Hi,

I think it is quite clear that e-Tugra has demonstrated that they are
not able to handle the responsibilities that come with being a
publicly trusted CA.
Additionally, as there would be no user impact as a result of
distrusting e-Tugra it seems to me that removal is the obvious choice.

-Cynthia

On Mon, Jun 5, 2023 at 7:36 PM Ben Wilson <bwil...@mozilla.com> wrote:
>
> Dear Mozilla Community,
>
> This email relates to the e-Tugra breach that was described in a blog post by 
> Ian Carroll and subsequent discussions here and in CCADB Public and Bugzilla. 
> We are grateful for the involvement of various individuals and organizations, 
> particularly Ian Carroll and Google Chrome, who have contributed their 
> expertise and resources while investigating this breach.
>
> We are now opening this discussion to help determine whether the e-Tugra root 
> certificates should be removed from Mozilla’s Root Store. We will greatly 
> appreciate your thoughtful and constructive feedback on this.
>
> Below are some questions for us to consider in this discussion.
>
> What were the main concerns raised by the community during the discussions 
> that took place in Bugzilla Bug #1801345? (this is not a complete list; 
> details may be found in the bug)
>
> Mr. Carroll indicated that he was able to log in and conduct reconnaissance 
> on e-Tugra’s email and document storage systems, gaining access to customer 
> PII.
>
> There were security holes in e-Tugra’s internal systems that existed because 
> access to internal resources was not adequately secured, namely, default 
> passwords on some administrative tools had not been changed, and internal 
> applications were left exposed without appropriate access control mechanisms.
>
> Statements by e-Tugra about the lack of impact were refuted by the fact that 
> the contents of 568,647 emails and 251,230 documents were accessible, 
> including access to password resets and confirmation codes.
>
> e-Tugra indicated in their incident report that they would conduct additional 
> vulnerability scanning and penetration testing before the end of 2022. They 
> also said that they were preparing a detailed report of the problem and would 
> provide more information.
>
> None of this information was provided until April 2023.
>
> The explanations in subsequent reports and executive summaries of penetration 
> testing did not fully answer the questions that had been asked.
>
> A detailed analysis was not provided, no root cause analysis was ever 
> provided, and the output of the penetration test (i.e., reports) did not 
> offer any detail addressing concerns raised in the incident report. (The 
> penetration test reports only provided brief statements and insufficient 
> information to evaluate the security posture of e-Tugra.)
>
> Does the benefit of having e-Tugra root certificates in Mozilla’s Root Store 
> outweigh the risk?
>
> The breach that was found by Mr. Carroll may indicate that the CA operators 
> may not have the level of expertise necessary to securely operate a publicly 
> trusted CA.
>
> The slow response by e-Tugra may also be an indication that they may not be 
> prepared to respond to concerns and incidents in the required timely manner.
>
> How would the distrust of e-Tugra affect our users?
>
> Since the e-Tugra root certificates are not currently being used, there would 
> not be any impact to our users.
>
> e-Tugra is not currently issuing TLS certificates within their own CA 
> hierarchy. Instead, e-Tugra has been acting as a reseller for the SSL.com CA, 
> which means that all domain validation and certificate issuance is being 
> performed by systems operated by the SSL.com CA, so SSL.com is the party 
> currently responsible for issuance/security procedures.
>
> If distrusted, could e-Tugra continue to be a reseller for a publicly trusted 
> CA?
>
> Yes, as long as the publicly trusted CA ensures correct 
> systems/procedures/processes in relation to reselling certificates within 
> their CA hierarchy.
>
> If distrusted, could e-Tugra re-apply to have their root certificates 
> included in Mozilla’s Root Store?
>
> If we decide to remove the current e-Tugra roots, then in order for e-Tugra 
> to apply to have their root certificates included in Mozilla’s Root Store 
> again, they would need to:
>
> Implement an infrastructure that is properly secure and tested, with 
> sufficiently detailed artifacts to show that the systems are properly 
> configured.
>
> Then create new root certificates within the properly secured infrastructure.
>
> Then re-apply for inclusion in Mozilla’s root store.
>
> As always, the onus is on the CA operator to demonstrate their ability to 
> operate a publicly trusted CA hierarchy.
>
> How are other root stores addressing this issue?
>
> Google Chrome announced that they will remove the “E-Tugra Global Root CA ECC 
> v3” and “E-Tugra Global Root CA RSA v3” roots from the Chrome Root Store.
>
> Apple stated that the e-Tugra roots are not in the Apple Root Store.
>
> Given that SSL.com has been the operator of the issuing CA, e-Tugra’s breach 
> has not necessitated that we take any urgent safeguarding actions. However, 
> e-Tugra’s problems give us reason to question whether the e-Tugra CA should 
> continue to be in our root store, based on the level of expertise required to 
> securely operate a publicly trusted CA infrastructure. Additionally, 
> e-Tugra’s inadequate responses to the problem and resulting requests for 
> information, give us reason to question e-Tugra’s commitment to the important 
> role that CAs have in ensuring security on the web.
>
> We appreciate your engagement and dedication, and we kindly request that all 
> participants adhere to our Community Participation Guidelines, fostering a 
> respectful and constructive environment for dialogue.
>
> Thanks,
>
> Ben and Kathleen
>
> PS: For your reference, below are excerpts from 
> https://wiki.mozilla.org/CA/Maintenance_and_Enforcement
>
> CA behavior
>
> Did the CA notice the error and take appropriate action in a timely manner?
>
> Was the threat or error properly contained?
>
> Did the CA notice the hacker intrusion and take appropriate action in a 
> timely manner?
>
> Were the CA's defense mechanisms current and sufficient?
>
> Was the intrusion appropriately contained?
>
> Was the CA's behavior reckless?
>
> Did the CA try to cover up the mistake/threat rather than follow Mozilla's 
> Security Policy?
>
> In incident response, Mozilla is looking for the following factors:
>
> A CA takes responsibility for their own actions.
>
> Incidents are taken with an appropriate level of seriousness.
>
> Incidents are handled with urgency.
>
> Root cause analysis is performed.
>
> Any questions posed, by anyone, are answered quickly and in detail.
>
> A reasonably-detailed incident report is made public on what happened, why, 
> and how things have changed to make sure it won’t happen again
>
>
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