Subject: Re: certification for pki

From: [email-masked]
Date: Wed, 21 Jun 2000 11:47:39 -0400

It is not a choice of CC vs. FIPS.  The FIPS 140-1 testing pertains narrowly to
crypto modules.  The CC evaluation/"torture" process is about the
system/components for certificate issuance and management meeting its security
specification (security target and claimed PP(s)).  A crypto module is just an
embedded "engine" in the larger vehicle.   To continue with the automotive
metaphor, it is not a choice between auto emission testing vs. crash testing vs.
fuel economy vs. performance testing, etc.  All of these tests may be required
for the consumer to understand and compare what they are buying.  It may be
"torture" for the manufacturer, but when the market (or laws, regulations, etc.)
demand it, manufacturers do it.
-GH

[email-masked] on 06/21/2000 11:11:43 PM

Please respond to [email-masked]

To:   [email-masked]
cc:    (bcc: Gene Hilborn/DEF/CSC)
Subject:  Re: certification for pki

[email-masked] writes:

>One internationally recognized avenue is an evaluation under the Common
>Criteria/ISO 15408.  Such an evaluation up to EAL4 is automatically recognized
>by the (currently) nine mutual recognition arrangement countries.  Two current
>problems are (1) that the CC itself does not contain a crypto module
>evaluation standard such as FIPS 140-1/2, and (2) there is not yet a consensus
>and evaluated Protection Profile for PKI components.   Some product vendors
>have undertanen evaluations without PPs.  FIPS 140-1 is officially US/Canada,
>but also widely recognized.

A third problem with the CC, for those who haven't experienced it before, is
that it acts as a form of torture for companies to determine how badly they
need government (or whatever) contracts - the more pain you can stand, the
better you've demonstrated that you need the contract.  I'm not just saying
this for $generic_CC_bashing, from talking to people who have gone through it
it really sounds like an incredibly unpleasant experience (when I used the term
"torture" to describe it above this doesn't originate with me but with the
people I talked to).  In terms of achieving more or less the same effect (the
certification that is, not the torture :-) it looks like FIPS 140 is the easier
path, and it does constitute a de facto PP which the CC doesn't have yet.  I'd
go with FIPS 140.

Peter.

---

From: Mack Hicks <[email-masked]>
Date: Wed, 21 Jun 2000 09:31:04 -0700

GH,

As a "consumer", a banking business, of these products and services -- and as one
who is also deploying into the marketplace, I do demand some testing and review. I
also ask how much all this security is costing, and what risks are being minimized
or eliminated.

What I do NOT demand is the use of a "military threat" model in a commercial
context. I define "military threat" as "a fault in security could ultimately lead to
nuclear war - so no faults are allowed".  What I mean is that most of the
evaluations and criteria I have seen, like the AICPA draft and the ANSI X9.79 draft,
are regarding risks as if they cannot be commercially controlled.  To this end, Bank
of America has voted "NO" on the first round of balloting for ANSI X9.79, and I
encourage all other ANSI members to do the same.

I mention this in the context of the mailing list discussion on private key cloning
for commercial servers. Given budget constraints and the cost of the cryptographic
hardware - not to mention the operational costs and customer (client) impact - there
is no choice but to have some cloning and/or key backup of server signing keys.
These keys are just too important to business flow to leave to a single location or
piece of hardware.

Admittedly, when one is acting in a position of trust for other organizations, care
must be exercised - but it must be compatible and commensurate with the risk
involved - not just to the risk to the keys but much more importantly - to the
on-going operation of our customer's business.

Further, when key management hardware is deployed to commercial servers that are not
under bank security guidelines (like we do with credit card merchants today), there
is an even greater need for resilience and key backup. The cost of hardware
replication or the cost of business interruption (for rekeying and certification) is
too high for the associated risk and perceived security benefit.

[email-masked] wrote:

> ... It may be

-------------------------------------------------
Mack Hicks, SVP     [email-masked]
Bank of America  +1-415-436-5809