While it’s fair to say that using a Cloud HSM means your keys are protected by a device meeting FIPS 140-3 standards, assuming the HSM in use has this certification, it’s important to realize this doesn’t guarantee the security you might expect. The security model of HSMs was built for the threats of the 1980s. These devices were not network-connected and were single-tenant — if they were “online” it was usually via HSMs attached to physical computers running an application on a machine connected to private networks — not connected to a globally reachable endpoint.

At their core, these devices were designed to protect keys from physical theft, more precisely, to slow down and increase the cost of theft, much like safe ratings (UL TL-15, TL-30, TL30x6) indicate for how effective the associated safes are. For example, early in my career, I worked on a project where we built attacks to extract non-exportable keys from a specific HSM and then imported them into another vendor’s HSM because the prior vendor went out of business. There have also been a number of key exfiltration bugs in these devices over the years as well.

We didn’t see network-connected HSMs until around 1999, but even then, these devices were single-tenant, essentially just a network-connected Linux or BSD box containing fundamentally the same hardware as years earlier. While this change did allow a single company to share an HSM across different application workloads, the assumption was still that this HSM was managed by the company in charge of all of these applications.

Why is this important today? Most computing is now done in shared cloud infrastructure, administered by someone else, with your competitor or an attacker on the same hardware as you. This presents a very different set of security considerations and design constraints than these devices were originally built. You are now exposed to the risks of the physical and logical administrators of these Cloud HSMs, the services they are dependent on, as well as other tenants of the Cloud HSM.

Consider that the compute operator usually can technically access the handle the application uses to talk to the HSM, and likely the secret used to authenticate to this HSM as well, meaning they, or an attacker, could potentially use that handle, or secret,  to sign, or decrypt data as they wish. You might find that an acceptable risk, but did you know some HSMs allow the administrator to blindly add users as operators to the “virtual HSMs” within it? Yup, they do.

What about when keys are stored in a KMS and the key policy dictates the key be managed by an HSM? If the HSM hardware attests that the key is stored in the HSM, and this attestation is verified, it’s nearly the same threat profile we just discussed. In some cases, it could be argued it is better because access to the HSM can have traditional user and service RBAC controls, and rate limiting, and keys can be replicated to many other HSMs without any administrative burden for you, keeping you safe from a common disaster recovery scenario while normalizing the management of these devices so it fits into your normal operational practices which hopefully are well managed and monitored.

Regardless of the approach, the bigger question is whether your provider’s operational and security practices are up to your specific threat model. Imagine a Bitcoin wallet worth 100 million dollars. Has your cloud provider proportionally invested enough into controls and tests around their system to prevent a motivated attacker from using your key to sign a transaction that moves all that to another wallet? Probably not.

The fundamental issue is that today’s HSMs were largely designed for different eras with different security concerns than we typically have today, mainly to protect against physical theft of keys in environments where data centers were effectively closets in dedicated office space. That doesn’t reflect today’s cloud computing scale.

It is worth noting that there are a few HSM solutions on the market that are making efforts to tackle some of these issues, but they still fall short but that is a topic for another post.

In essence, Cloud HSMs are to HSMs what Tenement Farming is to Farming.

That’s not to say there’s no value in these offerings, but as built today, they often fail to deliver the value they are assumed to deliver. And if regulations mandated their use before, say, 2010, chances are they’re not delivering the intended value that those regulations had in mind.

So, how should we be protecting keys now?

To be clear, this is not a case against Cloud HSMs, it is an argument to think about the threat model and use case you are solving for — for example if we look at Storm-0558 where Microsoft appears to have been using the private key material in the process of their IDP, the attacker was able to get a memory dump to be created and then via another attack vector gather the memory dump, and as a result the private key, we can take away at least one solid lesson. Do not load keys into the process of the applications that rely on them. In this case, the least costly method to have prevented this key theft would be simply moving the key to another process running in another user context with a very simple API that is easy to defend and can at least limit the attacker to a handle vs. what happened in this case where the attacker was able to use the key with impunity for years. This approach is the rough equivalent of a workload or node-specific software HSM similar in spirit to the original HSMs.

Another common problem we see in the industry is, that solutions like Hashicorp vault were designed to centralize key management and provide a one-size-fits-all answer to “Where do I keep my secrets?” Architecturally these solutions look much like a passively encrypted database, if you have sufficient permissions you can read the key in the clear and then copy it to whatever node or workload needs to use the key. This took us from secret sprawl to secret spray where we pushed the keys out in environment variables and files on production machines that later get dumped into logs, and backups, continuously exposing the keys to users who should have never had access, and often leaving key remnants all over the place. This is only marginally better than checking keys into dedicated source control repositories.

The problem here isn’t limited to these secret sprawl solutions, considering that almost every web-server TLS private key is sitting in the file system often with weak ACLs without any encryption which is then loaded into memory on that web server in the process. Similarly, most SSH keys are also sitting in some file, usually with a poor ACL, with a key either in the clear or with an easily grindable password so a malicious actor that gains read access to the file system is all that is needed to walk away with the key, for example, see this incident from last week. 

In both of these cases, we would be much better off if we would move these keys into another user context that is more defensible and constrained.

So how did we end here with such abysmal practices for managing keys?

While there is seldom one single reason to see such neglect, in this case, I think one of the largest is the dogmatic “all keys must be kept in HSMs or smart cards”. It is just too easy of a get-out-of-jail-free card for a security professional. Instead of thinking about the real risks and operational practices and then designing strategies to mitigate those threats that are practical and appropriate people who can afford to complete that checkbox do and those who can not just copy keys around in the clear out of a database.

The reality is we can do a lot better but as they say, the first step is to accept that you have a problem.

In short, as security professionals we need to avoid dogmatic answers to complex questions and spend the time to look more critically at the risks, constraints, obligations, resources, and real-world scenarios those we work with are operating within before we throw generic playbook answers to those coming to us for advice.