David,


Does FIPS-140-2 actually put this restriction on a KDF?

Yes, perhaps this may help explain the matter:

FIPS 140-2 is a prescriptive standard; vendors are not allowed to mix and match elements of security functions, and no KDF is by itself an approved security function. A KDF can therefore only be used as a component to an existing allowed security function.

For example, currently FIPS modules can establish keys with TLS. TLS uses a KDF, so the TLS-KDF may be used, but only in the context of TLS. The draft you cited is a KDF used in within draft-SP800-56, as well as in ANSI X9.63. The acceptability of the KDF depends on which key establishment protocol it is used in.

To see a list of which key establishment protocols are allowed, look at Annex D. You'll find that effectively NIST allows only asymmetric key establishment. Within the framework of an allowed asymmetric key establishment, multitudes of KDFs may be used, but not in LRW-AES. I'm assuming here that we will not create a TLS style key agreement scheme in which we generate keys from a KDF. Outside of asymmetric crypto, you have to stick to generating keys from a PRNG or having the keys loaded externally into your module.


That's certainly an unneeded restriction,

:)

and also it is at odds with Section 3.1 of http://www.ietf.org/ internet-drafts/draft-dang-nistkdf-00.txt, "(Key Derivation from) Secret Values Established out of band". So even if the current FIPS-140 docs have this restriction, it is clearly not the intended direction of NIST.

No, Section 3.1 says that the values may be established with a mechanism out of scope of the draft, in which case shared info values must be provided by that mechanism. Section 3.1 does not discuss whether the parent key establishment framework is or is not allowed in FIPS 140-2.

Well, it's not necessary to leave KDFs out of the specs in order to allow implementations to be FIPS-140 conformant. It is sufficient to not have a mandatory-to-use KDF that is not FIPS-140 conformant. The spec could mandate a KDF that didn't conform to FIPS-140, and it would still be possible to get a FIPS-140 validation, which would need to reference a security policy describing how to operate the cryptomodule in a manner that didn't use the non-coformant KDF.

Yes, I agree. However, I view the current LRW-AES document as the definition of an encryption mode. It is unusual to mandate any type of key management in an encryption mode definition -- even if the mandate consists of a list of options. It's fine to have a discussion of threats and advantages relating to keys, but to specify key derivation algorithms is dangerous. First, you can't forsee how this mode will be used, if successful, so there is a risk of hamstringing vendors in the future. Also, suppose a vulnerability is announced in a KDF -- does this kill AES-LRW? Tomorrow a hot KDF is announced, and vendors want to use it instead of what is specified. In general requirements on the keys should be stated in a mode document, not mechanisms of achieving those requirements. Optimizations to mechanisms, although valuable, are rarely robust.

Note that NIST has already issued SP-800-57 Part 1, General Key Management Guidance. A discussion of how those requirements apply when using LRW-AES in a stored data environment would be an important document to have, but not incorporated into the specification of the encryption algorithm.

Thanks,
Robert

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