Perhaps never a true guarantee, but level 4 HSMs are still impressive.

> The 4769 HSM has been verified to meet the FIPS 140-2 Level 4 requirements by protecting against attacks that include penetration of the secure module, side-channel attacks, and environmental failure protection (power or temperature manipulation). From the time of manufacture, the hardware is fully self-protecting. If tamper sensors detect a possible attack, all critical keys and other sensitive data are immediately destroyed and the HSM is rendered permanently inoperable. Note therefore that the 4769 HSM must be maintained at all times within the temperature, humidity, and barometric pressure ranges specified.

https://public.dhe.ibm.com/security/cryptocards/pciecc4/docs...

Huh, I don't know about the world of HSMs or crypto and their audits, but in FedRAMP SaaS, you absolutely have to run everything with FIPS mode enabled, there are strong guarantees that need to be in place and audited.

> Track the lifecycle, not the purchase.

In my experience this is the core issue with security. It has to be a continuous process in reality but its hard to justify the cost and resource allocation. For this reason it ends up being a point in time function leaving gaps over the life cycle of the product.

The practical benefit of FIPS 140 is less that your crypto is better and more that your systems will fail to establish connections with anything not using FIPS mode, thus reducing your threat exposure. A silver lining to the overall unfortunate situation that is the FIPS CMVP.

Every customer wants FIPS 140-3 until the realize the performance hit. Then suddenly they don’t remember why they wanted it. Datasheet engineering FTW.

Why does the tone have to be ragebait? This is just a basic overview of what compliance looks like.

Government crypto governance seems to be written by people who think aerospace engineering is the epitome of diligence.

My friends in Christ, a aerodynamic object need only contend with 7 degrees of freedom, and occasional take-offs and landings.

FedRAMP actually has a bunch of workarounds for the problems of FIPS.

In the "FedRAMP Policy for Cryptographic Module Selection and Use" (https://www.fedramp.gov/resources/documents/FedRAMP_Policy_f...), there are a ton of gems that make it clear that the FedRAMP folks are fed up with the CMVP process backlog. The most explicit is:

"FRR9: CSPs shall determine if updating to a newer version of the software, whether or not its cryptographic modules are FIPS validated, would eliminate the vulnerabilities; if it would, CSPs shall promptly update if that is feasible."

In reality FedRAMP has multiple variations, low, moderate, high, gives enough wiggle room to companies on what they can do when. Other good thing about government is that its quite flexible when needed. There is always exists a path to override a regulation if required.

Even on fedramp high, it’s possible to just be mistaken about configurations and still pass. I have been in the situation where I’m the guy answering all sorts of questions to the best of my ability to get the certification, then later discovered some of the claims made by developers were just not true and we had been out of compliance on a fedramp high datacenter for months. On accident.

If the requirement causes a massive security hole, the lawyers will probably tell you that knowingly allowing a security hole from a liability perspective is worse than turning off something an audit will flag.

I don't know about FedRAMP specifically, but I have gone through several procurements for federal agencies on the vendor side, and have never had any issues getting a FIPS waiver approved.

> That lag creates a perverse choice every vendor of validated modules eventually faces: ship the security fix now and fall off the validated list for a year or more, or keep shipping the validated build with the known flaw. Customers whose contracts require an active certificate are, in effect, paying the vendor to choose the second option.

That's what the blog post says about why/when FIPS is turned off, although I'm not sure I completely agree with this take. All forms of compliance in all industries (not just IT) is like this. Otherwise we get a lot of cowboy solutions.

This is why compliance does not operate in a silo. There's the baseline (when FIPS is on) and then there's the real world configuration that the business must carefully accept along with its own risks. This is why you have your own employees auditing and collaborating with everyone else involved in the decisions. That can often include the client wanting your services that depend on the HSMs. I'm not understanding what all the frustration is about unless some people have just never left their silo.

If your client is the government, then of course they're going to be very strict about FIPS. We're all at least in agreement that FIPS sucks because it moves at a glacial pace. There's a reason the phrase: "good enough for government work" means mediocre.