This is useful feedback.  Thanks.

-Tim

-----Original Message-----
From: dev-security-policy 
[mailto:dev-security-policy-bounces+tim.hollebeek=digicert....@lists.mozilla.org]
 On Behalf Of Jakob Bohm via dev-security-policy
Sent: Tuesday, December 12, 2017 6:36 AM
To: mozilla-dev-security-pol...@lists.mozilla.org
Subject: Re: On the value of EV

On 12/12/2017 01:08, Adam Caudill wrote:
>>>> Even if it is, someone filed the paperwork.  Court houses have 
>>>> clerks, guards, video cameras, etc...  It still may present a real 
>>>> physical
> point
>>>> from which to bootstrap an investigation.
>>>
>>> Court houses also have online systems. I think if you read both Ian 
>>> and
> James' work, you'll see the issues they're raising address this 
> hypothetical.
>>
>> I shall certainly read their work closely on that matter.  In my
> experience, these generally don't allow filings for new businesses 
> from those not previously known to the court/registrar in real life.
> 
> I can say from my own experience, in some states in the US, it's a 
> trivial matter to create a company online, with no validation of 
> identity or other information. It takes about 10 minutes, and you'll 
> have all the paperwork the next day. When I did this (in a state I had 
> never done business in before), there was absolutely no identity 
> checks, no identity documents, nothing at all that would tie the 
> business to me if I had lied. Creating a business with no connection 
> to the people behind it is a very, very simple thing to do.
> 

A lot of people have posed suggestions for countermeasures so extreme they 
should not be taken seriously.  This includes discontinuing EV, requiring that 
companies cannot get EV certs during their first year of existence, or 
suggesting that only "famous" companies can get EV certificates.

Here is a more reasonable suggestion:

1. In the Fx UI, display the actual jurisdictionOfIncorporation instead
   of just the country, especially where those differ (For example
   Kentucky versus all-of-US).

2. Add a rule that if there is a big national or international company
   with a name, other companies cannot get certificates for the same
   name in related jurisdictions.  For example if there is a company
   listed on NYSE or NASDAQ, no similarly named US company can get an
   EV or OV certificate for that name.  Ditto for a reasonable list of
   national registries in each country.  CAs should be required to
   publicly state which "big-status" lists beat local
   company/organization registrations in each country, and similar for
   any special lists of major global organizations, such as Google or
   The Red Cross.

3. Minimum (not maximum) standards for such things need to be published
   by the CAB/F.

4. Note that stock exchanges should not be the only list of "nationally
   significant companies", as that would exclude a lot of companies with
   different ownership structures, such as Mozilla Inc. or the pre-IPO
   Google.  However the list criteria should be clear and not rely
   too heavily on the subjective experience of vetting agents etc.

5. It is worth noting that some countries do use a national company
   registry which ensures uniqueness directly.  Denmark is one such
   country (though the uniqueness checking is probably limited to exact
   matches).

6. It should still be possible for local branches and franchise holders
   to get EV certificates, if the bigger company approves as part of the
   vetting process.  For example Google Canada should be able to get a
   3rd party EV certificate if the international headquarters of Alphabet
   approves it.

Formulating this into formal rules, and selecting appropriate per-country and 
global lists of name-dominating organizations will both take some time and 
should be done in parallel.


Enjoy

Jakob
--
Jakob Bohm, CIO, Partner, WiseMo A/S.  
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Transformervej 29, 2860 Søborg, Denmark.  Direct +45 31 13 16 10 This public 
discussion message is non-binding and may contain errors.
WiseMo - Remote Service Management for PCs, Phones and Embedded 
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