> You're probably referring to the critique that Tim Hudson of RSA SI has
> been circulating.

No, I didn't know Tim has been circulating a critique.

> As for ?breaks in security?, for level 1 validations the CMVP recognizes
> that there is no effective defense against malicious subversion of
> software.  An attacker with write access to a validated module can 
disable
> the integrity checks, corrupt keys, modify algorithms, etc.  FIPS 140-2
> level 1 does not require defenses against malicious attack, other than 
the
> initial integrity test and configuration of the host operating system in
> ?single user mode?.

But providing an alternative implementation of a routine outside of the 
security boundary a priori cannot be malicious, and therefore this 
"attack" is entirely legitimate.  Further, it needn't be the application 
itself that provide an alternate implementation, but rather a separate 
library that the application uses.  If an application developer needs to 
ensure that every non-system library doesn't provide alternate 
implementations of certain functions, then the security policy needs to 
say that.
 
> Initially our guidance was that the BN library, which was not contained 
in
> the crypt module boundary, was an acceptable ?non cryptographic?
> reference.

Who gave that guidance, and to whom?  I'd like to hear the rationale.  The 
RSA key operations are implemented via BN calls!

As for the DES self-test, it tested API's which aren't used by the rest of 
the module, right?

> Well, you're waxing poetic here and I think you're being a little harsh.

Only a little? :)
 
> The CMVP is doing the right thing

Here we agree.

> BTW the correct term is ?validation?, not ?certification?.

Yeah, I keep forgetting that.  And I've been involved with FIPS and Common 
Criteria for many years.


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