So I understand:
- KISA itself operates the South Korean governement CA
- There other CAs in Korea (LCAs), and they are private
  organizations that are audited and signed by KISA.
- Those LCAs are not audited to comply with the baseline
  requirements, or it's at least not clear they are.

I see no reason to accept it if they're not required to
comply with the baseline requirements.

I really suggest those LCAs should instead apply for inclusion
themself.

About the contraining to *.kr.  I don't see why you want to do
that.  I understand that anybody can go to a one of those LCAs
and ask for a certificate for anything, and that it doesn't have
anything to do with the governement.  So I fail to see why that
certificate should be for .kr.


Kurt

On Tue, Mar 04, 2014 at 11:38:24AM -0800, Kathleen Wilson wrote:
> All,
> 
> I will appreciate your input on how to proceed with the KISA root
> inclusion request.
> 
> My personal preference is to proceed with the process to
> approve/include the KISA root under the condition that Mozilla would
> constrain the CA hierarchy to *.kr. However, KISA does not want to
> constrain their CA hierarchy to *.kr. I have also suggested that
> KISA have each subCA apply for inclusion as separate trust anchors,
> but KISA does not want to take that approach either.
> 
> The following is my understanding of this CA.
> 
> Inclusion Request Bug:
> https://bugzilla.mozilla.org/show_bug.cgi?id=335197
> CA Information Document:
> https://bugzilla.mozilla.org/attachment.cgi?id=727859
> KISA document repository:
> http://www.rootca.or.kr/kor/accredited/accredited02.jsp
> CPS (English):
> http://www.rootca.or.kr/kor/down/cps16(en).pdf
> 
> Korea Information Security Agency (KISA) is the Electronic Signature
> Authorization Management Center for South Korea. The Korean
> Certification Authority Central (KCAC) of KISA issues certificates
> to intermediate CAs (licensed CAs = LCAs), which then issue
> end-entity certificates to Korean citizens, businesses, and other
> organizations. The LCAs are private organizations (not government
> organizations).
> 
> The LCAs are listed in Korean at
> http://www.rootca.or.kr/kor/accredited/accredited02.jsp
> They are:
> Korea Information Certificate Authority Inc (KICA), http://www.signgate.com
> KICA CPS (Korean): http://www.signgate.com/customer/cus_cps.sg
> Korea Securities Computer Corporation (KOSCOM), http://www.signkorea.com
> KOSCOM CPS (English): https://bugzilla.mozilla.org/attachment.cgi?id=479655
> Korea Electronic Certification Authority Inc (CrossCert),
> http://gca.crosscert.com
> CrossCert CPS (English):
> https://bugzilla.mozilla.org/attachment.cgi?id=479658
> KTNET ("TradeSign" or "KITA"), http://www.tradesign.net/
> TradeSign CPS (English):
> https://bugzilla.mozilla.org/attachment.cgi?id=479659
> Korea Financial Telecommunications (KFTC), http://www.yessign.or.kr
> (non-profit)
> KFTC CPS (English): https://bugzilla.mozilla.org/attachment.cgi?id=479657
> 
> Deloitte completed a WebTrust audit of KISA's operation of the root,
> but the subordinate CAs (LCAs) are not WebTrust audited. The LCAs
> are regulated by the Korean Electronic Signature Act, and the law
> requires that KISA does the actual examination of the LCAs and
> report their findings to the government. The evaluation (audit)
> criteria are attached to the Bugzilla bug.
> Electronic Signature Act:
> https://bugzilla.mozilla.org/attachment.cgi?id=594638
> Enforcement Decree:
> https://bugzilla.mozilla.org/attachment.cgi?id=594639
> Enforcement Regulations:
> https://bugzilla.mozilla.org/attachment.cgi?id=594640
> 
> The LCAs are annually audited and are not allowed to change anything
> (system, h/w, s/w) without reporting to the government, and any
> mis-issuance of certificates would lead to penalty by the Act.
> 
> The Korean government controls the policies and technical standards
> under the Electronic Signature Act. Although the actual auditing is
> done by KISA, all the results are reported to the ministry
> (currently the Ministry of Science, ICT and future Planning). KISA
> is an expert group to help the ministry for the actual examination
> and other expertise for the national PKI. KISA is an affiliated
> organization of the ministry, and is run by the government. All the
> orders to control the LCAs are from the ministry.
> 
> Note that KISA is also the National Internet resources Center of
> Korea, http://krnic.kisa.or.kr/jsp/english/krnic/intro.jsp
> 
> We need to take into account sections 8 through 14 of Mozilla's CA
> Certificate Inclusion Policy:
> http://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/inclusion/
> 
> Section 10 says that if the subordinate CA certificate is not
> technically constrained (as described in section 9) then the
> subordinate CA must be audited according to sections 11 through 14.
> So, according to section 11 the subordinate CA operations must be
> audited according to the WebTrust CA or ETSI TS 102 042 criteria,
> and must also be audited according to the Baseline Requirements (the
> websites trust bit is requested).
> 
> My questions...
> 
> How would we know that the criteria that KISA uses to audit their
> LCAs is inclusive of the versions of the WebTrust or ETSI criteria
> that Mozilla's policy requires?
> 
> How would we know that the criteria that KISA uses to audit their
> LCAs is inclusive of the Baseline Requirements audit criteria that
> Mozilla requires?
> 
> Based on the above information, is there sufficient evidence to
> assert that the people within KISA who are performing the audits of
> the LCAs are qualified to do so, and are acting as an independent
> party as described in sections 13 and 14 of Mozilla's CA Certificate
> Inclusion Policy?
> 
> If KISA's root was to be included, should Mozilla products constrain
> the KISA hierarchy to *.kr? Why? Why not?
> 
> I will greatly appreciate your thoughtful input into how to proceed
> with this CA's root inclusion request.
> 
> Kathleen
> 
> _______________________________________________
> dev-security-policy mailing list
> dev-security-policy@lists.mozilla.org
> https://lists.mozilla.org/listinfo/dev-security-policy
> 
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