Rob Schramm wrote:
>So.. even though the protected key starts with the Crypto Express, it
>wouldn't pass an audit for protection of card data?

>I had thought that the key never appears in the clear at any time with
>protected key.  Seems like as long as it never is in the clear that it
>would pass muster.  Even with the more esoteric attacks.. if all they get
>is the encrypted key... what does it buy them?  Or am I missing something
>obvious?

Somebody is, but it isn't you. Remember that auditors typically aren't 
technicians. And their model is PCs. So they get told, "Stuff gotta be done in 
an HSM to be considered secure". That's the beginning and the end of the 
conversation. Protected Mode isn't entirely in an HSM (which is what the CEX 
is), so they don't buy it.

Part of their job is not to believe the grizzled veteran who says "This stuff 
IS secure". Part of their job might should be-but isn't-to prove that he's 
wrong. But instead, it's just "Nope, doesn't fit the rule, can't do it".

Disclaimer: Not all QSAs are this simplistic. But that's the case that causes 
the most problems.

...phsiii

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