This is potentially a question with openssl-dev/openssl-users crossover.

In the FIPS Security Policy there are listed two functions for generating RSA keys:
FIPS_rsa_generate_key_ex()      (renamed from RSA_generate_key_ex())
and
FIPS_rsa_x931_generate_key_ex() (renamed from RSA_X931_generate_key_ex())

The later is a complete implementation, according to X9.31, and an approved method in FIPS 186-2.

The former is a wrapper function for either a "custom" keygen contained in the RSA struct, or the static "rsa_builtin_keygen". This builtin function does not conform to X9.31 (and therefor is not acceptable under 186-2).

In testing, it appears when running in FIPS mode and calling the wrapper function, the non-approved builtin function is the one that is called. The default RSA struct creation function, defined in "fips/fips_rsa_lib.c:FIPS_rsa_new()" sets a mechanism parameter ("RSA_PKCS1_SSLeay()") that doesn't specify any key construction method (see cryupto/rsa/rsa_eay.c). Without this specified in the struct, the default (builtin; non-approved) method is used.

Thus, it appears that there is a function in the FIPS API that allows for the creation of RSA keys in a non-approved manner.

Am I missing something?

Assuming I was to remediate this for one of my clients, the wrapper function within the canister should replace the call to the builtin function with a call to the RSA_X931_generate_key_ex() function, and/or the struct creation function should explicitly set the rsa_keygen method. Correct?

Thanks,
Randy
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