Adam Grossman wrote:
hello,

from my understanding, the US government can not buy a FIPS 140-2
compliant product after 2010.  But my employer spoke to someone who said
they can still purchase a FIPS 140-2 validated product as long as they
are "transitionally" compliant by only using cryptographic algorithms
that have sufficient strength and follow the guidlines in:
http://csrc.nist.gov/publications/drafts/800-131/draft-800-131_transition-paper.pdf

- SHA-1 will not be approved for digital signature generation but will
be approved for other uses including digital signature verification,
HMACs, KDFs, RNGs, and the approved integrity technique specified in
Section 4.6.1 of FIPS 140-2;

Since the FIPS module digest is generated with SHA1, i do not know if
this will automatically make this issue dead in the water.

Has anyone heard of this or dealt with this, or has made OpenSSL FIPS
compliant for post-2010 (with the understanding it has not been
validated for compliance).

if this has been discussed already, i apologize.  i could not find
anything on this issue, just on whether or not there will be a FIPS
140-3 validation in the future for OpenSSL.

thank you very much,
-=- adam grossman


First of all, FIPS 140-3 and SP 800-131 are different things. Both are also currently still in draft form, meaning they are not yet official policy. A finalized SP 800-131 will be out well before FIPS 140-3 is finalized and takes effect.

Since SP 800-131 is still in draft form, and also since I hear there has been more than a little industry pushback, one has to speculate what's ultimately going to happen. I'll give you my speculation and it's worth what you paid for it: SP 800-131 will tighten the rules for new validations (post 2010) but the CMVP is unlikely to revoke all existing prior validations (think of the disruption that would cause!), so currently validated products will still be available for procurement and use for some time after 2010.

Note that SP 800-131 will mean that the current OpenSSL FIPS Object Module v1.2 will no longer be suitable as the basis for "private label" validations (a common industry practice). In addition, the new OpenSSL 1.0.x baseline is incompatible with the v1.2 validated module. For both reasons those vendors who have been leveraging the v1.2 module in their products will need a new game plan in the absence of a new SP 800-131 compatible open source based validation. As with the earlier validations such a new validation will need sponsorship to defray the substantial costs (that's a hint, folks). We're ready and eager to take that on but do not have the financial resources. It's already mid April so we're also rapidly running out of time to have a validation completed before 2011.

-Steve M.

--
Steve Marquess
Open Source Software institute
marqu...@oss-institute.org

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