On Monday, April 23, 2018 at 3:34:38 PM UTC-4, Wayne Thayer wrote:
> Section 9.2.1 of the EVGLs is stricter, only permitting abbreviations. If
> this were an EV cert I would argue that it was misissued.
> 
> On Mon, Apr 23, 2018 at 12:13 PM, Ryan Sleevi via dev-security-policy <
> dev-security-policy@lists.mozilla.org> wrote:
> 
> > On Mon, Apr 23, 2018 at 1:11 PM, Henri Sivonen via dev-security-policy <
> > dev-security-policy@lists.mozilla.org> wrote:
> >
> > > First, it seems to me that the Baseline Requirements allow
> > > transformations of the organization's name only if the CA documents
> > > such transformations. I am unable to find such documentation in
> > > DigiCert's CP and CPS documents. Am I missing something?
> > >
> >
> > At present, these are not required to be in the public documentation.
> > Merely, the requirement is that the CA "documents" - i.e. it is presently
> > acceptable to only include this documentation in information provided to
> > the auditors.
> >
> >
> > > Second, while verifying that the applicant indeed represents a
> > > specific real organization is a difficult problem, in the case where
> > > the country that the certificate designates operates an
> > > online-queryable database of registered businesses, associations,
> > > etc., it should be entirely feasible to eliminate the failure mode
> > > where the certificate's organization field is (absent documented
> > > transformations permitted under the Baseline Requirements) not
> > > canonically equivalent (in the Unicode sense) to the name of any
> > > organization registered in the country that the certificates
> > > designates. That (inferring from the certificate for
> > > www.alandsbanken.fi) there isn't technical process that would by
> > > necessity remove diacritical marks from the organization field and
> > > that the certificate for www.saastopankki.fi has them removed is
> > > strongly suggestive that DigiCert's process for validating
> > > Finland-based organization does not include as a mandatory part either
> > > the retrieval of the organization's name via an online API to the
> > > business registry or a human CA representative copying and pasting the
> > > organization's name from a browser view to the business registry.
> > >
> >
> > The Baseline Requirements do not dictate the datasource used in various
> > jurisdictions. Thus even when there is a canonical source through
> > legislation, the BRs do not require its use.
> >
> >
> > >  I wonder: When a given country
> >
> > has an online-queryable business registry, why isn't it either
> > > recommended or required to import names digitally from the business
> > > registry into certificates? Such practice would eliminate the failure
> > > mode of the certificate designating a name that doesn't match any
> > > entry in the business registry for such country. (Obviously, if it was
> > > _required_, the BRs would need to include a list of countries whose
> > > business registry is considered online-queryable in the sense that the
> > > requirement would apply, but unwillingness to maintain such a list
> > > does not explain why it isn't even recommended.)
> > >
> >
> > "Recommended" is pointless. Required is the only thing that makes sense,
> > and the complexities and overhead involved precisely explain why it isn't
> > required.
> > _______________________________________________
> > dev-security-policy mailing list
> > dev-security-policy@lists.mozilla.org
> > https://lists.mozilla.org/listinfo/dev-security-policy
> >

Appendix D of the EV Guidelines 
(https://cabforum.org/wp-content/uploads/CA-Browser-Forum-EV-Guidelines-v1.6.8.pdf)
 describes additional allowances for the Organization Name to be written with 
Latin letters. Section 1.2 of Appendix D is especially relevant here, as it 
appears that the organization names that are mentioned by Henri are 
transliterations of the original Finnish names.
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