if a customer asks for a new 
feature that might touch the crypto, the vendor has to choose between 
losing the validation (and paying for a new one, and waiting for the 
results) or keeping the customer happy.

- The validation doesn't even check for on-the-wire interoperability, 
which is what the customers care about most.

- The test process is too expensive for many low-end devices that 
would be very useful in USGovt offices.

- The system introduces silly modes that make the systems more
complicated.

These are the top complaints I hear from both large and small 
vendors. There are certainly others. "Oh, don't get me started" is 
commonly heard when discussing FIPS 140 testing.

>   Compared to other security evaluation criteria, e.g. CC or the old 
>Organge Book, most security folks I know view the FIPS 140 
>evaluation program as well managed and not very onerous.

"Security folks" are not good evaluators on how some processes affect 
the market.

>Also, if buyers believe that a device that "could be evaluated" is 
>good enough, they are being rather naive.

Maybe. If a buyer cares about "does this box support the needed 
crypto in an interoperable fashion", then the perception is fine. If 
they care about all the details that FIPS 140 testing covers, then of 
course it is naive.

>Experience with the FIPS 140 program has shown that a significant 
>fraction of of products submitted for evaluation fail the process.

This statement is usually bandied about without any quantification of 
what failures were found, as it is here. As someone who creates test 
suites, I can assure you that I can make a few picky rules for 
systems that would cause some of those systems to fail, but most end 
users who understood those few rules would say that those rules were 
silly. Of course, different end users have different requirements. It 
is generally felt by vendors that some/many of the rules for FIPS 140 
are silly and unneeded; on the other hand, it is likely that at least 
a few USGovt customers would really want some of those rules for 
particular reasons.

>Presumably a vendor submitting a product for evaluation believes 
>that the product is ready, and will pass, otherwise the vendor is 
>wasting money on the evaluation effort.

Wrong, very wrong. You cannot tell what the testing agency might try 
to knock you down on ahead of time. Of course, you cover what you 
can, but you also know that there is a good chance they'll just whack 
you a bit because it makes them look good.

>The fact that many products fail evaluation (for good security 
>reasons), tells me that a vendor's claim that a product "could be 
>evaluated" is not much of an assurance.

If you believe in the testing regime, that's fine. Others don't, and 
I believe for very good reasons in their own use scenarios.

--Paul Hoffman, Director
--VPN Consortium
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Paul,

These statements are not based on "feelings".  They are based on
experience of doing third party testing such as TPEP (TCSEC), TTAP
(TCSEC and CC), CC testing and FIPS since 1987 and being involved in the
FIPS program since its pre-formative days.

If there are specific concerns, I would be happy to look into those.

My general observation is that vendors do not assign their engineers to
these efforts and there is a dearth of qualified testers, resulting in
blind leading the blind.

If you get a good tester, he/she will force the vendor to provide a good
engineering answer and many of the general issues you are mentioning
will get tackled right.

I would recommend that VPNC members/vendors have good engineers making
sound arguments.  Most of the times, that works.

-----Original Message-----
From: Paul Hoffman [mailto:paul.hoffman@vpnc.org] 
Sent: Tuesday, February 19, 2008 1:04 PM
To: Santosh Chokhani; Stephen Kent
Cc: saag@mit.edu; Randall Atkinson
Subject: RE: [saag] Algorithms/modes requested by users/customers

At 11:49 AM -0500 2/19/08, Santosh Chokhani wrote:
>On the issue of restart, that is misunderstanding on Paul's part.
There
>is no restart.

Ahem. I am reporting what the members of VPNC report to me. They are 
the vendors in the testing, not me. I have heard this from multiple 
vendors. If I was not clear that I was reporting what others said, I 
apologize.

>Generally, problem is fixed and you pick up that point.

Not to be too picky, but how can you say "generally" without seeing 
every test that was stopped? Maybe you have not had this problem, but 
others say they have.

>Subjective tests seems to be misunderstanding on Paul's part.  Having
>been in the Orange Book, CC and FIPS process, I as validator, tester,
>and certifier as well as vendor generally rue about rigidness of the
>standard and lack of subjective judgment on the part of the tester or
>lack of subjective latitude to vendors.

If you, as a tester, feel that there are no subjective parts of the 
test process, that's fine. Some/many people who are being tested 
disagree with you.

>FIPS 140 has specific guidelines on how to deal with minor incremental
>changes that helps reduce cost and calendar time.

Great! It does not seem to have gotten through to the vendors 
themselves as "inexpensive enough" or "fast enough". As a tester, you 
may have a different view.

>The standard is NOT a protocol standard.  It does verify the algorithm
>implementations and thus, FIPS validated algorithms can interoperate.

Quite true.

>In terms of low end devices, 20-30K for level 1 testing amortized over
>devices does not seem too onerous.

...to you. Others disagree, both on the financial cost, and 
particularly on the cost of elapsed time before customers can use the 
latest release from a vendor.

>I do not understand what Paul refers to as silly modes.  The module
>being FIPS validated must use FIPS validated or recognized algorithms
>for a given crypto service.  That seems like a good thing to me.

That is a good thing; it is also not what I was talking about. There 
is disagreement about what needs to be in a "FIPS mode", and whether 
the shipped product needs to allow "FIPS mode" to be enabled, and if 
so, how.

Again: I am reporting what I hear from many VPNC members over many 
years. You as a single vendor and/or tester might feel differently; 
your feeling does not invalidate the views of others.

--Paul Hoffman, Director
--VPN Consortium


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From: Randall Atkinson <rja@extremenetworks.com>
To: Peter Gutmann <pgut001@cs.auckland.ac.nz>
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Earlier, Peter Gutmann wrote:
% Politician's Fallacy again: Is FIPS 140 really the best way to spend your
% money?

If someone has a better proposal, I am very sure that there is a large
audience that would love to hear it. (More on this at bottom)

% If FIPS 140 is the answer now, why wasn't the Orange Book
% the answer then?

You are comparing apples to oranges above.

FIPS-140 is only about assurance for cryptographic modules.
Orange Book (TCSEC) was only about operating system security.

The two address different issues.

% What about giving the money to (picking a random name) Cigital and
% saying "make sure this code is OK"?

One needs a process that is as consistent and reproducible as practical
-- no human process could ever be 100% consistent and reprodcible --
otherwise implementers will legitimately complain about a non-level
playing field.  Or were you proposing to setup a monopoly ?

FIPS-140 has multiple certification labs in multiple countries evaluating
products -- to avoid creating a monopoly.  This HAS driven the evaluation
costs downwards over time, and it permits implementers the choice
to trade more money for less evaluation time.

I don't think anyone has claimed FIPS-140 is perfect.  The claims (not by
me so much as by other folks on the SAAG list) have been that (1) FIPS-140
 is better than other extant security evaluations and that (2) so far
no serious alternative proposal that looks reasonably better has appeared.

If you think that FIPS-140-* is a target-rich environment, then please
try to seriously propose something better.  I understand NIST and its
partners are looking to evolve into FIPS 140-3 from FIPS 140-2.

Have you sent them any concrete suggestions for improvement ?
I know the folks at NIST are happy to listen to any serious inputs
or proposals.

Cheers,

Ran



From SChokhani@cygnacom.com Wed Feb 20 10:33:12 2008
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Orange Book was not about OS security alone.

It was successfully applied to network components and DBMS systems also.

-----Original Message-----
From: saag-bounces@mit.edu [mailto:saag-bounces@mit.edu] On Behalf Of
Randall Atkinson
Sent: Wednesday, February 20, 2008 10:27 AM
To: Peter Gutmann
Cc: saag@mit.edu
Subject: Re: [saag] Algorithms/modes requested by users/customers

Earlier, Peter Gutmann wrote:
% Politician's Fallacy again: Is FIPS 140 really the best way to spend
your
% money?

If someone has a better proposal, I am very sure that there is a large
audience that would love to hear it. (More on this at bottom)

% If FIPS 140 is the answer now, why wasn't the Orange Book
% the answer then?

You are comparing apples to oranges above.

FIPS-140 is only about assurance for cryptographic modules.
Orange Book (TCSEC) was only about operating system security.

The two address different issues.

% What about giving the money to (picking a random name) Cigital and
% saying "make sure this code is OK"?

One needs a process that is as consistent and reproducible as practical
-- no human process could ever be 100% consistent and reprodcible --
otherwise implementers will legitimately complain about a non-level
playing field.  Or were you proposing to setup a monopoly ?

FIPS-140 has multiple certification labs in multiple countries
evaluating
products -- to avoid creating a monopoly.  This HAS driven the
evaluation
costs downwards over time, and it permits implementers the choice
to trade more money for less evaluation time.

I don't think anyone has claimed FIPS-140 is perfect.  The claims (not
by
me so much as by other folks on the SAAG list) have been that (1)
FIPS-140
 is better than other extant security evaluations and that (2) so far
no serious alternative proposal that looks reasonably better has
appeared.

If you think that FIPS-140-* is a target-rich environment, then please
try to seriously propose something better.  I understand NIST and its
partners are looking to evolve into FIPS 140-3 from FIPS 140-2.

Have you sent them any concrete suggestions for improvement ?
I know the folks at NIST are happy to listen to any serious inputs
or proposals.

Cheers,

Ran


_______________________________________________
saag mailing list
saag@mit.edu
http://mailman.mit.edu/mailman/listinfo/saag


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Earlier, Santosh Chokhani wrote:
% Orange Book was not about OS security alone.
%
% It was successfully applied to network components and DBMS systems also.

Santosh,

I was using terms precisely, not loosely.

The network evaluations were done against Red Book (TNI)
published as NCSC TG-005, and not against the Orange Book
proper.

DBMS evals were done against the Purple Book, published
as NCSC TG-021, and not against the Orange Book
proper.

(I have a full set of colouring books to hand from
a previous life.  :-)

Cheers,

Ran



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	<E1JRpLO-0006MQ-Lc@wintermute01.cs.auckland.ac.nz>
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The other books were no more than the interpretations so that we can
reuse the standard.

Except for TNI Part 2, the source document and requirement for rainbow
series is TCSEC.

-----Original Message-----
From: Randall Atkinson [mailto:rja@extremenetworks.com] 
Sent: Wednesday, February 20, 2008 10:40 AM
To: Santosh Chokhani
Cc: saag@mit.edu
Subject: RE: [saag] Algorithms/modes requested by users/customers

Earlier, Santosh Chokhani wrote:
% Orange Book was not about OS security alone.
%
% It was successfully applied to network components and DBMS systems
also.

Santosh,

I was using terms precisely, not loosely.

The network evaluations were done against Red Book (TNI)
published as NCSC TG-005, and not against the Orange Book
proper.

DBMS evals were done against the Purple Book, published
as NCSC TG-021, and not against the Orange Book
proper.

(I have a full set of colouring books to hand from
a previous life.  :-)

Cheers,

Ran



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Earlier Santosh wrote:
% The other books were no more than the interpretations so that we can
% reuse the standard.
%
% Except for TNI Part 2, the source document and requirement for rainbow
% series is TCSEC.

So then you do agree with me, Network evals and
DBMS evals used the other volumes that I cited,
because the Orange book didn't really cover either
networking or DBMS topics.

I was involved in formal evaluations for the US DoD,
while a DoD employee in a prior life, so I've got
specific first hand experience with this topic.

:-)

Cheers,

Ran



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Folks like me when we had issues, we focused on pragmatics and the TCSEC
and not the two interpretations you cite.

-----Original Message-----
From: Randall Atkinson [mailto:rja@extremenetworks.com] 
Sent: Wednesday, February 20, 2008 10:45 AM
To: Santosh Chokhani
Cc: saag@mit.edu
Subject: RE: [saag] Algorithms/modes requested by users/customers

Earlier Santosh wrote:
% The other books were no more than the interpretations so that we can
% reuse the standard.
%
% Except for TNI Part 2, the source document and requirement for rainbow
% series is TCSEC.

So then you do agree with me, Network evals and
DBMS evals used the other volumes that I cited,
because the Orange book didn't really cover either
networking or DBMS topics.

I was involved in formal evaluations for the US DoD,
while a DoD employee in a prior life, so I've got
specific first hand experience with this topic.

:-)

Cheers,

Ran



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Cc: saag@mit.edu, Randall Atkinson <rja@extremenetworks.com>
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-----BEGIN PGP SIGNED MESSAGE-----
Hash: SHA1

>
> I don't think anyone has claimed FIPS-140 is perfect.  The claims (not
> by
> me so much as by other folks on the SAAG list) have been that (1)
> FIPS-140
> is better than other extant security evaluations and that (2) so far
> no serious alternative proposal that looks reasonably better has
> appeared.

I agree that both of these are true, but these true statements are not  
inconsistent with the complaints.

A system can be the best available, as well as there being no "serious  
alternative" and still be inadequate.

I think this is the true problem.

I hope that we're not saying that FIPS 140 is the best of all possible  
systems.

	Jon

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From kent@bbn.com Wed Feb 20 17:52:14 2008
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At 12:36 AM +1300 2/21/08, Peter Gutmann wrote:
>mcgrew <mcgrew@cisco.com> writes:
>
>>Winston Churchill said that democracy is the worst form of government, except
>>for all of the others.  I think that the same is true for the FIPS-140
>>cryptomodule validation process ;-)
>
>I think it's more a case of the Politician's Fallacy:
>
>1. Something must be done.
>2. This is something.
>3. This must be done.
>
>It'd be interesting to see a study of the effectiveness in terms of finding
>security and interop problems of:

since I and others have pointed out several times that FIPS 140 eval 
has nothing to do with protocol interoperability, the reference to 
"interoo" above must be viewed purely within the context of crypto 
algorithms and modes thereof.

>
>A. A FIPS 140 eval.
>
>B. Running the code through Fortify/Coverity/whatever and completing a crypto
>    exchange with a peer (TLS, S/MIME, PGP, whatever the underlying crypto is
>    that's being used).
>
>in particular in terms of return for effort-involved.
>
>Peter.

FIPS 140 encompasses both hardware and software implementations of 
crypto modules. I see its greatest benefits in the context of the 
former. The process described above does not address hardware 
security module eval at all.

Steve

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Hi Peter,

On 2/20/08 3:36 AM, "Peter Gutmann" <pgut001@cs.auckland.ac.nz> wrote:

> mcgrew <mcgrew@cisco.com> writes:
> 
>> Winston Churchill said that democracy is the worst form of government, except
>> for all of the others.  I think that the same is true for the FIPS-140
>> cryptomodule validation process ;-)
> 
> I think it's more a case of the Politician's Fallacy:
> 
> 1. Something must be done.
> 2. This is something.
> 3. This must be done.
> 

I like that.

> It'd be interesting to see a study of the effectiveness in terms of finding
> security and interop problems of:
> 
> A. A FIPS 140 eval.
> 
> B. Running the code through Fortify/Coverity/whatever and completing a crypto
>    exchange with a peer (TLS, S/MIME, PGP, whatever the underlying crypto is
>    that's being used).
> 
> in particular in terms of return for effort-involved.
> 
> Peter.

I share you interest in the automation of validation testing; the more that
can be automated, the better.  It would be great to see more work in this
area. 

David


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Hi Jon,

>  When PGP first went through FIPS 140, we assigned a dedicated engineer
>  to the process. Shepherding software through FIPS 140 was so painful,
>  so mind-numbing, so annoying that he quit the company, quit
>  cryptography, and quit computer security altogether. He took a job
>  with a company that produced MP3 music software. That company was
>  bought out by Apple, and the software turned into what we now know as
>  iTunes. He is at Apple to this day as the lead of iTunes.
>
>  So the next time you listen to an iPod, think about FIPS 140, and
>  thank the horrible process.
Mind you, iTunes has its own DRM mechanism and that requires
cryptography. I have in the past worked on DTCP-IP which is now the
content protection mechanism in home devices (after DLNA adopted it)
used for content. It uses mechanisms similar to IKE (called AKE) and
DTCP (like IPsec).

So may be it is not as far away from cryptography as you might assume.

Thanks,
Vishwas

>         Jon
>
>
>  -----BEGIN PGP SIGNATURE-----
>  Version: PGP Universal 2.6.3
>  Charset: US-ASCII
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>  eRur6xWa+w6FdH022GobtDg=
>  =ZTOd
>  -----END PGP SIGNATURE-----
>
>
> _______________________________________________
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From: pgut001@cs.auckland.ac.nz (Peter Gutmann)
To: pgut001@cs.auckland.ac.nz, rja@extremenetworks.com
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Randall Atkinson <rja@extremenetworks.com> writes:
>Earlier, Peter Gutmann wrote:
>% If FIPS 140 is the answer now, why wasn't the Orange Book
>% the answer then?
>
>You are comparing apples to oranges above.
>
>FIPS-140 is only about assurance for cryptographic modules.
>Orange Book (TCSEC) was only about operating system security.
>
>The two address different issues.

They certainly seem to be addressing them in very similar ways.

>Or were you proposing to setup a monopoly ?

Ten years ago the rule-of-thumb estimate for a FIPS 140 level 1 eval was $100K
and 6-12 months no matter who you went to.  In 2006 (last time I checked) the
rule-of-thumb estimate for a FIPS 140 level 1 eval was $100K and 6-12 months
no matter who you went to.  So it looks like we already have a well-
established oligopoly with FIPS 140 evals, the only difference is the
nomenclature.

>One needs a process that is as consistent and reproducible as practical

Why?  This is the ISO 9000-for-software fallacy, reproducibility is great when
you're cranking out lightbulbs, but not much use for software, which isn't a
mass production process but instead is based on the cloning of the result of a
one-off development effort which is the product of the creativity, skill, and
co-operation of developers and users.  I can easily get 100% consistency in
reproducing an executable on a CDROM, but I don't think that's what's meant
here.

>If you think that FIPS-140-* is a target-rich environment, then please try to
>seriously propose something better.  I understand NIST and its partners are
>looking to evolve into FIPS 140-3 from FIPS 140-2.

It depends on what you want from FIPS 140 (and I'm talking specifically FIPS
140 for software modules here, which is the form that 99.9% of users encounter
it in ).  Some people have said you get "assurance", but the assurance you're
getting here is a high level of assurance that the vendors were desperate
enough for government sales that they shelled out a large amount of money in
order to get a ticket to ride the gravy train.

The problem is that like "religion" or "morals", "assurance" is a loaded term
and can be interpreted to mean almost anything.  Without some basic definition
of what's meant by "assurance", it's not really possible to reason about this.
So here's an attempt to nail it down: For me (and I would guess most end
users) assurance is being able to sleep at night knowing there's little chance
of anyone compromising my system ("things that should happen do happen, things
that shouldn't happen don't happen").

Let's see what FIPS 140 gives you to help you sleep at night.  It tests some
crypto mechanisms, but ignores others.  If you're buying an IPsec product it
doesn't test all the mechanisms needed for IPsec.  If you're buying a TLS
product it doesn't test the mechanisms needed for TLS.  If you're buying...
well, you get the idea.

Compare this to the example I gave earlier of performing a TLS exchange with
Amazon.  This performs an in-depth test of all the crypto algorithms
(corresponding to the FIPS algorithm tests, including ones that FIPS ignores),
and the crypto mechanisms (many/most of which FIPS again ignores).  In other
words simply by connecting to Amazon using TLS and ordering a "Scrubs" DVD for
$19.95 I'm getting more comprehensive algorithm testing than I can for a five-
figure sum with the FIPS algorithm tests.

So what else do you get?  You get a bit of a code review and some checking
that you don't do stupid things with keys.  Only some of the code is reviewed
(for example that trivial buffer overflow in the client handshake that allows
a remote attacker to do whatever they want with your server, including the
FIPS 140-evaluated portion, isn't checked because it's outside the scope of
what FIPS 140 is interested in), and (from having gone through several of
these) the review itself seems to be more coding style nitpicks than looking
for potential exploits, and in any case you can often document away any
problems without having to fix them.

So the assurance a FIPS 140 eval gets you is a tautological "the product
vendor was able to pass a FIPS 140 eval".  In terms of being able to
demonstrate this type of assurance, I agree completely with you that there is
no better mechanism for it than FIPS 140.

Admittedly there is some value to FIPS 140: You know that a subset of the
crypto used is OK, that the code doesn't do anything stupid with its keys
(unless the vendor has documented away the stupid things that do happen, e.g.
CryptoAPI's plaintext private-key export, you ask it "Give me the user's
private key in plaintext form" and it says "Sure, here you go"), and that it's
had a bit of a code check (and obviously if you're doing hardware crypto you
get a lot more value than this, but the discussion here is about software
modules).

What you don't get from FIPS 140 is the stuff that customers really care
about: Assurance that your IPsec product can actually do IPsec, that your TLS
product can do TLS, or that the product really is secure(-ish).  Excusing this
by saying that a FIPS 140 crypto product eval doesn't have to check half your
crypto so this isn't a problem is like saying that your TSA passenger-
screening process is OK even though it doesn't bother checking men with beards
or anyone under 5'6" tall.

If I'm going to spend $100K to feel safe then I can really think of better
ways than FIPS 140 (or CC, or ITSEC, or ...).  How about the following
comparison: You get to spend the cost of a FIPS 140 eval in one of two ways:

$100K: FIPS 140

-- or --

$20K: Fortify (or whatever) scan.
$20K: Cigital (or whatever) audit/analysis (these are just representative
      figures/estimates since there don't seem to be any fixed rates for this
      sort of thing).
$5K: Grant to French university to pen-test code "written at a German
     university".
$5K: Grant to British university to pen-test code "written at a French
     university".
$5K: Set up a fake banking site running the code and bring it to the attention
     of the Russian Business Network.
$free: Leak "security code for Windows 7" to Slashdot.
$free: Leak "security code for BluRay++" on warez boards.
$free: Leak "Diebold voting machine security code" to Cryptome.
$45K: 50" plasma TV, home theatre system, and beer to kill time while you
      wait for the results to come in (and to emphasise how much cheaper
      this is than FIPS 140 :-).

If your life depended on the security of the product that went through those
two processes, which one would you trust?  FIPS 140 is just not cost-effective
in providing assurance - it costs too much, it takes too long, and it doesn't
evaluate the stuff that real users care about having evaluated.

>The claims (not by me so much as by other folks on the SAAG list) have been
>that (1) FIPS-140 is better than other extant security evaluations

Thus showing that the politician's fallacy is alive and well :-).

There was a long and extremely interesting discussion on the (somewhat
misnamed) open-source list recently, thread topic "How can high assurance
FLOSS development be encouraged?".  The archives are at
http://lists.csl.sri.com/mailman/listinfo/open-source, but you have to sign up
to the list in order to access them.

Peter.

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Peter,

You are wrong about FIPS 140-1 costs being 100K for Level 1.  It is more
like 30K.

In terms of what FIPS buys is that you ensure that the algorithm is
implemented correctly, keys will be generated in accordance with FIPS
(meaning that the seed feeding the PRNG will have requisite entropy and
PRNG will be FIPS approved).

You also get the assurance that the keys are being managed properly in
the crypto module.

-----Original Message-----
From: saag-bounces@mit.edu [mailto:saag-bounces@mit.edu] On Behalf Of
Peter Gutmann
Sent: Monday, February 25, 2008 10:44 AM
To: pgut001@cs.auckland.ac.nz; rja@extremenetworks.com
Cc: saag@mit.edu
Subject: Re: [saag] Algorithms/modes requested by users/customers

Randall Atkinson <rja@extremenetworks.com> writes:
>Earlier, Peter Gutmann wrote:
>% If FIPS 140 is the answer now, why wasn't the Orange Book
>% the answer then?
>
>You are comparing apples to oranges above.
>
>FIPS-140 is only about assurance for cryptographic modules.
>Orange Book (TCSEC) was only about operating system security.
>
>The two address different issues.

They certainly seem to be addressing them in very similar ways.

>Or were you proposing to setup a monopoly ?

Ten years ago the rule-of-thumb estimate for a FIPS 140 level 1 eval was
$100K
and 6-12 months no matter who you went to.  In 2006 (last time I
checked) the
rule-of-thumb estimate for a FIPS 140 level 1 eval was $100K and 6-12
months
no matter who you went to.  So it looks like we already have a well-
established oligopoly with FIPS 140 evals, the only difference is the
nomenclature.

>One needs a process that is as consistent and reproducible as practical

Why?  This is the ISO 9000-for-software fallacy, reproducibility is
great when
you're cranking out lightbulbs, but not much use for software, which
isn't a
mass production process but instead is based on the cloning of the
result of a
one-off development effort which is the product of the creativity,
skill, and
co-operation of developers and users.  I can easily get 100% consistency
in
reproducing an executable on a CDROM, but I don't think that's what's
meant
here.

>If you think that FIPS-140-* is a target-rich environment, then please
try to
>seriously propose something better.  I understand NIST and its partners
are
>looking to evolve into FIPS 140-3 from FIPS 140-2.

It depends on what you want from FIPS 140 (and I'm talking specifically
FIPS
140 for software modules here, which is the form that 99.9% of users
encounter
it in ).  Some people have said you get "assurance", but the assurance
you're
getting here is a high level of assurance that the vendors were
desperate
enough for government sales that they shelled out a large amount of
money in
order to get a ticket to ride the gravy train.

The problem is that like "religion" or "morals", "assurance" is a loaded
term
and can be interpreted to mean almost anything.  Without some basic
definition
of what's meant by "assurance", it's not really possible to reason about
this.
So here's an attempt to nail it down: For me (and I would guess most end
users) assurance is being able to sleep at night knowing there's little
chance
of anyone compromising my system ("things that should happen do happen,
things
that shouldn't happen don't happen").

Let's see what FIPS 140 gives you to help you sleep at night.  It tests
some
crypto mechanisms, but ignores others.  If you're buying an IPsec
product it
doesn't test all the mechanisms needed for IPsec.  If you're buying a
TLS
product it doesn't test the mechanisms needed for TLS.  If you're
buying...
well, you get the idea.

Compare this to the example I gave earlier of performing a TLS exchange
with
Amazon.  This performs an in-depth test of all the crypto algorithms
(corresponding to the FIPS algorithm tests, including ones that FIPS
ignores),
and the crypto mechanisms (many/most of which FIPS again ignores).  In
other
words simply by connecting to Amazon using TLS and ordering a "Scrubs"
DVD for
$19.95 I'm getting more comprehensive algorithm testing than I can for a
five-
figure sum with the FIPS algorithm tests.

So what else do you get?  You get a bit of a code review and some
checking
that you don't do stupid things with keys.  Only some of the code is
reviewed
(for example that trivial buffer overflow in the client handshake that
allows
a remote attacker to do whatever they want with your server, including
the
FIPS 140-evaluated portion, isn't checked because it's outside the scope
of
what FIPS 140 is interested in), and (from having gone through several
of
these) the review itself seems to be more coding style nitpicks than
looking
for potential exploits, and in any case you can often document away any
problems without having to fix them.

So the assurance a FIPS 140 eval gets you is a tautological "the product
vendor was able to pass a FIPS 140 eval".  In terms of being able to
demonstrate this type of assurance, I agree completely with you that
there is
no better mechanism for it than FIPS 140.

Admittedly there is some value to FIPS 140: You know that a subset of
the
crypto used is OK, that the code doesn't do anything stupid with its
keys
(unless the vendor has documented away the stupid things that do happen,
e.g.
CryptoAPI's plaintext private-key export, you ask it "Give me the user's
private key in plaintext form" and it says "Sure, here you go"), and
that it's
had a bit of a code check (and obviously if you're doing hardware crypto
you
get a lot more value than this, but the discussion here is about
software
modules).

What you don't get from FIPS 140 is the stuff that customers really care
about: Assurance that your IPsec product can actually do IPsec, that
your TLS
product can do TLS, or that the product really is secure(-ish).
Excusing this
by saying that a FIPS 140 crypto product eval doesn't have to check half
your
crypto so this isn't a problem is like saying that your TSA passenger-
screening process is OK even though it doesn't bother checking men with
beards
or anyone under 5'6" tall.

If I'm going to spend $100K to feel safe then I can really think of
better
ways than FIPS 140 (or CC, or ITSEC, or ...).  How about the following
comparison: You get to spend the cost of a FIPS 140 eval in one of two
ways:

$100K: FIPS 140

-- or --

$20K: Fortify (or whatever) scan.
$20K: Cigital (or whatever) audit/analysis (these are just
representative
      figures/estimates since there don't seem to be any fixed rates for
this
      sort of thing).
$5K: Grant to French university to pen-test code "written at a German
     university".
$5K: Grant to British university to pen-test code "written at a French
     university".
$5K: Set up a fake banking site running the code and bring it to the
attention
     of the Russian Business Network.
$free: Leak "security code for Windows 7" to Slashdot.
$free: Leak "security code for BluRay++" on warez boards.
$free: Leak "Diebold voting machine security code" to Cryptome.
$45K: 50" plasma TV, home theatre system, and beer to kill time while
you
      wait for the results to come in (and to emphasise how much cheaper
      this is than FIPS 140 :-).

If your life depended on the security of the product that went through
those
two processes, which one would you trust?  FIPS 140 is just not
cost-effective
in providing assurance - it costs too much, it takes too long, and it
doesn't
evaluate the stuff that real users care about having evaluated.

>The claims (not by me so much as by other folks on the SAAG list) have
been
>that (1) FIPS-140 is better than other extant security evaluations

Thus showing that the politician's fallacy is alive and well :-).

There was a long and extremely interesting discussion on the (somewhat
misnamed) open-source list recently, thread topic "How can high
assurance
FLOSS development be encouraged?".  The archives are at
http://lists.csl.sri.com/mailman/listinfo/open-source, but you have to
sign up
to the list in order to access them.

Peter.
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From: pgut001@cs.auckland.ac.nz (Peter Gutmann)
To: pgut001@cs.auckland.ac.nz, rja@extremenetworks.com, SChokhani@cygnacom.com
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"Santosh Chokhani" <SChokhani@cygnacom.com> writes:

>You are wrong about FIPS 140-1 costs being 100K for Level 1.  It is more like
>30K.

The figures I've been given, from numerous vendors going through numerous labs
over a number of years, is that their all-up cost for a level 1 software eval
was around $100K (give or take a few tens of $K).  This isn't just the final
cheque they cut to get the coloured piece of paper, this is the all-up cost of
getting their product through a FIPS 140 eval.

I realise the following may be a bit unfair since you weren't intending to
provide a price quote :-), but I'm willing to put my money where my mouth is:
If Cygnacom can get me a FIPS 140 level 1 on my code for an all-up cost of
$30K I'll send you a cheque and CDROM of the source within 24 hours (I need to
get mgt.approval first).  Just let me know where to send it and who to make
the payment out to.

>In terms of what FIPS buys is that you ensure that the algorithm is
>implemented correctly,

That a *subset* of the algorithms used are impemented correctly, in other
words a subset of what you can get for $19.95 via a TLS connect to Amazon.
And the actual crypto mechanisms don't get tested at all.

>keys will be generated in accordance with FIPS (meaning that the seed feeding
>the PRNG will have requisite entropy and PRNG will be FIPS approved).

A nice circular definition: "A FIPS evaluation guarantees that keys will be
generated as required in order to pass a FIPS evaluation".

>You also get the assurance that the keys are being managed properly in the
>crypto module.

... unless the vendor has documented away the mismanagement, e.g. CryptoAPIs
plaintext private key export.

You're not making a very convincing argument here :-).

Peter.

From SChokhani@cygnacom.com Tue Feb 26 07:40:12 2008
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Peter,

I do not think this is a forum for negotiations.  But, we will be happy
to do FIPS testing for your product for Level 1 for quoted price.

As to algorithms, all FIPS approved algorithms need to be tested.

As to key generation there are standards that come out of NIST and ANSI
X9 that IETF also takes its cue from, and FIPS process ensures that the
keys are generated in accordance with those standards.

Have you yourself participated in a FIPS evaluation or have you looked
at the NIST FIPS 140-2 DTR and FIPS 140-2 IG (i.e. Implementation
Guidance) available on the Web?

-----Original Message-----
From: pgut001 [mailto:pgut001@cs.auckland.ac.nz] 
Sent: Tuesday, February 26, 2008 1:34 AM
To: pgut001@cs.auckland.ac.nz; rja@extremenetworks.com; Santosh Chokhani
Cc: saag@mit.edu
Subject: RE: [saag] Algorithms/modes requested by users/customers

"Santosh Chokhani" <SChokhani@cygnacom.com> writes:

>You are wrong about FIPS 140-1 costs being 100K for Level 1.  It is
more like
>30K.

The figures I've been given, from numerous vendors going through
numerous labs
over a number of years, is that their all-up cost for a level 1 software
eval
was around $100K (give or take a few tens of $K).  This isn't just the
final
cheque they cut to get the coloured piece of paper, this is the all-up
cost of
getting their product through a FIPS 140 eval.

I realise the following may be a bit unfair since you weren't intending
to
provide a price quote :-), but I'm willing to put my money where my
mouth is:
If Cygnacom can get me a FIPS 140 level 1 on my code for an all-up cost
of
$30K I'll send you a cheque and CDROM of the source within 24 hours (I
need to
get mgt.approval first).  Just let me know where to send it and who to
make
the payment out to.

>In terms of what FIPS buys is that you ensure that the algorithm is
>implemented correctly,

That a *subset* of the algorithms used are impemented correctly, in
other
words a subset of what you can get for $19.95 via a TLS connect to
Amazon.
And the actual crypto mechanisms don't get tested at all.

>keys will be generated in accordance with FIPS (meaning that the seed
feeding
>the PRNG will have requisite entropy and PRNG will be FIPS approved).

A nice circular definition: "A FIPS evaluation guarantees that keys will
be
generated as required in order to pass a FIPS evaluation".

>You also get the assurance that the keys are being managed properly in
the
>crypto module.

... unless the vendor has documented away the mismanagement, e.g.
CryptoAPIs
plaintext private key export.

You're not making a very convincing argument here :-).

Peter.


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Content-Type: text/plain; charset="iso-8859-1"
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Daer sir,
=20
Why i can't find any group for manet security. if there please iform me how=
 to access it.
=20
best regards,
=20
Ahmed M. Abdullah
=20
_________________________________________________________________
Climb to the top of the charts!=A0Play the word scramble challenge with sta=
r power.
http://club.live.com/star_shuffle.aspx?icid=3Dstarshuffle_wlmailtextlink_ja=
n=

--_3fb6503a-cb93-4732-b6ee-22ccfd01385c_
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<html>
<head>
<style>
.hmmessage P
{
margin:0px;
padding:0px
}
body.hmmessage
{
FONT-SIZE: 10pt;
FONT-FAMILY:Tahoma
}
</style>
</head>
<body class=3D'hmmessage'>
Daer sir,<BR>
&nbsp;<BR>
Why i can't find any group for manet security. if there please iform me how=
 to access it.<BR>
&nbsp;<BR>
best regards,<BR>
&nbsp;<BR>
Ahmed M. Abdullah<BR>
&nbsp;<BR><br /><hr />Climb to the top of the charts!=A0Play the word scram=
ble challenge with star power. <a href=3D'http://club.live.com/star_shuffle=
.aspx?icid=3Dstarshuffle_wlmailtextlink_jan' target=3D'_new'>Play now!</a><=
/body>
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--_3fb6503a-cb93-4732-b6ee-22ccfd01385c_--

From tim.polk@nist.gov Tue Feb 26 10:01:49 2008
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Folks,

Sam, Pasi, and I are putting together the SAAG agenda for Philadelphia.

The agenda traditionally includes one or two invited presentations  
after the
working group reports.  We would appreciate submission of  
presentation topics
that you believe would be of interest to the community.

If you can identify an appropriate presenter (not necessarily  
yourself) that would
be helpful.

Note:  If you previously submitted a topic or presentation request, I  
missed it or it
got filtered accidentally.  Please resubmit!

Thanks,

Tim Polk

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One final note - please direct your presentation topics to Pasi, Sam,  
and I.

Unfortunately, I forgot to CC them on the last message, so a reply  
would only go to me...

On Feb 26, 2008, at 10:01 AM, Tim Polk wrote:

> Folks,
>
> Sam, Pasi, and I are putting together the SAAG agenda for  
> Philadelphia.
>
> The agenda traditionally includes one or two invited presentations  
> after the
> working group reports.  We would appreciate submission of  
> presentation topics
> that you believe would be of interest to the community.
>
> If you can identify an appropriate presenter (not necessarily  
> yourself) that would
> be helpful.
>
> Note:  If you previously submitted a topic or presentation request,  
> I missed it or it
> got filtered accidentally.  Please resubmit!
>
> Thanks,
>
> Tim Polk


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At 4:44 AM +1300 2/26/08, Peter Gutmann wrote:
>...
>
>Ten years ago the rule-of-thumb estimate for a FIPS 140 level 1 eval was $100K
>and 6-12 months no matter who you went to.  In 2006 (last time I checked) the
>rule-of-thumb estimate for a FIPS 140 level 1 eval was $100K and 6-12 months
>no matter who you went to.  So it looks like we already have a well-
>established oligopoly with FIPS 140 evals, the only difference is the
>nomenclature.

BBN developed the first crypto module evaluated at level 3 under FIPS 
140-1. The fee we paid to the eval lab was about $40K, and the 
elapsed time was about 6 months.  That was more than  ten years ago, 
but we're also talking about a much more thorough eval. The cost to a 
developer is, of course, higher, when you add in the time required to 
prepare the necessary documentation. Also, if the developer is not 
experienced in secure development practices, the likelihood increases 
that the eval will not go smoothly, and thus the costs will be 
higher.  Maybe what you're reporting is the result of more 
developers, with less experience  secure crypto module development 
experience submitting products that are "not quite ready."

...

>  >If you think that FIPS-140-* is a target-rich environment, then 
>please try to
>>seriously propose something better.  I understand NIST and its partners are
>>looking to evolve into FIPS 140-3 from FIPS 140-2.
>
>It depends on what you want from FIPS 140 (and I'm talking specifically FIPS
>140 for software modules here, which is the form that 99.9% of users encounter
>it in ).  Some people have said you get "assurance", but the assurance you're
>getting here is a high level of assurance that the vendors were desperate
>enough for government sales that they shelled out a large amount of money in
>order to get a ticket to ride the gravy train.

Sotware modules are easier for a developer to create and submit, and 
this too may cause more submissions that are less well thought out. 
If you're building hardware there may be more of an effort to "get it 
right" in the planning stages, because the costs of redesign are 
potentially higher.

>The problem is that like "religion" or "morals", "assurance" is a loaded term
>and can be interpreted to mean almost anything.  Without some basic definition
>of what's meant by "assurance", it's not really possible to reason about this.
>So here's an attempt to nail it down: For me (and I would guess most end
>users) assurance is being able to sleep at night knowing there's little chance
>of anyone compromising my system ("things that should happen do happen, things
>that shouldn't happen don't happen").

Assurance (in the security context) is not as squishy a term as your 
suggest. Security assurance is generally characterized as confidence 
that an implementation meet certain objective security-relevant 
criteria. These are not interoperability criteria. It is 
distinguished from security functionality, which refers to the set of 
functions (features) ascribed to a product (without confidence that 
these features operate as promised).


>Let's see what FIPS 140 gives you to help you sleep at night.  It tests some
>crypto mechanisms, but ignores others.  If you're buying an IPsec product it
>doesn't test all the mechanisms needed for IPsec.  If you're buying a TLS
>product it doesn't test the mechanisms needed for TLS.  If you're buying...
>well, you get the idea.

For a protocol such as TLS or IPsec,  crypto module security 
assurance does not encompass most aspects of what a users sees as 
"correct" operation. It makes sense to look for both functionality 
testing and security assurance evaluation, if you care about both 
functionality and security.

>Compare this to the example I gave earlier of performing a TLS exchange with
>Amazon.  This performs an in-depth test of all the crypto algorithms
>(corresponding to the FIPS algorithm tests, including ones that FIPS ignores),
>and the crypto mechanisms (many/most of which FIPS again ignores).  In other
>words simply by connecting to Amazon using TLS and ordering a "Scrubs" DVD for
>$19.95 I'm getting more comprehensive algorithm testing than I can for a five-
>figure sum with the FIPS algorithm tests.

nonsense! what you get is confidence that the SSL/TLS implementation 
at Amazon and in your browser work compatibly, even if both happen to 
be "wrong."  In fact, the test you propose checks only a small subset 
of the SSL/TLS spec, as it verifies only that the RSA key transport 
method of key management works, none of the other key management 
methods defined by the RFCs. So, maybe what you meant to say was that 
the proposed test regimen verifies that a protocol and associated 
crypto work compatibility with an implementation of the most common 
subset of the crypto modes and protocol features deployed.  That's a 
useful finding, but let's not confuse it with protocol standard 
conformance or security assurance.

I won't bother to respond to the rest of your observations, since 
they repeat many of the themes I touched upon above.

It is silly to ask FIPS 140 to address protocol interop issues; that 
is simply not in scope for a generic crypto security eval criteria. 
So let's forgo all the arguments along those lines.

Vendor claims about security sometimes (often?) prove to be wrong. 
Thus is makes sense to seek external, independent assurances about 
security, if you care. The fact that FIPS 140 addresses only a subset 
of those claims is also not a basis for criticizing a generic crypto 
module evaluation criteria like FIPS 140. Common Criteria eval of 
products is more encompassing, but also MUCH more expensive.

So, IF one cares about crypto security, THEN FIPS 140 eval is the 
best option for now. That does not make it ideal, but it also does 
not make it as bad as some comments have suggested, and it is unfair 
to criticize it for not doing something that it has never promised to 
do.


Steve

