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List:       openssl-users
Subject:    Re: [openssl-users] FIPS 140-2 certification
From:       Michael Wojcik <Michael.Wojcik () microfocus ! com>
Date:       2018-06-20 16:15:10
Message-ID: SN1PR18MB2112C1728C6E2E75027CB0FAF9770 () SN1PR18MB2112 ! namprd18 ! prod ! outlook ! com
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> From: openssl-users [mailto:openssl-users-bounces@openssl.org] On Behalf Of Oleg \
>                 Paikin
> Sent: Wednesday, June 20, 2018 01:01

> We would like to add to our product OpenSSL with FIPS 140-2 module. The problem is \
> that our OS and CPUs are not FIPS certified. We use vxWorks 5.5.1 with 3 types of \
> CPUs in different products.

Disclaimer: I've never had to shepherd anything through the FIPS validation process. \
The following is just my understanding from reading about it.


Nothing is "FIPS certified". FIPS 140-2 does not define a "certification". There is \
FIPS validation, which if successful results in a "validation certificate". There's \
also FIPS 140 "user affirmation", which basically involves you saying "hey, any \
crypto we have is FIPS 140-2 validated in some other context, just not here, cross \
our hearts". Some customers may accept that, and others may not.

There's also a "FIPS Inside" claim, where you say that even if the entire system is \
not FIPS-validated, all the actual crypto is. (I'm actually not sure that's \
officially endorsed by the NIST procurement procedures doc; I've heard people who \
should know claim that it is, but I haven't looked for chapter & verse myself.)

Also, note that what's validated is a combination of the cryptographic implementation \
itself; cryptographic things that are done (e.g. the self-tests) and not done (e.g. \
no forbidden algorithms are used); and the runtime platform (the "Operational \
Environment"). So what you'd be getting validated is not the OS and CPUs themselves, \
but the combination of OpenSSL (and any other crypto software or hardware you might \
have), OS, and CPU. From your description, it sounds like you need four validations, \
unless your customers will accept user affirmation.

That's assuming your customers aren't also requesting FIPS 140-2 hardware \
tamper-resistance or some other additional assurance.

> How can we get certification for these environments? OSF answered that they do not \
> do FIPS consulting work anymore. Can somebody explain what is the process and cost \
> to get such certification?

The process is you find a lab that will do FIPS 104-2 validation, pay them a lot of \
money, and wait a long time (months) while they do the testing and go back and forth \
with the CMVP. History shows that the CMVP can be rather arbitrary. The cost is \
generally considerable - I think tens of thousands of dollars is typical.

Now, all that said, you can use OpenSSL with the FIPS container and enable FIPS mode \
without claiming you're FIPS-validated. That doesn't fulfill NIST procurement rules, \
but you may have a customer who isn't subject to those rules but wants to tick some \
"FIPS" checkbox anyway. (There's no technical advantage to doing so, but cryptography \
is an esoteric subject and sometimes people come up with pointless requirements.) \
I've known people who don't need FIPS validation to ask for some FIPS claim anyway, \
even when that claim is essentially meaningless. If that's the case, just make it \
possible for the customer to enable FIPS mode and let them go their merry way.

--
Michael Wojcik
Distinguished Engineer, Micro Focus
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