Reminds me of a Thales rack mount HSM the former security architect of CVS Caremark told me they deployed back in the 2000s. There were two of them in a dataceter used for a their transaction processing. One day, someone accidentally bumped into the rack where both HSMs were mounted, and they physically self-destructed, causing a major incident.

For the higher levels, definitely. But even for just "we need FIPS" (which is always level 1) it's at least some form of guarantee in that anyone who gets it has proven that they're desperate enough for government contracts that they're willing to set fire to several hundred thousand dollars to prove it. So it's a guarantee, just not necessarily the one intended.

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"FRR9: CSPs shall determine if updating to a newer version of the software, whether or not its cryptographic modules are FIPS validated, would eliminate the vulnerabilities; if it would, CSPs shall promptly update if that is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

There’s no automatic enforcement across most systems though. You can use a Thales HSM that’s configured in FIPS mode just fine from non-FIPS software.

At this point, I'd rather be waterboarded than do any more compliance. Especially in this heat.

because for most use cases FIPS-140 have been waste of time for everyone involved

Presumably the prompt focused on the aspect described in the title, and the LLM obliged.