On Friday, February 10, 2023 at 12:29:54 PM UTC-8 ku...@seifried.org wrote:
FYI at least one person is being blocked from posting to the list properly 
for reasons unknown.

On Fri, Feb 10, 2023 at 11:04 AM Steve Keller <kellerst...@proton.me> wrote:
Unfortunately it won't let me post. I don't see why it would be harmful to 
ask the community to double-check my work to make sure that I'm not 
misunderstanding the new requirements?
As far as I can tell, there's a number of CAs currently rooted that are 
already engaging in Concerning Behavior, but maybe I'm misunderstanding 
something or Mozilla doesn't like that question?

Steve will need to:
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Only members can post to this group, otherwise this group would receive a 
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What happens to the CAs engaging in "Concerning Behavior" that *currently* 
have their root certificates in Mozilla's root store?

Concerning Behavior: "The following situations are concerning *and in 
aggregate*..."
So concern would be raised when a collection (several) of the main bullet 
points happen.

 

Mozilla states:
>  If the CA operator currently has root certificates in Mozilla's root 
store, then Mozilla *may* remove those root certificates or set them to be 
distrusted after a specified date.

How much Concerning Behavior would a CA need to engage in before their root 
certificates were removed? 

When several of the concerning behaviors exist, then we need to look more 
closely at the CA and do a risk versus value assessment of the CA.
 

Just a quick review of all the currently included CAs in Mozilla's root 
store and it seems that these CAs are already engaging in Concerning 
Behavior according to the recently announced considerations:

1. Agence Nationale de Certification Electronique - Corruption Perceptions 
Index Score less than 50 (score = 40)
2. certSIGN - Corruption Perceptions Index Score less than 50 (score = 46)
3. China Financial Certification Authority (CFCA) - Internet Freedom Score 
less than 50 (score = 10), Corruption Perceptions Index Score less than 50 
(score = 45)
4. E-Tugra - Internet Freedom Score less than 50 (score = 32), Corruption 
Perceptions Index Score less than 50 (score = 36)
5. eMudhra Technologies Limited - Corruption Perceptions Index Score less 
than 50 (score = 40)
6. Global Digital Cybersecurity Authority Co., Ltd. (Formerly Guang Dong 
Certificate Authority (GDCA)) - Internet Freedom Score less than 50 (score 
= 10), Corruption Perceptions Index Score less than 50 (score = 45)
7. Government of Hong Kong (SAR), Hongkong Post, Certizen aka "Hongkong 
Post" - Internet Freedom Score less than 50, Corruption Perceptions Index 
Score less than 50
8. Government of Turkey, Kamu Sertifikasyon Merkezi (Kamu SM) aka "TUBITAK" 
- Internet Freedom Score less than 50 (score = 10), Corruption Perceptions 
Index Score less than 50 (score = 45), CA's auditor has not audited other 
CAs whose root certificates are already included in Mozilla’s Root store
9. iTrusChina Co., Ltd. - Internet Freedom Score less than 50 (score = 10), 
Corruption Perceptions Index Score less than 50 (score = 45)
10. Microsec Ltd. - Corruption Perceptions Index Score less than 50 (score 
= 42), CA's auditor has not audited other CAs whose root certificates are 
already included in Mozilla’s Root store
11. Netlock - Corruption Perceptions Index Score less than 50 (score = 42), 
CA's auditor has not audited other CAs whose root certificates are already 
included in Mozilla’s Root store
12. Shanghai Electronic Certification Authority Co., Ltd. aka "UniTrust" - 
Internet Freedom Score less than 50 (score = 10), Corruption Perceptions 
Index Score less than 50 (score = 45)

I am interested in feedback on using the Internet Freedom Score and 
Corruption Perceptions Index when considering CAs...
Is this check useful? 
How much should it impact our decisions? 
Is it only useful when the CA is also closely aligned with a government 
organization?
 
13. Actalis - CA's auditor has not audited other CAs whose root 
certificates are already included in Mozilla’s Root store
14. Atos Trustcenter - CA's auditor has not audited other CAs whose root 
certificates are already included in Mozilla’s Root store
15. Buypass - CA's auditor has not audited other CAs whose root 
certificates are already included in Mozilla’s Root store
16. Chunghwa Telecom - CA's auditor has not audited other CAs whose root 
certificates are already included in Mozilla’s Root store
17. Disig, a.s. - CA's auditor has not audited other CAs whose root 
certificates are already included in Mozilla’s Root store
18. e-commerce monitoring GmbH - CA's auditor has not audited other CAs 
whose root certificates are already included in Mozilla’s Root store
19. HARICA - CA's auditor has not audited other CAs whose root certificates 
are already included in Mozilla’s Root store
20. SwissSign AG - CA's auditor has not audited other CAs whose root 
certificates are already included in Mozilla’s Root store


I think this concern about auditor only auditing one CA means that we might 
need to do more due diligence in regards to verifying that auditor's 
qualifications. Especially when any other items in the Concerning Behaviors 
list apply to the CA.

These are all good questions, and I am very interested to hear feedback 
from CAs who are currently in Mozilla's program and may be impacted by this 
list.

Thanks,
Kathleen

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