The ICMP protocol has been widely used and accepted as a covert channel. While the ICMP protocol is very simple to use, modern security approaches such as Firewalls, deep-packet inspection and intrusion detection systems threaten the use of ICMP for a reliable means for a covert channel. This study explores the modern usefulness of ICMP with typical security measures in place. Existing ICMP covert channel solutions are examined for compliance with standard RFCs and resiliency with modern security approaches.