Visa has filed a bug [1] requesting removal of the eCommerce root from the
Mozilla root store. Visa has also responded to the information requested in
the qualified audits bug [2], but it's unclear if or when they will respond
to the issues list presented in this thread. Two weeks have passed since I
posted the issues list, and I see no reason to delay the complete distrust
of Visa's eCommerce root. That is likely to happen in Firefox 64 [3] via
removal of the root from NSS version 3.40 . Visa is still welcome to
respond to the issues list, but I think the removal of Visa's only included
root, and thus Visa, from the Mozilla CA Certificate Program implies that
this discussion has reached a conclusion.

- Wayne

[1] https://bugzilla.mozilla.org/show_bug.cgi?id=1493822
[2] https://bugzilla.mozilla.org/show_bug.cgi?id=1485851#c2
[3] https://wiki.mozilla.org/Release_Management/Calendar

On Sun, Sep 23, 2018 at 1:15 PM Ryan Sleevi <r...@sleevi.com> wrote:

>
>
> On Thu, Sep 13, 2018 at 3:26 PM Wayne Thayer via dev-security-policy <
> dev-security-policy@lists.mozilla.org> wrote:
>
>> Visa recently delivered new qualified audit reports for their eCommerce
>> Root that is included in the Mozilla program. I opened a bug [1] and
>> requested an incident report from Visa.
>>
>> Visa was also the subject of a thread [2] earlier this year in which I
>> stated that I would look into some of the concerns that were raised. I've
>> done that and have compiled the following issues list:
>>
>> https://wiki.mozilla.org/CA:Visa_Issues
>>
>> While I have attempted to make this list as complete, accurate, and
>> factual
>> as possible, it may be updated as more information is received from Visa
>> and the community.
>>
>> I would like to request that a representative from Visa engage in this
>> discussion and provide responses to these issues.
>>
>> - Wayne
>>
>> [1] https://bugzilla.mozilla.org/show_bug.cgi?id=1485851
>> [2]
>>
>> https://groups.google.com/d/msg/mozilla.dev.security.policy/NNV3zvX43vE/ns8UUwp8BgAJ
>
>
> I've not seen Visa engage in this discussion. The silence is rather
> deafening, and arguably unacceptably so.
>
> With respect to the Qualified Audit, Visa's response as to the substance
> of the issue is particularly unsettling.
> https://bugzilla.mozilla.org/show_bug.cgi?id=1485851#c3 demonstrates that
> they've not actually remediated the qualification, that they've further
> failed to meet the BRs requirements on revocations by any reasonable
> perspective, and they don't even have a plan yet to remedy this issue.
>
> Examining the bug itself is fairly disturbing, and the responses likely
> reveal further BR violations. For example, the inability to obtain evidence
> of domain validation information reveals that there are further issues with
> 2-7.3 - namely, maintaining those logs for 7 years. The response to 2-7.3
> suggests that there are likely more endemic issues around the issuance.
>
> Given the past issues, the recently identified issues (that appear to have
> been longstanding), and the new issues that Visa's PKI Policy team is
> actively engaging in, I believe it would be appropriate and necessary to
> consider removing trust in this CA.
>
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