OpenSSL Blog

FIPS 140-2: Once More Unto the Breach


The last post on this topic sounded a skeptical note on the prospects for a new FIPS 140 validated module for OpenSSL 1.1 and beyond. That post noted a rather improbable set of prerequisites for a new validation attempt; ones I thought only a governmental sponsor could meet (as was the case for the five previous open source based validations).

Multiple commercial vendors have offered to fund (very generously in some cases) a new validation effort under terms that would guarantee them a proprietary validation, while not guaranteeing an open source based validation. At one point we actually came close to closing a deal that would have funded an open source based validation attempt in exchange for a limited period of exclusivity; a reasonable trade-off in my opinion. But, I eventually concluded that was too risky given an uncertain reception by the FIPS validation bureaucracy, and we decided to wait for a “white knight” sponsor that might never materialize.

I’m pleased to announce that white knight has arrived; SafeLogic has committed to sponsor a new FIPS validation on “truly open or bust” terms that address the major risks that have prevented us from proceeding to date. SafeLogic is not only providing the critical funding for this effort; they will also play a significant role. The co-founders of SafeLogic, Ray Potter and Wes Higaki, wrote a book about the FIPS 140 validation process. The SafeLogic technical lead will be Mark Minnoch, who I worked with extensively when he was director of the accredited test lab that performed the open source based validations for the OpenSSL FIPS Object Module 2.0. The test lab for this effort will be Acumen Security. While I’ve not worked directly with Acumen before, I have corresponded with its director and co-founder, Ashit Vora, on several occasions and I know SafeLogic has chosen carefully. With my OpenSSL colleagues doing the coding as before, in particular Steve Henson and Andy Polyakov, we have a “dream team” for this sixth validation effort.

Note that this validation sponsorship is very unusual, and something most commercial companies would be completely incapable of even considering. SafeLogic is making a bold move, trusting in us and in the sometimes fickle and unpredictable FIPS validation process. Under the terms of this sponsorship OpenSSL retains full control and ownership of the FIPS module software and the validation. This is also an all-or-nothing proposition; no one – including SafeLogic – gets to use the new FIPS module until and if a new open source based validation is available for everyone. SafeLogic is making a major contribution to the entire OpenSSL user community, for which they have my profound gratitude.

Now, why would a commercial vendor like SafeLogic agree to such an apparently one sided deal? Your typical MBA would choke at the mere thought. But, SafeLogic has thought it through carefully; they “get” open source and they are already proficient at leveraging open source. This new OpenSSL FIPS module will become the basis of many new derivative products, even more so than the wildly popular 2.0 module, and no vendor is going to be closer to the action or more familiar with the nuances than SafeLogic. As an open source product the OpenSSL FIPS module with its business-friendly license will always be available to anyone for use in pursuing their own validation actions, but few vendors have much interest in pursuing such a specialized and treacherous process when better alternatives are available. Having sponsored and actively collaborated with the validation from the starting line, SafeLogic will be in the perfect position to be that better alternative.

There are a lot of moving parts to this plan – technical details of the new module, interim licensing, schedule aspirations, etc. – that I’ll try to cover in upcoming posts.