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FedRAMP is designed to provide reusable cybersecurity work against the NIST security controls that your Federal agency's Authorizing Official deems your Federal
by mpyne 5y ago
FedRAMP is designed to provide reusable cybersecurity work against the NIST security controls that your Federal agency's Authorizing Official deems your Federal IT system must implement.
Those security controls come from a document NIST SP 800-53, 2 of which (that Slack linked to in the linked post-mortem), SC-20 and SC-21, effectively seem to me to conspire to require DNSSEC. Both of these are included as part of the "Low" baseline of security controls, so they are effectively required for all Federal IT systems unless your Agency Authorizing Official wants to walk on the wild side.
So even if you get a FedRAMP certification, if you do it without fully implementing SC-20 and SC-21, that just means your customer needs to either convince their Agency Authorizing Official to sign off on an ATO despite the missing SC-20 and SC-21 security control, convince them to sign off on some sort of Plan of Action and Milestones where Slack will commit to fix this in the future (which is just kicking the can down the road), or somehow manage to implement the same effect completely within the customer end without help from Slack. All you would have done is to spend a lot of money on FedRAMP paperwork without making it appreciably easier for potential customers who have to deal with compliance regimes to buy your product.
Cloud.gov's argument is valid but all they posted is that they don't implement SC-20 or SC-21 for their government customers, and that the OMB M-08-23 mandate for DNSSEC is no longer operative (not that no other DNSSEC mandate applies). Indeed they even give explanation for how their customers should work to enable it (presumably by refusing to use the non-DNSSEC compliant .app.cloud.gov services and instead using only their DNSSEC-compliant custom domains).
FWIW I fully agree with tptacek's arguments against DNSSEC, and will note that I recently stopped being able to navigate to literally the entire .mil on my Linux host until I disabled DNSSEC in systemd, for reasons that are still unclear to me even now.