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Adoption of the Standard The American National Standards Institute (ANSI) approved DES as a private-sector standard in 1981 (ANSI X3.92) [50]. They called it the Data Encryption Algorithm (DEA). ANSI published a standard for DEA modes of operation (ANSI X3.106) [52], similar to the NBS document, and a standard for network encryption that uses DES (ANSI X3.105) [51]. Two other groups within ANSI, representing retail and wholesale banking, developed DES-based standards. Retail banking involves transactions between financial institutions and private individuals, and wholesale banking involves transactions between financial institutions. ANSI’s Financial Institution Retail Security Working Group developed a standard for the management and security of PINs (ANSI X9.8) [53] and another DES-based standard for the authentication of retail financial messages (ANSI X9.19) [56]. The group has a draft standard for secure key distribution (ANSI X9.24) [58]. ANSI’s Financial Institution Wholesale Security Working Group developed its own set of standards for message authentication (ANSI X9.9) [54], key management (ANSI X9.17) [55,1151], encryption (ANSI X9.23) [57], and secure personal and node authentication (ANSI X9.26) [59]. The American Bankers Association develops voluntary standards for the financial industry. They published a standard recommending DES for encryption [1], and another standard for managing cryptographic keys [2]. Before the Computer Security Act of 1987, the General Services Administration (GSA) was responsible for developing federal telecommunications standards. Since then, that responsibility transferred to NIST. The GSA published three standards that used DES: two for general security and interoperability requirements (Federal Standard 1026 [662] and Federal Standard 1027 [663]), and one for Group 3 facsimile equipment (Federal Standard 1028) [664]. The Department of the Treasury wrote policy directives requiring that all electronic-funds transfer messages be authenticated with DES [468,470]. They also wrote DES-based criteria that all authentication devices must meet [469]. The ISO first voted to approve DES—they called it the DEA-1—as an international standard, then decided not to play a role in the standardization of cryptography. However, in 1987 the International Wholesale Financial Standards group of ISO used DES in an international authentication standard [758] and for key management [761]. DES is also specified in an Australian banking standard [1497]. Validation and Certification of DES Equipment As part of the DES standard, NIST validates implementations of DES. This validation confirms that the implementation follows the standard. Until 1994, NIST only validated hardware and firmware implementations—until then the standard prohibited software implementations. As of March 1995, 73 different implementations had been validated. NIST also developed a program to certify that authentication equipment conformed to ANSI X9.9 and FIPS 113. As of March, 1995, 33 products had been validated. The Department of the Treasury has an additional certification procedure. NIST also has a program to confirm that equipment conforms to ANSI X9.17 for wholesale key management [1151]; four products have been validated as of March, 1995. 1987 The terms of the DES standard stipulate that it be reviewed every five years. In 1983 DES was recertified without a hitch. In the March 6, 1987 Federal Register, NBS published a request for comments on the second five-year review. NBS offered three alternatives for consideration [1480,1481]: reaffirm the standard for another five years, withdraw the standard, or revise the applicability of the standard. NBS and NSA reviewed the standard. NSA was more involved this time. Because of an executive directive called NSDD-145, signed by Reagan, NSA had veto power over the NBS in matters of cryptography. Initially, the NSA announced that it would not recertify the standard. The problem was not that DES had been broken, or even that it was suspected of having been broken. It was simply increasingly likely that it would soon be broken. In its place, the NSA proposed the Commercial COMSEC Endorsement Program (CCEP), which would eventually provide a series of algorithms to replace DES [85]. These NSA-designed algorithms would not be made public, and would only be available in tamper-proof VLSI chips (see Section 25.1). This announcement wasn’t well received. People pointed out that business (especially the financial industry) uses DES extensively, and that no adequate alternative is available. Withdrawal of the standard would leave many organizations with no data protection. After much debate, DES was reaffirmed as a U.S. government standard until 1992 [1141]. According to the NBS, DES would not be certified again [1480]. 1993 Never say “not.” In 1992, there was still no alternative for DES. The NBS, now called NIST, again solicited comments on DES in the Federal Register [540]: The purpose of this notice is to announce the review to assess the continued adequacy of the standard to protect computer data. Comments from industry and the public are invited on the following alternatives for FIPS 46-1. The costs (impacts) and benefits of these alternatives should be included in the comments: — Reaffirm the standard for another five (5) years. The National Institute of Standards and Technology would continue to validate equipment that implements the standard. FIPS 46-1 would continue to be the only approved method for protecting unclassified computer data. — Withdraw the standard. The National Institute of Standards and Technology would no longer continue to support the standard. Organizations could continue to utilize existing equipment that implements the standard. Other standards could be issued by NIST as a replacement for the DES. — Revise the applicability and/or implementation statements for the standard. Such revisions could include changing the standard to allow the use of implementations of the DES in software as well as hardware; to allow the iterative use of the DES in specific applications; to allow the use of alternative algorithms that are approved and registered by NIST. The comment period closed on December 10, 1992. According to Raymond Kammer, then the acting director of NIST [813]: Last year, NIST formally solicited comments on the recertification of DES. After reviewing those comments, and the other technical inputs that I have received, I plan to recommend to the Secretary of Commerce that he recertify DES for another five years. I also plan to suggest to the Secretary that when we announce the recertification we state our intention to consider alternatives to it over the next five years. By putting that announcement on the table, we hope to give people an opportunity to comment on orderly technological transitions. In the meantime, we need to consider the large installed base of systems that rely upon this proven standard. Even though the Office of Technology Assessment quoted NIST’s Dennis Branstead as saying that the useful lifetime of DES would end in the late 1990s [1191], the algorithm was recertified for another five years [1150]. Software implementations of DES were finally allowed to be certified. Anyone want to guess what will happen in 1998?
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