FedRAMP and FIPS 140-2/140-3 Encryption Validation

Michael Peters

3 weeks ago

Achieving FedRAMP authorization requires a hardened approach to cryptographic validation beyond shallow ciphers. For CSPs, simply saying that you use AES-256 or support TLS without verified, validated cryptographic modules introduces fatal flaws into authorization efforts.

To succeed, CSPs must build systems that assume validation is an operational need and not something they do after the fact. They must also recognize that misinterpretations of FIPS requirements can derail otherwise sound security architectures during 3PAO audits or agency reviews.

The Non-Negotiable Nature of FIPS 140 Validation in FedRAMP

FedRAMP Moderate and High baselines explicitly require that any cryptographic module used to protect CUI or manage cryptographic keys be validated under the NIST Cryptographic Module Validation Program (CMVP). Validation requires an NIST certificate number, publication on the NIST CMVP database, and implementation with validated hardware, software, and firmware.

Many organizations assume libraries like OpenSSL or BoringSSL satisfy requirements; however, the implementation is non-compliant unless it operates within its validated cryptographic boundary (often requiring special configurations, startup self-tests, and tamper response checks).

Real-World Audit Failures Due to Issues with FIPS

FedRAMP auditors and agency reviewers consistently identify common failure patterns related to cryptographic validation:

Non-Validated TLS Implementations: CSPs using reverse proxies compiled with non-FIPS mode libraries, even if they offer TLS 1.2+, have been flagged for critical findings.
Third-Party SaaS Dependencies: Services integrating third-party identity providers or logging solutions without verified FIPS modules for session management or secure API calls often fail FedRAMP Moderate requirements.
Custom Software Modifications: Applications embedding open-source crypto libraries but recompiling or modifying them invalidate the original module’s certification unless separately validated.
Incomplete Boundary Documentation: Failure to define cryptographic module boundaries in the SSP, or assuming the entire operating system is the boundary, leads to immediate technical clarifications and significant authorization delays.

Each failure stems from the false assumption that algorithm selection satisfies cryptographic requirements, rather than verified modules and hardware.

The FIPS 140-3 Transition and Long-Term Authorization

While FIPS 140-2 remains accepted under FedRAMP, NIST has shifted its active certification program to FIPS 140-3, aligning requirements with ISO/IEC 19790:2012 standards. FIPS 140-3 introduces deeper requirements around module design assurance, life-cycle management, and post-quantum cryptography considerations.

CSPs pursuing new FedRAMP authorizations will find themselves facing new requirements:

Module Lifecycle Risk: NIST has issued sunset timelines for FIPS 140-2 certificates. Modules validated under 140-2 will eventually transition to the “historical” list, triggering FedRAMP reassessment obligations.
Procurement Risk: Agencies increasingly prefer systems validated under 140-3, seeing them as future-resilient investments amid executive orders like EO 14028 demanding modernization.
Validation Delay Risk: Due to increased complexity, FIPS 140-3 validation processes have longer timelines (12-18 months on average) than FIPS 140-2. Waiting until modules are deprecated leaves CSPs vulnerable to significant authorization interruptions.

Thus, CSPs pursuing sustainable FedRAMP positions should prioritize new cryptographic modules already validated or actively undergoing testing under FIPS 140-3, even if 140-2 modules remain technically acceptable.

Strategies for Achieving FIPS Validation Compliance in FedRAMP Systems

CSPs must approach FIPS validation as an architectural and operational requirement to avoid catastrophic gaps during 3PAO audits or JAB reviews. Expert strategies include:

Select Only NIST-Validated Modules

Every cryptographic component, from disk encryption to web servers to VPN appliances, must utilize modules listed on the NIST CMVP Validated Modules List. Always verify:

Correct operating environment match (OS version, firmware version).
Specific cryptographic boundary documentation.
Module versions match precisely what is deployed.

Modules “in process” (pending validation) must not be treated as validated unless a formal Plan of Action and Milestones (POA&M) with agency concurrence exists… and even then, it is a high-risk mitigation.

Design Cryptographic Workflows Inside FIPS Boundaries

Cryptographic key generation, storage, distribution, and destruction must occur entirely within validated modules. An example mistake is generating random keys on a non-validated system and importing them into a validated environment. This breaks the trust chain and violates SC-12 and SC-13 controls in FedRAMP.

All session establishment techniques (TLS handshakes, SSH logins, IPsec tunnels) must start within FIPS-validated boundaries. Handshakes initiated or completed outside of validated modules may be considered noncompliant.

Enable and Document FIPS Mode Operations

Merely installing a validated module is insufficient. Systems must be configured explicitly by FIPS, typically enforced via kernel parameters, environment variables, or application settings.

CSPs must provide SSP narrative details and screenshots/logs demonstrating:

FIPS mode is enabled on boot.
Self-tests pass at startup (integrity checks).
Logging records of FIPS mode enforcement and failures.

Without this documentation, FedRAMP 3PAOs often assume the system isn’t FIPS-aligned.

Map Cryptographic Usage Per Control, Not Globally

Rather than asserting “our system uses FIPS modules” broadly, map cryptographic implementations at the control level, especially for SC family controls. For each instance, your organization should, for every cryptographic module, be able to:

Identify the module used.
Provide the certificate number.
Describe a cryptographic boundary.
Document evidence artifacts (configs, logs).

This control-by-control mapping significantly reduces audit findings and clarifications.

Plan for Cryptographic Module Updates Proactively

Validated modules can become obsolete due to:

New vulnerabilities (side-channel attacks).
Module boundary changes.
NIST “historical” status transitions.

Build continuous monitoring (CONMON) processes that monitor module statuses quarterly. The budget for periodic revalidations or module upgrades should be aligned with CMVP updates.

Quantum Readiness and Cryptographic Modernization

Executive orders and NIST research increasingly point toward a future where traditional asymmetric cryptography will be vulnerable to quantum attacks. FedRAMP is expected to integrate quantum-resilient requirements gradually into baselines before quantum threats can make an end-run around existing cryptographic techniques.

Accordingly, forward-looking CSPs are beginning to:

Inventory cryptographic dependencies across systems.
Assess readiness to migrate to post-quantum cryptographic algorithms like CRYSTALS-Kyber and CRYSTALS-Dilithium.
Engage vendors who are incorporating NIST’s PQC recommendations into future FIPS validations.

Organizations that integrate quantum risk assessments into their FedRAMP roadmaps will be better positioned to meet evolving federal standards without facing disruptive re-authorization events.

Document and Report on Cryptographic Ciphers with Continuum GRC

FedRAMP compliance demands that cryptographic protections are theoretically strong and operationally validated under FIPS 140-2 or FIPS 140-3 requirements. Misunderstanding or underestimating the rigor around cryptographic module validation consistently leads to authorization delays, audit failures, and increased program costs.

Implementing effective log management practices is essential for achieving CMMC compliance and enhancing an organization’s overall cybersecurity resilience.

Continuum GRC is a cloud platform that stays ahead of the curve, including support for all certifications (along with our sister company and assessors, Lazarus Alliance).

We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.

Continuum GRC is a proactive cybersecurity® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and learn how we can help protect its systems and ensure compliance.

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