OMB: FIPS matters

Agencies have not been requiring vendors to meet mandatory FIPS cryptography standard

FIPS publication 140-2

Software buyers typically take vendors at their word when the vendors assert that their antivirus software or other security application is effective. But the Office of Management and Budget wants federal agencies to demand more than a smile and a handshake from antivirus companies.

Through a recently announced enterprise software license deal for McAfee antivirus products and in a forthcoming memo to chief information officers, OMB and the General Services Administration will enforce a federal requirement pertaining to any software that contains a cryptographic module. Agencies can buy only those cryptographic products that the National Institute of Standards and Technology has validated.

NIST, relying on 13 independent third-party labs, certifies cryptographic modules that meet requirements in 11 categories outlined in Federal Information Processing Standard 140-2. Vendors can get their security products certified at least one of four different levels of assurance.

“We individually validate each cryptographic algorithm that is recognized by FIPS or special publications,” said Ray Snouffer, NIST’s manager of security testing and metrics group. “When one of the modules says they are using the Advanced Encryption Standard or RSA encryption, the federal government can be assured that is happening.”

FIPS certification is not a new mandate. Since 1994, NIST has required agencies to buy products that meet FIPS 140 standards when they have a need for cryptographic software. The FIPS 140-2 requirement became a sticking point when GSA and OMB began negotiating a governmentwide license deal for antivirus software under GSA’s SmartBuy program.

The lead agencies for the SmartBuy program realized that none of the antivirus software vendors incorporated a FIPS 140-2 validated encryption module in their software, said a government official, who requested anonymity because of the procurement sensitivity of the topic.

“If an agency bought antivirus software before December 2006, it was not FIPS 140-2 validated,” said the official, who added that “agencies failed to understand the requirements or did not put enough pressure on vendors to develop software with validated modules.”

The discovery of unqualified vendors led OMB and GSA to delay the SmartBuy deal for more than a year. It also provided OMB the impetus to draft a memo reminding agencies about the FIPS 140-2 requirement.

OMB is reviewing comments it received on the draft memo from CIOs and other federal officials. One federal official said the memo’s release has been delayed while officials decide whether it should also address cryptographic requirements for classified information. The FIPS 140-2 standard applies only to sensitive-but-unclassified information.

“We have been working to make it easier for agencies to purchase products that are FIPS 140-2 compliant,” an OMB spokeswoman said. “For governmentwide deals, it is especially important that certain basic criteria are met — including a requirement that all law and policy directives are considered and adhered to through the procurement process.”

When agencies use software that has been validated as FIPS 140-2 compliant, they are assured that the software does what the vendor claims it will do, said Tom Anderson, chief of the technologies and capabilities division at the Defense Department’s CIO’s office. “If you are not using it, you are assuming more risk.”

Glenn Schlarman, a former OMB official who is familiar with an early version of the memo, said it would not set new policy but instead would be more like a program manual describing all existing federal cryptographic requirements. The memo would require agencies to document their use of approved cryptographic modules through the annual certification and accreditation process. That process includes a set of mandatory security procedures that agencies must follow when they modify or buy new information systems.

“The memo is an outgrowth that, by and large, people didn’t understand the requirements, or the people who did are long gone,” Schlarman said. “Is there a security problem? OMB didn’t think so, but agencies need to verify it. If your encryption module is not validated, you don’t know whether the security you are getting is what you think it is.”

McAfee made its antivirus software FIPS 140-2 compliant in July 2006 and signed a SmartBuy deal in December. Mike Carpenter, McAfee’s federal group vice president, said it cost the company about $1 million to add a validated encryption module from PGP.

In March, antivirus vendor Symantec added a cryptographic module from RSA Security to its antivirus application to make it meet the federal cryptographic standard.

“It was more efficient to go outside and buy it instead of taking on additional development efforts that take place with a new release,” said Jim Russell, Symantec’s public-sector vice president.
NIST plans to release a new cryptographic standardNational Institute of Standards and Technology officials say the agency plans to release a draft version of Federal Information Processing Standard 140-3 before summer. Ray Snouffer, manager of NIST’s security testing and metrics group, said the new standard will eventually replace FIPS 140-2.

“FIPS 140-2 is fine the way it is, but we want to look at new technology types,” Snouffer said. “There are new types of attacks out there that we need to address.”

NIST has worked on the draft for more than a year. After the agency releases it, the public will have 90 days to comment on it. NIST expects to complete the new federal standard by spring 2008.
— Jason Miller

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