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Editor's note: This post was updated on March 14, 2017 to reflect a distinction that came to light in dialogue with CMVP - validations moved to the Historical List have not been revoked outright. The validation still exists, but are not for Federal Agencies to include in a new procurement. Agencies are recommended to conduct a risk determination on whether to continue using existing deployments that include modules on the Historical List.

Over a year ago, our blog featured posts about the RNG issue that was leading to certain FIPS 140-2 validations moving to the Historical List and the 5 year sunset policy that CMVP was adopting. [Geez, was that really more than a year ago? Crazy.]

Now the hammer has dropped, and the industry is seeing modules routinely relegated to the Historical List each month. The sunset policy created a waterfall in January 2017, and as of today, there are 1,914 modules on the Historical List, representing approximately 2/3rds of the total validations completed in the history of the CMVP.

Let me repeat that for emphasis. 1,914 modules.
Approximately 2/3rds of all modules ever validated by NIST to meet the FIPS 140 standard are no longer on the active validation list.

This includes some modules that were updated in 2016, and a few were even just revised in 2017! Many of these are hardware, so they are often more static and harder to update, but certainly not all. Check out the entire Historical Validation List for yourself. It's a veritable "Who's Who" of once-proudly validated companies. Big names, hot startups, none are immune. Between the sunset timeline and the active removal of modules that are no longer compliant, the herd has been severely thinned.

The takeaway? Maintaining FIPS 140 validation is really hard! It's not "just one big push" to get on the list anymore. It requires constant vigilance to stay on top of the updates and to keep up with NIST's reinvigorated policies. A more active CMVP can seem like a pain in the ass at first glance, but it is ultimately better for the industry. Nobody (except for lazy vendors) benefited from old, insecure, 'grandfathered' modules remaining on the active validation list. A stringent, active CMVP has embraced their role as a clearing house and it increases the value of the modules that do satisfy current standards. And I think they're doing a great job.

This underscores the strategic significance of relying upon SafeLogic to complete and maintain FIPS 140-2 validation. As I tell folks every day, this is our focus. Our business is based upon the proper production of FIPS-compliant modules and their subsequent validation. Our customers reap the benefits of our work, and we succeed by scaling it, replicating our effort and leveraging our niche expertise for each client. CryptoComply is smooth and RapidCert accelerates the initial validation, but our customers have really appreciated the value of offloaded maintenance for the certificate. We talk a lot about the time, money, and effort with the traditional process, and the savings realized when using SafeLogic are growing. The delta is getting wider.

I scratch my head when a product manager boasts that they plan to roll their own crypto and get it validated. There are no bonus points for suffering in-house or for reinventing the wheel. When you hire consultants to complete a validation, you're paying a premium for a single push, when the maintenance really is a constant effort. Consider those costs in time, money, and effort to complete your initial validation - and then add a multiplier for every revalidation you anticipate. It will be at minimum a quinquennial (every five years) project, and that's if you're lucky enough to avoid any other pitfall. The math doesn't lie - the traditional path to FIPS 140-2 validation has become cost prohibitive. And if you're pursuing Level 2 or Level 3, you still need a solid crypto module at the heart of the product. Using CryptoComply ensures that component meets the necessary requirements, again saving time, money, and effort.

CryptoComply is proven, again and again, to continually meet standards and retain its validated status with NIST. This is one of those situations where you don't need to be creative. Choose SafeLogic, let us take care of the crypto, and you can get back to doing what you do best.