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Amped for FedRAMP

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David Gerendas, Group Product Manager, Intel Security
Ray Potter, CEO of SafeLogic

With the advent of the cloud and the explosion of mobile endpoints, enterprises have increased their focus on maintaining data integrity and confidentiality from growing threats. As a result, the Federal Risk and Authorization Management Program, a.k.a. FedRAMP, has taken on greater significance outside of federal deployments. By standardizing requirements and expectations, the program has set a strong benchmark for the entire cloud industry. In response to repeated security breaches that have damaged brands’ credibility, corporate mandates are now matching and even exceeding their government counterparts. If you are not FedRAMP compliant, enterprises demand to know why not.

The use of encryption is integral to FedRAMP and has become ubiquitous in the effort to protect information assets. But while certain crypto algorithms are often installed alone and unverified, customer expectations have risen in recent years. Enterprises certainly no longer accept homegrown cryptography from vendors, strongly preferring to rely upon solutions that have been vetted by third-party labs and validated by the government. Federal Information Processing Standard (FIPS) 140-2 is the leading international standard for encryption and the Cryptographic Module Validation Program (CMVP) was established to certify solutions that meet the stringent benchmark. In tandem, FedRAMP and FIPS offer the highest level of assurance for cloud buyers, but both are still generally misunderstood.

You will learn:
• What FedRAMP compliance entails
• Advantages of using a validated cryptographic module in the cloud
• How encryption modules become validated and the pitfalls of the process
• Meaning of FedRAMP compliance claims and how to confirm
• Right questions to ask vendors about their encryption and FedRAMP compliance

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Amped for FedRAMP

  1. 1. Amped for FedRAMP Cloud Security World, New Orleans Ray Potter CEO SafeLogic David Gerendas Group Product Manager Intel Security
  2. 2. Takeaways • What FedRAMP compliance entails • Advantages of using a validated cryptographic module in the cloud • How encryption modules become validated and the pitfalls of the process • Meaning of FedRAMP compliance claims and how to confirm • Right questions to ask vendors about their encryption and FedRAMP compliance 2
  3. 3. Assurance • A measure of confidence and trust (usually via a third party) that a product, product component, or system meets its claims or meets a specified set of requirements • Applies to products and to systems 3
  4. 4. Systems Assurance / FedRAMP
  5. 5. Systems Assurance • Using evaluated products does not provide an appropriate level of assurance by default • Need to look at overall functionality of the system • Risk mitigation / due diligence 5
  6. 6. FedRAMP • December 9, 2010 • Office of Management and Budget (OMB) released the 25 Point Implementation Plan To Reform Federal Information Technology Management • Cloud First policy was enacted -- requiring agencies to use cloud- based solutions whenever a secure, reliable, cost-effective cloud option exists. • December 8, 2011 • OMB FedRAMP Policy Memo: Security Authorization of Information Systems in Cloud Computing Environments • Establishes the Federal Risk and Authorization Management Program (FedRAMP) • Requires all Federal agencies to meet FedRAMP requirements by June 2014
  7. 7. Purpose • Ensure that cloud based services have adequate information security • Eliminate duplication of effort and reduce risk management costs • Enable rapid and cost-effective procurement of information systems/services
  8. 8. Applicable Standards and Guidance  FIPS Publication 140-2: Security Requirements for Cryptographic Modules  FIPS Publication 199: Standards for Security Categorization of Federal Information and Information Systems  FIPS Publication 200: Minimum Security Requirements for Federal Information and Information Systems  NIST SP 800-37, Rev 1: Guide for Developing the Risk Management Framework to Federal Information Systems: A Security Life Cycle Approach  NIST SP 800-53, Rev 4: Recommended Security Controls for Federal Information Systems  NIST SP 800-53A: Guide for Assessing the Security Controls in Federal Information Systems  NIST SP 800-137: Information Security Continuous Monitoring for Federal Information Systems and Organizations
  9. 9. Goals • Standardize security requirements • Accredit qualified third-party assessors • Provide repository of authorized secure cloud packages • Standardize on-going assessment methodologies • Standardize contract language
  10. 10. Key Stakeholders • Federal agency customer – has a requirement for cloud technology that will be deployed into their security environment and is responsible for ensuring FISMA compliance • Cloud Service Provider (CSP) – is willing and able to fulfill agency requirements and to meet security requirements • Joint Authorization Board (JAB) – reviews the security package submitted by the CSP and grants a provisional Authority to Operate (ATO) • Third Party Assessor (3PAO) – validates and attests to the quality and compliance of the CSP provided security package • FedRAMP Program Management Office (PMO) – manages the process assessment, authorization, and continuous monitoring process
  11. 11. Executive Sponsorship & Governance
  12. 12. Security Assessment Packages • JAB Provisional ATO • may take 18+ months; requires broader reviews/approvals • more widely accepted (government wide) • Agency ATO • May take 12+ months; only requires sponsoring Agency ATO • Agency reputation and experience matters • CSP Supplied • Package “in-waiting” • May not meet all acquiring agency requirements Category Assessed By Authorizing Authority FedRAMP Provisional Authorization Accredited 3PAO JAB Agency ATO w/ FedRAMP 3PAO Accredited 3PAO Agency CSP Supplied Accredited 3PAO None
  13. 13. Security Testing • Systems Security Plan • Security Assessment Plan • Security Test Cases • Security Assessment Report • Scanning / Continuous Monitoring
  14. 14. Authorization Process and Timeline Authorize CSP Addresses JAB Concerns JAB Review ISSO & CSP Review SSP 3PAO Creates SAP/ ISSO Reviews SAP JAB Review Final JAB Review / P-ATO Sign Off 3PAO Tests & Creates SAR System Security Plan Security Assessment Plan SAR & POA&M ReviewTesting JAB Review ISSO / CSP Reviews SAR CSP Addresses Jab Concerns Creates POA&M CSP Addresses JAB Concerns CSP Addresses Agency Concerns Agency Review CSP Implements Control Delta Agency Review SAP Address Agency Notes Final Agency ATO Sign Off 3PAO Tests & Creates SAR System Security Plan Security Assessment Plan SAR & POA&M ReviewTesting Authorize CSP Addresses Concerns Agency Reviews SAR CSP Creates POA&M Quality of documentation will determine length of time and possible cycles throughout the entire process -
  15. 15. AWS – Shared Security Model
  16. 16. AWS – Shared Security Model (Cont.)
  17. 17. Product Assurance / FIPS 140
  18. 18. Product Assurance • Certification or evaluation of a product or product functionality against a set of requirements • Required for product procurement in government and commercial industry • Sets a barrier to entry 18
  19. 19. FIPS 140-2 • Federal Information Processing Standard 140 • Specifies requirements for cryptographic hardware and software modules • Published by US (NIST) and Canadian Governments • Tested by independent laboratories • Offers 4 levels of validation 19
  20. 20. Areas of Validation • Module Definition • Ports and Interfaces • Roles, Services, and Authentication • Finite State Model • Physical Security • Operating Environment • Key Management • Self Tests 20
  21. 21. Why FIPS 140-2? • Required for Federal and industry procurement • Provides a level of confidence that encryption functions are implemented correctly and to a benchmark • FIPS Compliant – Embedding a module that already has a FIPS validation – Uses proven crypto functions • FIPS Validated – Getting your own certificate – Reassures buyers 21
  22. 22. Challenges of a Typical FIPS 140-2 Validation • Definition of the Module • HW & OS platform support • Use of approved algorithms • Development of appropriate documentation • Algorithm testing • Lengthy validation process • Significant time and resource requirements 22
  23. 23. Where Does FIPS 140 Fit? • Encrypt Data in Motion • Encrypt Data at Rest
  24. 24. The Role of FIPS 140-2 in FedRAMP • Validated crypto is required for government – FedRAMP – FISMA – SP800-53 • If crypto isn’t validated, it might as well be plaintext
  25. 25. Do Your Due Diligence • Where is your FIPS 140 Certificate? • Is the product / module FIPS-tested on a current platform? • For consumers / developers, is your CSP doing the right things? • Did you go through the FedRAMP process?
  26. 26. Let’s Connect • @SafeLogic_Ray • @SafeLogic • www.SafeLogic.com • info@SafeLogic.com

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