Regarding KPMG: It appears to be a Switzerland-based group of
auditors.  http://www.kpmg.com/Global/ContactUs/Pages/InternationalHotline.aspx
has contact information for the Group which relates to accounting,
auditing, or other irregularities.

For US reporting, http://www.kpmgethics.com/ is where it directs.

-Kyle H

On Mon, Dec 29, 2008 at 10:28 AM, Ben Bucksch
<ben.bucksch.n...@beonex.com> wrote:
> Background: CertStar issued certificates without verification whatsoever.
> The faulty certs were signed with the PositiveSSL certificate, which is
> chained to the UserTRUST root cert that Mozilla ships. The UserTRUST cert is
> owned and operated by Comodo.
>
> Our policy mandates that CAs have a valid audit to prove that they do
> diligent verifications.
>
> Thanks to Frank Hacker for posting the link to the what he thinks is the
> latest audit of Comodo regarding normal certs (non-EV):
> <https://cert.webtrust.org/SealFile?seal=798&file=pdf>
>
> This audit is issued by KPMG. It merely certifies that Comodo follows its
> *own* self-defined guidelines. (I think that is not sufficient, but EV fixes
> that to some extend.)
>
> The Comodo guidelines and processes, as certified by the above document, are
> at
> <http://www.comodo.com/repository/09_22_2006_Certification_Practice_Statement_v.3.0.pdf>
>
> Section 1.10 shows that Comodo indeed uses Registration Authorities to do
> all verification, see my previous post "Re: CAs and external entities
> (resellers, outsourcing)"
> <http://groups.google.com/group/mozilla.dev.tech.crypto/browse_thread/thread/43bdc908878eb4b4?q=#fd8d123e7881c729>
>
> Most interesting to the current case, where the PositiveSSL certificate
> proved most problematic and which was already contemplated to yank, is
> section 2.4.1 a):
>
>> a) PositiveSSL Certificate
>> PositiveSSL Certificates are low assurance level Secure Server
>> Certificates from Comodo ideal for mail servers and server to server
>> communications. They are not intended to be used for websites conducting
>> e-commerce or transferring data of value.
>> ...
>> Due to the increased validation speed and the nature of how Comodo intends
>> PositiveSSL certificates to be used, the certificates carry no warranty.
>>
>> PositiveSSL certificates are available from the following channels: Comodo
>> Website, Reseller Network, Web Host Netowrk, PoweredSSL Network, and EPKI
>> Manager.
>
> "not intended for ... e-commerce. ... the certificates carry no warranty"
>
> It's clear that these certificates were never defined to be used in
> browsers, and therefore never should have been shipped with browsers. In any
> case, whatever Comodo's intends or actions, PositiveSSL does *not* carry a
> valid audit for inclusion in browsers.
>
> I think the fault is clearly on Codomo's side, as the PositiveSSL cert is
> not included directly in Mozilla's root certs, but signed by Comodo's
> UserTRUST cert, which is included in Mozilla browsers. Therefore, Comodo is
> responsible for having allowed certificates for e-commerce which were
> specifically excluded for e-commerce and which explicitly "carry no
> warranty".
>
> The audit was also faulty, because the signature of PositiveSSL by the
> UserTRUST root and its inclusion in browsers is mentioned in the same
> document in section 1.8.3. In other words, the document contradicts itself
> and should never have been approved by the auditor (KPMG) as-is.
>
> Suggested actions:
> * Add PositiveSSL cert to cert root with trust bit disabled, i.e. disabling
> it, assuming that works. IMHO, the current Firefox UI dialog is fine. It's
> as if PositiveSSL were never added to the cert store, which is what should
> have been the case all the time.
> * Reconsider inclusion of Comodo certificates in the Mozilla root, as Comodo
> has violated its own definitions.
> * Require Comodo to remove the concept of Registration Authorities and do
> all verifications themselves. At minimum, Comodo must do a Domain Validation
> themselves.
> * For KPMG having done a faulty audit, I don't know what the possible
> actions are, legal or reputation nature.
>
>
> _______________________________________________
> dev-tech-crypto mailing list
> dev-tech-crypto@lists.mozilla.org
> https://lists.mozilla.org/listinfo/dev-tech-crypto
>
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