On Wed, Jul 18, 2018 at 1:56 PM Wayne Thayer <wtha...@mozilla.com> wrote:

> I would like to begin a 3-week public discussion period for InfoCert's
> acquisition of Camerfirma [1] as described in section 8.1 of the Mozilla
> Root Store Policy. I believe that the intent of our policy in this scenario
> is to identify and consider any risks introduced by the acquisition of
> Camerfirma, and not to reevaluate Camerfirma's inclusion as if it were a
> new CA. In that context, I will appreciate everyone's constructive input on
> issues that may affect Mozilla's ongoing trust in InfoCert/Camerfirma. I
> have included some additional information below.
>
> - Wayne
>
> Camerfirma answered the questions that I posed [2] about this acquisition
> as follows:
>
> <snip>

>
> Camerfirma has one open compliance bug [5] requesting full audit
> information for a subordinate CA.
>
> Camerfirma has supplied the audit information for this subordinate CA.

Camerfirma also recently issued two intermediates that were not disclosed
within the required week [8][9].

Camerfirma's 2018 audit statements are overdue - the prior period ended on
> 14-April 2017, and new statements have not yet been supplied to Mozilla.
> Last year's statements are still listed on the Camerfirma website [6].
>
> Camerfirma has supplied their 2018 audit reports:
https://bugzilla.mozilla.org/show_bug.cgi?id=1478933

The WebTrust, BR, and EV reports all contain multiple qualifications. I
would summarize the qualifications as follows:
* Inconsistencies and omissions in CP/CPS documents which I would consider
relatively minor.
* Misissuances. The reports appear to be referring to those documented in
bugs 1357067, 1390977, 1405815, 1431164, and 1443857.
* Misissuance for "wildcard to immediate left of public suffix in SAN" was
also reported. I found [10] but since those are for the .sener brand TLD,
it is possible that Camerfirma issued them in compliance with BR 3.2.2.6.
* Not meeting the BR requirement to revoke within 24 hours, presumably
referencing bug 1390977.
*The revocation time differs between the OCSP service and CRL for a few
certificates, and the OCSP service responds "good" for some certificates
revoked according to the CRL.
* Failure to begin investigations of problem reports within 24 hours.
* Failure to self-audit at least 3% of issued certificates each quarter.

<snip>

[1]
> https://infocert.digital/infocert-underwrites-a-capital-increase-to-acquire-51-of-the-spanish-ac-camerfirma/
>
[2] https://bugzilla.mozilla.org/show_bug.cgi?id=1463597
>
[3] https://bugzilla.mozilla.org/show_bug.cgi?id=986854
>
[4]
> https://groups.google.com/d/msg/mozilla.dev.security.policy/skev4gp_bY4/snIuP2JLAgAJ
>
[5] https://bugzilla.mozilla.org/show_bug.cgi?id=1455147
>
[6] https://www.camerfirma.com/camerfirma/acreditaciones/
>
[7]
> http://docs.camerfirma.com/publico/DocumentosWeb/politicas/CPS_3.3.1_EN.pdf
>
[8]
> https://crt.sh/?sha256=06a57d1cd5879fba2135610dd8d725cc268d2a6de8a463d424c4b9da89848696&opt=mozilladisclosure

[9]
> https://crt.sh/?sha256=1defd59846cc2049ba1f1a74d3a8329d1357a2d47c1e1b0c15c27a8c60295455&opt=mozilladisclosure
>
[10] https://crt.sh/?cablint=319&iCAID=1778&minNotBefore=2017-01-01
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