A publicly trusted CA is expected to demonstrate technical competence
around validation, issuance, and security of their infrastructure. When
non-compliant issuance occurs the community should expect any well operated
CA to rapidly detect, remediate the issue, and perform a root cause
analysis focused on how to prevent that entire class of problems in the
future.

Issues E and F argue that Certinomis is technically incapable of operating
a certificate authority in compliance with the expectations we have for
such trust. In issue E we see non-compliance with a BR requirement for OCSP
responder behavior for over 4 years. Incidentally, the requirement in
question was explicitly added to the BRs in response to a major CA security
incident. Issue F lists a pattern of repeated misissuance that suggests
repeated human typos with no systemic improvement.

Similarly, issues A through D show an apparent disinterest in policy,
compliance, and communications. Issuing a cross-certification for a CA that
was in the middle of major sanctions, having repeated audit gaps, ignoring
Mozilla root store policies for years, and generally declining to engage
with the community to help resolve these issues is not the action of an
organization that understands the responsibility of being a CA.

I believe the issues highlighted by Mozilla represent, in aggregate,
extremely strong evidence that Certinomis is unfit to operate a trusted
certificate authority.

-Paul

On April 17, 2019 at 2:44:44 AM, Wayne Thayer via dev-security-policy (
dev-security-policy@lists.mozilla.org) wrote:

Mozilla has decided that there is sufficient concern [1] about the
activities and operations of the CA Certinomis to collect together a list
of issues. That list can be found here:
https://wiki.mozilla.org/CA/Certinomis_Issues

Note that this list may expand or contract over time as issues are
investigated further, with information either from our or our community's
investigations or from Certinomis.

We expect Certinomis to engage in a public discussion of these issues and
give their comments and viewpoint. We also hope that our community will
make comments, and perhaps provide additional information based on their
own investigations.

When commenting on these issues, please clearly state which issue you are
addressing on each occasion. The issues have been given identifying letters
and numbers to help with this.

At the end of a public discussion period between Mozilla, our community,
and Certinomis, which we hope will be no longer than a couple of weeks,
Mozilla will move to make a decision about how to respond to these
concerns, based on the picture which has then emerged.

- Wayne

[1] https://wiki.mozilla.org/CA/Maintenance_and_Enforcement#Recurring_Issues
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