Re-sending -----Original Message----- From: Ben Wilson Sent: Wednesday, August 15, 2018 8:34 AM To: 'r...@sleevi.com' <r...@sleevi.com>; Wayne Thayer <wtha...@mozilla.com> Cc: mozilla-dev-security-policy <mozilla-dev-security-pol...@lists.mozilla.org> Subject: RE: Misissuance and BR Audit Statements
Thanks, Ryan and Wayne, Going forward we'll work to improve our management letter disclosures to include reported mis-issuances during the audit period. Sincerely yours, Ben -----Original Message----- From: dev-security-policy <dev-security-policy-boun...@lists.mozilla.org> On Behalf Of Ryan Sleevi via dev-security-policy Sent: Monday, August 13, 2018 3:57 PM To: Wayne Thayer <wtha...@mozilla.com> Cc: mozilla-dev-security-policy <mozilla-dev-security-pol...@lists.mozilla.org> Subject: Re: Misissuance and BR Audit Statements Wayne, Thanks for raising this. I definitely find it surprising to see nothing noted on Comodo's report, as you call out. As another datapoint, consider this recent audit that is reported to be from DigiCert, by way of Amazon Trust Services' providing the audits for their externally operated sub-CAs in [A]. The scope of the WebTrust BR audit report in [B] contains in its scope "DigiCert ECC Extended Validation Server CA" of hash FDC8986CFAC4F35F1ACD517E0F61B879882AE076E2BA80B77BD3F0FE5CEF8862, which [C]. During that time, this CA issued a cert [D] as part of their improperly configured Onion issuance in [E], which was remediated in early March, within the audit period for [B]. I couldn't find it listed in the report. Looking over that period, there were two other (resolved) DigiCert issues, [F] and [G], which affect the CAs listed in scope of [B]. I was a bit surprised by this, as like you, I would have expected these to be called out by both Management's Assertion and the auditor. http://www.webtrust.org/practitioner-qualifications/docs/item85808.pdf provides some of the illustrative reports, but it appears to only provide templates for management on the result of obtaining a qualified report. [A] https://bugzilla.mozilla.org/show_bug.cgi?id=1482930 [B] https://bug1482930.bmoattachments.org/attachment.cgi?id=8999669 [C] https://crt.sh/?id=23432431 [D] https://crt.sh/?id=351449246 [E] https://bugzilla.mozilla.org/show_bug.cgi?id=1447192 [F] https://bugzilla.mozilla.org/show_bug.cgi?id=1465600 [G] https://bugzilla.mozilla.org/show_bug.cgi?id=1398269#c29 On Tue, Aug 7, 2018 at 1:32 PM, Wayne Thayer via dev-security-policy < dev-security-policy@lists.mozilla.org> wrote: > Given the number of incidents documented over the past year [1][2] for > misissuance and other nonconformities, I would expect many of the 2018 > period-of-time WebTrust audit statements being submitted by CAs to > include qualifications describing these matters. In some cases, that > is exactly what we’re seeing. One of many positive examples is > Deloitte’s report on Entrust [3] that includes 2 of the 3 issues documented > in Bugzilla. > > Unfortunately, we are also beginning to see some reports that don’t > meet my expectations. I was surprised by GlobalSign’s clean reports > [4] from Ernst & Young, but after examining their incident bugs, it > appears that the only documented misissuance that occurred during > their audit period was placing metadata in Subject fields. I can > understand how this could be regarded as a minor nonconformity rather > than a qualification, but I would have liked to at least see the issue noted > in the reports. > > Ernst & Young’s clean reports on Comodo CA [5] is the example that > prompted this message. We have documented the following issues that > occurred during Comodo’s last audit period: > * Misissuance using "CNAME CSR Hash 2" method of domain control > validation (bug 1461391) > * Assorted misissuances and failure to respond to an incident report > within > 24 hours (bug 1390981) > * CAA misissuance (bugs 1398545,1410834, 1420858, and 1423624 ) > > I would like to know if Comodo reported these issues to EY. I asked > Comodo this question four weeks ago [6] but have not received a response. > > I will acknowledge that ETSI audits are an even bigger problem > (Actalis and SwissSign are recent examples [7][8][9]). Due to the > structure of those audits, there is no provision for issuing a > qualified report. WebTrust audits are theoretically much better in > this regard, but only if auditors actually find and report on issues! > I don’t think it is productive to expect auditors to search Bugzilla > for a list of issues to copy into their reports, but I do think it is > reasonable to question the competence and trustworthiness of the > auditor when so many known issues are absent from their report. > > In this particular example, unless additional facts are presented, I > plan to notate the auditor’s record in CCADB with this issue. We have > documented a number of other issues with Ernst & Young - including the > disqualification of their Hong Kong branch - but this is the first > issue I’m aware of from their New York office. We also recently > received a very “good” qualified audit report from EY’s Denmark office on > Telia [10]. > > - Wayne > > [1] https://wiki.mozilla.org/CA/Incident_Dashboard > [2] https://wiki.mozilla.org/CA/Closed_Incidents > [3] > https://www.entrustdatacard.com/-/media/documentation/ > licensingandagreements/entrust_baselinerequirements_2018.pdf?la=en&has > h= > BC08BAF5AE81B2EE66A2146EE7710FB2F4F33BA6 > [4] https://bugzilla.mozilla.org/show_bug.cgi?id=1388488 > [5] https://bugzilla.mozilla.org/show_bug.cgi?id=1472993 > [6] https://bugzilla.mozilla.org/show_bug.cgi?id=1472993#c5 > [7] https://www.actalis.it/documenti-en/actalisca_audit_ > statement_2018.aspx > [8] > https://it-tuv.com/wp-content/uploads/2018/07/AA2018070301_ > Audit_Attestation_TA_CERT__SwissSign_Platinum_G2_signed.pdf > [9] > https://it-tuv.com/wp-content/uploads/2018/07/AA2018070303_ > Audit_Attestation_TA_CERT__SwissSign_Silver_G2_signed.pdf > [10] https://bugzilla.mozilla.org/show_bug.cgi?id=1475115 > _______________________________________________ > dev-security-policy mailing list > dev-security-policy@lists.mozilla.org > https://lists.mozilla.org/listinfo/dev-security-policy > _______________________________________________ dev-security-policy mailing list dev-security-policy@lists.mozilla.org https://lists.mozilla.org/listinfo/dev-security-policy
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