Europe built sovereign clouds to escape US control. Then forgot about the processors
Pangram verdict · v3.3
We believe that this document is primarily human-written, with some AI-generated content detected
AI likelihood · overall
MixedArticle text · 1,560 words · 5 segments analyzed
SystemsIntel ME and AMD PSP: The silicon layer nobody certifies
FEATURE Can digital sovereignty exist on American silicon? Europe is pouring more than €2 billion into sovereign cloud initiatives designed to reduce exposure to US legal reach. The EU's IPCEI-CIS program funds infrastructure development. France qualifies operators under SecNumCloud, a framework with nearly 1,200 technical requirements promising "immunity from extraterritorial laws."But most datacenters and qualified cloud operators still rely heavily on Intel or AMD processors. And inside those processors sits a computer beneath the computer: management engines operating at Ring -3, below the operating system, outside the control of host security software, persistent even when the machine appears powered off. Under the US Reforming Intelligence and Securing America Act (RISAA) 2024, hardware manufacturers count as "electronic communications service providers" subject to secret government orders. REG ADEurope's frameworks certify the clouds. They don't assess the silicon.REG ADThe computer your OS can't seeThat computer beneath the computer has a name. On Intel processors, it is the Management Engine (ME), or more precisely the Converged Security and Management Engine (CSME). On AMD, it is the Platform Security Processor (PSP). Both run at what security researchers call Ring -3, below the operating system, below the hypervisor, in a privilege level the host cannot see or log.
"It's a computer inside your computer," explains John Goodacre, Professor of Computer Architectures and former director of the UK's £200 million Digital Security by Design program. He is clear about what that means in practice. The ME has its own memory, its own clock, and its own network stack, and because it can share the host's MAC and IP addresses, any traffic it generates is indistinguishable from the host's own traffic to the firewall.The architecture is not theoretical. Embedded in the Platform Controller Hub, the CSME is a separate microcontroller that operates independently of the host, with direct memory, device access, and network connectivity the host operating system cannot monitor. AMD's PSP works the same way.Intel's Active Management Technology (AMT), the remote management feature the ME enables, exposes at least TCP ports 16992, 16993, 16994, and 16995 on provisioned devices. Goodacre notes that an attack surface exists on unprovisioned hardware too. These ports deliver keyboard-video-mouse redirection, storage redirection, Serial-over-LAN, and power control to administrators managing fleets of devices remotely. The capability has legitimate uses. It also provides a channel that operates at a level below what European sovereignty frameworks can attest.Microsoft documented in 2017 that the PLATINUM nation state actor used Intel's Serial-over-LAN (SOL) as a covert exfiltration channel. SOL traffic transits the Management Engine and the NIC sideband path, delivered to the ME before the host TCP/IP stack runs. The host firewall and endpoint detection saw nothing, and any security tooling running on the compromised machine itself was equally blind. PLATINUM did not exploit a vulnerability. It exploited a feature, requiring only that AMT be enabled and credentials obtained. In documented cases, those credentials were the factory default: admin, with no password set.Goodacre catalogues this and related scenarios in a 37-page risk assessment prepared for CISOs evaluating Intel vPro hardware connected to corporate networks. Its conclusion is blunt: connecting an untouched-ME device to corporate resources "exposes the organization to a class of compromise that defeats the host security stack in its entirety."The ME does not stop when the machine appears to.
Users recognize the symptom: a laptop powered off and stored for weeks is found, on next boot, to have a depleted battery. On modern thin and light platforms, what Microsoft documents as Modern Standby means "off" does not correspond to "all subsystems unpowered." The system-on-chip components the Management Engine runs on remain in low-power states, drawing enough to drain a 55 Wh battery over weeks, on the order of 100-200 mW continuous draw.REG ADThe implication is documented in Goodacre's risk assessment: "Whether the radio is in a Wake-on-Wireless-LAN listening state is firmware policy. On a device whose firmware has been tampered with during transit through the supply chain, the answer cannot be inferred from the visible power state." A laptop that appears off, in a bag, can associate with a hostile network the user has no knowledge of.Professor Aurélien Francillon, a security researcher at French engineering school EURECOM, has spent years studying exactly this class of problem. Working with colleagues, he built a fully functional backdoor in hard disk drive firmware [PDF], a proof of concept demonstrating how storage devices could silently exfiltrate data through covert channels. Three months after presenting it at an academic conference, the Snowden disclosures revealed the NSA's ANT catalogue, which documented an identical capability already deployed in the field. "The NSA were already doing it," Francillon says flatly. "Quite amazing." That background informs his assessment of the ME. "Yes, it can probably be used as a backdoor, like many other things, including BMC [baseboard management controller] and many other firmwares," he says. The question, he argues, is not whether the backdoor exists but whether operational controls make it unreachable in practice.AMD faces the same architectural question. On April 14, 2026, researchers demonstrated the Fabricked attack against AMD's SEV-SNP confidential computing technology, achieving a 100 percent success rate with a software-only exploit. The Platform Security Processor proved vulnerable to the same class of compromise.On server hardware, the picture is the same. Intel ME runs on servers under a different name, Server Platform Services or SPS, and the BMC, the remote administration controller standard in datacenter hardware, relies on it. "More or less the same," Francillon says of the server variant.
For datacenter operators, he sharpens the focus further: "If I look at cloud systems, servers, I would be more concerned with the BMC," pointing to published research demonstrating remote exploitation of BMC vulnerabilities that could allow an attacker to reinstall or fully compromise a server. The BMC is not a separate concern from the ME: on server hardware, it is the primary network entry point into the SPS, making it both the most exposed interface and the most consequential.Both Intel and AMD processors contain management engines that operate below the operating system. The silicon is designed by American companies and subject to American legal process.The backdoor the CLOUD Act doesn't useThat legal process has teeth that most European policymakers underestimate. The CLOUD Act, passed in 2018, gave US authorities extraterritorial reach to data held by American companies. FISA Section 702 allows intelligence agencies to compel US persons and companies to provide access to communications. Both are well known in European sovereignty discussions. They operate through the front door: a legal order served on a company that controls data. Less well known is RISAA 2024, a law that opens a different entrance entirely.REG ADRISAA amended FISA's definition of "electronic communications service provider" in ways that go beyond cloud operators and platform companies, and beyond the bilateral agreements that European policymakers have built their legal defenses around. Hardware manufacturers now fall within scope. Intel and AMD can be compelled, via secret orders with gag clauses, to cooperate with US intelligence access.The mechanism through which that access could be exercised is the management engine: a persistent, privileged, network-connected runtime that operates below anything the host operating system can see or block. A SecNumCloud-certified operator can be legally isolated from American data demands. The processor inside its servers cannot. "You've actually got a policy mechanism by which any such machine anywhere can deliver any of its information," Goodacre says.
RISAA's two-year term expired on April 20, 2026, but Congress extended it by 45 days while debating reforms. Whether it is renewed, amended or allowed to lapse, the architecture it targets does not change.SecNumCloud's blind spotFrance's SecNumCloud is Europe's most rigorous attempt to build a cloud certification that is legally immune to American law. It did not emerge from nowhere. ANSSI, France's national cybersecurity agency, was established in 2009 as part of a broader effort to build institutional muscle on digital sovereignty long before the term became fashionable. When Edward Snowden revealed the scale of NSA surveillance in 2013, France's response was technical rather than rhetorical: ANSSI published the first SecNumCloud framework in July 2014. A decade later, that framework has grown to nearly 1,200 technical requirements.At the time, SecNumCloud was a cybersecurity qualification, not a sovereignty instrument: it set requirements for architecture, encryption standards, access controls, and incident response, but said nothing about who controlled the underlying infrastructure or whose laws applied to it. The CLOUD Act changed that. Passed in 2018, it gave American authorities extraterritorial reach to data held by US companies, and suddenly a French cybersecurity framework had a geopolitical dimension it was not designed for. Version 3.2, introduced in 2022, added Chapter 19: a set of explicit requirements targeting extraterritorial law, mandating that only EU operators could run the service, that no non-EU party could access customer data, and that the provider could operate autonomously without external intervention. It promised "immunity from extraterritorial laws."In December 2025, S3NS, a joint venture between French defense and technology group Thales and Google Cloud, operating Google Cloud Platform technology under French control, became the first "hybrid" cloud to receive SecNumCloud qualification. The certification triggered heated debate: was this real sovereignty, or American technology with a European flag?But the debate missed a more fundamental question. Does SecNumCloud's certification reach as far as the silicon it runs on? Francillon is positioned to see both sides of that question.