Dear Ray,

On 2013-10-11, at 19:38 , Ray Dillinger <> wrote:
> This is despite meeting (for some inscrutable definition of "meeting")
> FIPS 140-2 Level 2 and Common Criteria standards.  These standards
> require steps that were clearly not done here.  Yet, validation
> certificates were issued.
This is a misunderstanding of the CC certification and FIPS validation 
the certificates were issued *under the condition* that the software/system 
built on it uses/implements the RNG tests mandated. The software didn't, 
invalidating the results of the certifications.

At best the mandatory guidance is there because it was too difficult to prove 
that the smart card meets the criteria without it (typical example in the OS 
world: the administrator is assumed to be trusted, the typical example in smart 
card hardware: do the RNG tests!).
At worst the mandatory guidance is there because without it, the smart card 
would not have met the criteria (i.e. without following the guidance there is a 
This is an example of the latter case. Most likely the software also hasn't 
implement the other requirements, leaving it somewhat to very vulnerable to the 
standard smart card attack such as side channel analysis and perturbation.

If the total (the smart card + software) would have been CC certified, this 
would have been checked as part of the composite certification.

(I've been in the smart card CC world for more than a decade. This kind of 
misunderstanding/misapplication is rare for the financial world thanks to 
EMVco, i.e. the credit card companies. It is also rare for European government 
organisations, as they know to contact the Dutch/French/German/UK agencies 
involved in these things. European ePassports for example are generally 
certified for the whole thing and a mistake in those of this order would be ... 
surprising and cause for some intense discussion in the smart card 
certification community. Newer parties into the smart card world tend to have 
to relearn the lessons again and again it seems.)

With kind regards,
Wouter Slegers
The cryptography mailing list

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