On Wed, Mar 1, 2023 at 7:54 PM Ryan Hurst <ryan.hu...@gmail.com> wrote:

> Kathleen/Ben,
>
> I have been thinking about the new Concerning Behavior
> <https://wiki.mozilla.org/CA/Root_Inclusion_Considerations#Concerning_Behavior>
> language being proposed for the Mozilla Root Store Policy and I wanted to
> share my thoughts relative to this policy and censorship.
>
> When discussing CA inclusions, a topic that commonly comes up is the risk
> of the applicant violating the privacy of Mozilla's users by enabling
> MiTMs. However, there are other concerning behaviors that are not often
> discussed, such as the use of certificate issuance and denial as tools for
> censorship, community exclusion, and enabling misinformation.
>
> These behaviors can have far-reaching impacts on Mozilla's customers and
> are not aligned with the objectives of Mozilla as I understand them.
>
> In 2015, Let's Encrypt wrote a blog post on why CAs make poor content
> watchdogs <https://letsencrypt.org/2015/10/29/phishing-and-malware.html>.
> I believe the points raised in this post are still relevant today, and it
> may make sense to add some language to the Concerning Behavior section of
> the Root Store Policy to make Mozilla's position on these topics clear.
>
> For example, we could consider adding the following bullets to the warning
> signs section:
>
>
>    - CA operators who attempt to act as a content watchdog beyond what is
>    required by other root programs or governing legal jurisdictions should be
>    seen as a warning sign of behavior that could lead to censorship and be
>    incompatible with Mozilas objectives for the root program and its
>    principles overall.
>    - CA operators who attempt to act as content watchdogs by denying the
>    issuance of Internationalized Domain Names (IDNs) for reasons beyond legal
>    jurisdictional requirements, what is required by other root programs, or
>    the technical limitations of their certificate issuance systems should be
>    seen as a warning sign of behavior that could lead to censorship which
>    would be incompatible with Mozilas objectives for the root program and its
>    principles overall as it limits access to the internet for non-English
>    speaking users and may be used as a tool for political or cultural control.
>
>
Silly question but why isn't there more usage of certificate restrictions,
e.g. if a CA from a country has some concerns (like SERPRO) it would be
much less damaging if they were more limited (e.g. to *.br).


>
> While this is probably not the exact right wording something similar to
> this has the potential to make it clear what Mozilla's position on these
> topics is and as a result, strongly discourage CAs from leveraging their
> position to support these activities.
>
> Best regards,
>
> Ryan Hurst
>
>
>
> On Wed, Mar 1, 2023 at 4:46 PM Kathleen Wilson <kwil...@mozilla.com>
> wrote:
>
>> I continue to receive feedback/concerns about the auditor bullet point in
>> the "Concerning Behavior
>> <https://wiki.mozilla.org/CA/Root_Inclusion_Considerations#Concerning_Behavior>"
>> section, so I am attempting to resolve those concerns with the following
>> version of that bullet point:
>>
>>
>>    - The CA is using an auditing organization (ETSI
>>    
>> <https://wiki.mozilla.org/CA/Audit_Statements#Verifying_ETSI_Auditor_Qualifications>,
>>    WebTrust
>>    
>> <https://wiki.mozilla.org/CA/Audit_Statements#Verifying_WebTrust_Auditor_Qualifications>)
>>    that has not audited other publicly trusted CAs whose root certificates 
>> are
>>    included in browser root store programs, and the Auditor
>>    Qualifications
>>    
>> <https://wiki.mozilla.org/CA/Audit_Statements#Providing_Auditor_Qualifications>
>>    indicate that the audit team is inexperienced in auditing CA operations,
>>    public key infrastructure, trust services or similar information systems.
>>       - New auditors are allowed under the condition that the CA ensures
>>       that the Audit Team is lead by third-party specialists or affiliate 
>> audit
>>       firms who are experienced in auditing publicly trusted CAs, and this
>>       information must be provided as part of the Auditor Qualifications.
>>
>>
>> I will appreciate feedback and suggestions on this new text. Does it
>> address your concerns?
>>
>> Also, I am no longer receiving feedback on the rest of the wiki page,
>> https://wiki.mozilla.org/CA/Root_Inclusion_Considerations, so I am
>> assuming that the rest of the page is solid (i.e. ready to remove the
>> "DRAFT" at the top of the page).
>>
>> Thanks,
>> Kathleen
>>
>>
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-- 
Kurt Seifried (He/Him)
k...@seifried.org

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