Re: StartCom inclusion request: next steps

[Gervase Markham via dev-security-policy]

Dear Inigo,

On 14/09/17 09:49, Gervase Markham wrote:
> The Mozilla CA Certificates team has been considering what the
> appropriate next steps are for the inclusion request from the CA
> "StartCom".[0] As readers will know, this CA has previously been removed
> from trust[1], and so a re-application obviously involves particular
> scrutiny. In addition, several questions have been raised about the way
> in which the new StartCom PKI has been operated technically[2]. This is
> a proposal for the way forward, on which comments are invited.

A month ago we posted the above re: StartCom, in what was officially a
request for comments. The ensuing discussion did not lead us to conclude
that anything we were asking for was inappropriate. So we want to
formally confirm that it is indeed Mozilla's requirement that StartCom
begin again with a new-new hierarchy and do the other things outlined in
the original post before we will further consider a root inclusion
request from StartCom.

Gerv
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Re: FW: StartCom inclusion request: next steps

[userwithuid via dev-security-policy]

On Tue, Sep 19, 2017 at 3:09 PM, Nick Lamb via dev-security-policy
 wrote:
> I have no doubt that this was obvious to people who have worked for a public 
> CA, but it wasn't obvious to me, so thank you for answering. I think these 
> answers give us good reason to be confident that a cross-signed certificate 
> in this situation would not be available to either end subscribers or 
> StartCom unless/ until the CA which cross-signed it wanted that to happen.
>
> It might still make sense for Mozilla to clarify that this isn't a good idea, 
> or even outright forbid it anyway, but I agree with your perspective that 
> this seemed permissible under the rules as you understood them and wasn't 
> obviously unreasonable.

I'm pretty sure it's already forbidden, since policy version 2.5
anyway (has effective date after the Certinomis shenanigans though):

"The CA with a certificate included in Mozilla’s root program MUST
disclose this information within a week of certificate creation, and
before any such subordinate CA is allowed to issue certificates."

2.5 added the "within a week of certificate creation" [1] . "Creation"
vs "My Safe", "Creation" wins.  :-)

[1] 
https://github.com/mozilla/pkipolicy/commit/b7d1b6c04458114fbe73fa3f146ad401235c2a1b
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Re: FW: StartCom inclusion request: next steps

[Gervase Markham via dev-security-policy]

Hi Inigo,

On 15/09/17 17:30, Inigo Barreira wrote:
> There wasn´t a lack of integrity and monitoring, of course not. All PKI logs 
> were and are signed, it´s just the auditors wanted to add the integrity to 
> other systems which is not so clear that should have this enabled. For 
> example, if you want to archive database information for not managing a big 
> one, the integrity of the logs could be a problem when trying to "move" to an 
> archive system. I had some discussions about the "scope" of the integrity. 
> Regarding the monitoring, well, we monitor many things, in both data centers, 
> 24x7, etc. For this specific issue, it´s true that we didn´t have it 
> automatically but manually, but well, and we implement a solution, but this 
> is not a lack of monitoring. I think the audits are to correct and improve 
> the systems and don´t think any CA at the first time had everything correct. 
> So, for example, I thought this finding was good because made us improve.
> 
>> Repairing them afterwards does not remove the uncertainty.
> 
> Well, then any issue that you could find, even repaired or fixed, does not 
> provide you any security and hence you should not trust anyone. 

Not so. There is particular concern about issues with auditing and
monitoring. For other issues, you can check the logs to see whether a
particular bug was abused. If the auditing or monitoring is broken or
inadequate, you can't tell what happened.

>> I may have made a mistake here. I was under the impression that you had
>> told me that your new hierarchy, cross-signed by Certnomis, had issued
>> 50,000 certificates. Did I misunderstand? If so, my apologies.
> 
> No, or not totally. We have issued those certs but not cross-signed by 
> Certinomis because we didn´t have the cross-signed certificates so, all of 
> them were issued under the new startcom hierarchy

But once the cross-signed cert is publicly available (and it is; it's in
CT, however it got there), all of those certificates become trusted (or
potentially trusted, if the owner reconfigures their webserver to serve
the intermediate, or if Firefox has already encountered it in the
current browsing session).

> This is something I don´t understand. Why do you say the audits I presented 
> don´t meet the BRs? Because of the findings? The auditors indicate those were 
> fixed 

I don't believe there's a formal way for an auditor to bindingly say "by
the way, the problems we found have since been fixed" in an audit
report. But to help me understand: exactly what statement on what page
of your audit report(s) are you referring to here?

> About the remediation steps, well, I answered the bug about it providing all 
> the info and yes, you haven´t answered yet nor to approve nor to deny.

Right. So why are you proceeding?

You might reasonably complain it's taken us a while to respond to that
comment about the steps. Yes, it has. The Mozilla inclusion process is
slow. :-(

>>> In fact, recently, I asked for permission to use the Certinomis cross-signed
>> certificates and have no response. I don´t know if this is an administrative
>> silence which may allow me to use it but until having a clear direction we
>> haven´t used it.
>>
>> Can you remind me how you asked and when?
> 
> It was in an email of sept 4th, titled "StartCom communication" in which at 
> the end of the long email I asked for feedback to use the cross-signed 
> certificates and give additional explanations

I have no record of any email with that title, or any email from you
between 15th August ("Re: Problem Reporting Mechanism") and 11th
September ("Re: Remove old Startcom roots from NSS"). Where did you send it?

Gerv
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Re: FW: StartCom inclusion request: next steps

[Gervase Markham via dev-security-policy]

Hi Franck,

On 18/09/17 15:49, Franck Leroy wrote:
> Our understanding in April was that as long as StartCom is not
> allowed by Certinomis to issue EE certs, the disclosure was not
> mandated immediately.

I think that we need to establish a timeline of the exact events
involved here.

But I would say that it seems to me that Startcom _were_ issuing EE
certs at that time, from the part of their hierarchy that you had
cross-signed. In what way was Certnomis forbidding them from doing so?
My understanding is that your answer to this question is...

> This control that StartCom was not allowed to use our path was
> technical in place by the fact that I was the only one to have the
> intermediate cross signed certificates, stored (retained) in my
> personal safe.

that you had not given Startcom a copy of the cross-sign. However,
leaving aside for the moment the reasonable question about how such an
assertion can be audited, the point is that once the certificate _does_
become public, all of the existing certificates immediately become
publicly trusted. Wouldn't you agree?

Gerv
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Re: FW: StartCom inclusion request: next steps

[Gervase Markham via dev-security-policy]

On 15/09/17 15:35, Inigo Barreira wrote:
> No, those weren´t tests. We allowed the use of curves permitted by the BRs 
> but this issue came up in the mozilla policy (I think Arkadiusz posted) and I 
> also asked about it in the last CABF F2F (I asked Ryan about it) and then, 
> with that outcome and as the browsers didn´t accept them, we revoked and then 
> not allow the issuance. I think the discussion is still active (i.e. the use 
> of P-521).

Unless Mozilla says otherwise (which we do occasionally), you should not
be basing your practice on what we are discussing, or even on draft
versions of the policy, but on the published version - which clearly
prohibits P-521.

Gerv
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Re: FW: StartCom inclusion request: next steps

[Franck Leroy via dev-security-policy]

Le lundi 18 septembre 2017 14:52:27 UTC+2, Ryan Sleevi a écrit :
> On Mon, Sep 18, 2017 at 8:12 AM, Inigo Barreira <>
> wrote:
> Then they misissued a CA certificate and failed to disclose it, and we
> should start an incident report into it.

Hello
In April 2017 the mozilla policy in force (v2.4) stated: 
“The CA with a certificate included in Mozilla’s CA Certificate Program MUST 
disclose this information before any such subordinate CA is allowed to issue 
certificates.”

Our understanding in April was that as long as StartCom is not allowed by 
Certinomis to issue EE certs, the disclosure was not mandated immediately.

This control that StartCom was not allowed to use our path was technical in 
place by the fact that I was the only one to have the intermediate cross signed 
certificates, stored (retained) in my personal safe.

As soon as Certinomis has authorized StartCom to use the path to our root, I 
disclosed the certificates with the audit reports in the CCADB, and send the 
certificates to Inigo.

May be I misunderstood the Mozilla requirements v2.4, and as I already said in 
previous post, I do apologize for it. But it was not my intention not to 
enforce the policy; I personally took care that StartCom could not be able to 
use the path to our root until a full BR audit assessment report was provided.

Regards
Franck Leroy

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Re: FW: StartCom inclusion request: next steps

[Ryan Sleevi via dev-security-policy]

On Mon, Sep 18, 2017 at 8:12 AM, Inigo Barreira 
wrote:
>
> We are not seeking to identify personal blame. We are seeking to
> understand what, if any, improvements have been made to address such
> issues. In reading this thread, I have difficulty finding any discussion
> about the steps that StartCom has proposed to improve its awareness of the
> expectations placed upon it as a potential participant in the Mozilla
> store. Regardless of who bears responsibility for that, the absence of a
> robust process - and, unfortunately, the absence of a deep understanding -
> does mean that the restablishing of trust can present a significant risk to
> the community.
>
>
>
> I think I´ve posted everything we did to improve our systems. I replied to
> every error posted in the crt.sh explaining what happened and what we did
> to fix it for not having the same issue again, but will try to recap here
> again.
>
>
>
> -  Test certificates. We issued test certificates in production
> to test the CT behaviour. After the checking those certs were revoked,
> within minutes. This was due to an incorrect configuration in the EJBCA
> roles that was changed and updated accordingly for not allowing anyone to
> issue certs from the EJBCA directly
>
> -  Use of unallowed curves. We issued certificates with P-521
> which is not allowed by Mozilla. We revoked all those certs and configure
> the system to not allow it. This remediation was put into production on
> mid-july not issuing certs with that curve.
>
> -  RSA parameter not included. We issued one certificate which no
> RSA parameter included. We revoked that certificate and started an
> investigation. The EJBCA system didn´t check the keys, concretely for this
> issue. We developed a solution to check the CSR files properly before
> sending to sign
>
> -  Country code not allowed. We issued one certificate with
> country code ZR for Zaire, which does not exist officially. We revoked the
> cert and checked our internal country code database with the ISO one. We
> made the correspondent changes. The cert was reissued with the right code
> representing the Democratic Republic of Congo.
>
>
>
> Furthermore, we have added x509lint and cablint to our issuance process.
> We have integrated crt.sh tool into our CMS system. We have developed a CSR
> checking tool. We have updated the EJBCA system to the latest patch,
> 6.0.9.5 which also came with a Key (RSA and ECC) validator, and we are also
> willing to integrate the zlint once is getting more stable. We have applied
> all these tools and we are not misissuing certificates.
>

Unfortunately, I am not sure how to more effectively communicate that this
pattern of issues indicates an organization failure in the review of,
application of, and implementation of the Baseline Requirements. Through
both coding practices and issuing practices, security and compliance are
not being responded to as systemic objectives, but rather as 'one offs',
giving the impression of 'whack-a-mole' and ad-hoc response.

For example, the country code failure indicates a more deeper failing - did
you misunderstand the BRs? Were they not reviewed? Was the code simply not
implemented correctly? With the RSA parameters, it similarly indicates a
lack of attention.

I greatly appreciate the use of and deployment of x509lint and cablint, but
those merely offer technical checking that, as an aspiring trusted root CA,
you should have already been implementing - whether your own or using those
available COTS.

The continued approach to issue-and-revoke rather than holistically review
the practices and take every step possible to ensure compliance -
particularly at a CA that was previously distrusted due to non-compliance -
is a particularly egregious oversight that hasn't been responded to.

In every response, it still feels as if you're suggesting these are
one-offs and coding errors, when the concern being raised is how deeply
indicative they are of systemic failures from top to bottom, from policy to
technology, from oversight to implementation. Rather than demonstrate how
beyond reproach StartCom is, it feels like an excessive emphasis is being
put on the ineffective revocation of these certificates, while ignoring the
issues that lead to them being issued in the first place - both from policy
and from code.

It´s not like disagreements, but the example was about a root certificate
> private key in a USB stick, so IMO that example starts with a very
> problematic issue, because it´s about a root private key and in a USB stick
> left in the table, while the issues Startcom did was about end entity
> certificates, and nothing related to private keys and not in the root,
> that´s what I meant with “quality”.
>

I understand what you meant. I'm suggesting the community has a perception
that the issues StartCom is presently being faced with is as egregious and
as serious. I understand you disagree it's as 

Re: StartCom inclusion request: next steps

[James Burton via dev-security-policy]

On Monday, September 18, 2017 at 11:38:57 AM UTC+1, Inigo Barreira wrote:
> > 
> > I want to give you some words from one of the "community side" (this is a
> > personal opinion and may vary from other opinions inside the community).
> > 
> > Trust is not something that you get, it is something that you earn.
> 
> True
> 
> > StartCom was distrusted because of serious issues with their old PKI and now
> > had the chance to restart - there are serious issues again. I don't think 
> > that
> > the "community" wants rogue CAs on its list just because they restarted with
> > new certificates.
> > 
> > - The fact that you were cross-signed by Certnomis before you had valid
> > WebTrust Audits and the permission to issue trusted certificates again and
> > that the only thing which prevented you from using the trust path is a 
> > PUBLIC
> > certificate? Is the only thing that prevents me from entering your 
> > datacenter
> > a sign which tells me not to do so and the fact that you did not tell me 
> > where
> > your datacenter is located?
> > 
> > - Startcom operates/operated multiple CT Log Server itself. There is 
> > absolutely
> > no reason to use trusted certificates for testing purposes if he does have a
> > testing infrastructure. It would be easy for you to add one of your testing
> > roots to your CT Logs and then test your CT behaviour. I don't think that
> > Googles CTs are different from your own ones. Though your certificates might
> > not have been trusted at that time, they would be now and as Gerv said, test
> > certificates are not allowed. If you did not care about compliance at that
> > time, why should you care about it now?
> 
> Those certificates were not trusted at that time and can´t be now because 
> they were revoked within minutes.
> 
> > 
> > - There is a reason why Best Practices are called best practices. Why did 
> > you
> > reuse your key in root and intermediate certificates? 
> > Because there is nomoney for additional HSMs? Because you don't know how to 
> > generate new
> > keys? An explanation would be great.
> 
> A new thread has started about this. It´s not forbidden.
> 
> > 
> > - P-521 are forbidden by Mozilla. Even if there is a discussion to change 
> > this it
> > does not allow you to take that as a permission to test it. The fact that 
> > these
> > certificates were reported as unrevoked at the time of reporting (as far as 
> > I
> > remember) does imply that you do not monitor your certificate issuances for
> > policy compliance at all. What do you do to ensure that all of your 
> > certificates
> > are compliant with all requirements at all times?
> 
> At the time of application, the certificates were revoked and countermeasures 
> set and since then there´s no more issues. We have implemented cablint, 
> crt.sh, ... and some other tools into our issuance process and still trying 
> to improve much more. 
> I´m not trying to excuse we had issues but we corrected them.
> 
> > 
> > - What internal audits have you done to ensure the integrity of your 
> > systems?
> > If something so critically as the permission to issue certificates in EJBCA 
> > is
> > only noticed after you explicitly looked for it, what happens if someone
> > removes all of your security mechanisms? You will find that out too after 
> > you
> > misissued thousands of certificates? Quis custodiet ipsos custodes.
> 
> Despite all the terrible systems we have, etc. we haven´t misissued thousands 
> of certificates, nor hundreds. The issues we had, have been fixed.  Those 
> test certs issued directly from the EJBCA was a mistake, explained many 
> times. I have nothing to add to what I´ve already said. It was not a good 
> decission, not a good practice, and it´s forbidden.
> 
> > 
> > - The incidents with Diginotar should have made clear that secure, well
> > audited and hardened code is absolutely necessary as well as reliable logs.
> > The fact that these flaws where not found by your internal team and only
> > discovered after an external company tested your systems is deeply
> > concerning. What have you done now and what will you do to ensure that
> > your systems won't be abused? How do you make sure that the code your
> > people write in the future is safe and how do you detect security problems 
> > if
> > you were unable to do so at the first time?
> 
> This is a different example, Diginotar was attacked and the attacker was able 
> to enter in their systems, and this is not what happened with StartCom. As 
> said, the code that went live is not the same that was audited the first time 
> and has been improved since then. The audits are just for that, and we will 
> continue doing yearly security audits to improve our systems.

Why not open-source the code on GitHub and let us be the judge of the 
improvements made to your systems code? Lets encrypt does this and works 
successfully. 

> > 
> > Though I would love to see StartCom up and running again, I have to agree
> > with James that 

RE: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

> 
> I want to give you some words from one of the "community side" (this is a
> personal opinion and may vary from other opinions inside the community).
> 
> Trust is not something that you get, it is something that you earn.

True

> StartCom was distrusted because of serious issues with their old PKI and now
> had the chance to restart - there are serious issues again. I don't think that
> the "community" wants rogue CAs on its list just because they restarted with
> new certificates.
> 
> - The fact that you were cross-signed by Certnomis before you had valid
> WebTrust Audits and the permission to issue trusted certificates again and
> that the only thing which prevented you from using the trust path is a PUBLIC
> certificate? Is the only thing that prevents me from entering your datacenter
> a sign which tells me not to do so and the fact that you did not tell me where
> your datacenter is located?
> 
> - Startcom operates/operated multiple CT Log Server itself. There is 
> absolutely
> no reason to use trusted certificates for testing purposes if he does have a
> testing infrastructure. It would be easy for you to add one of your testing
> roots to your CT Logs and then test your CT behaviour. I don't think that
> Googles CTs are different from your own ones. Though your certificates might
> not have been trusted at that time, they would be now and as Gerv said, test
> certificates are not allowed. If you did not care about compliance at that
> time, why should you care about it now?

Those certificates were not trusted at that time and can´t be now because they 
were revoked within minutes.

> 
> - There is a reason why Best Practices are called best practices. Why did you
> reuse your key in root and intermediate certificates? 
> Because there is nomoney for additional HSMs? Because you don't know how to 
> generate new
> keys? An explanation would be great.

A new thread has started about this. It´s not forbidden.

> 
> - P-521 are forbidden by Mozilla. Even if there is a discussion to change 
> this it
> does not allow you to take that as a permission to test it. The fact that 
> these
> certificates were reported as unrevoked at the time of reporting (as far as I
> remember) does imply that you do not monitor your certificate issuances for
> policy compliance at all. What do you do to ensure that all of your 
> certificates
> are compliant with all requirements at all times?

At the time of application, the certificates were revoked and countermeasures 
set and since then there´s no more issues. We have implemented cablint, crt.sh, 
... and some other tools into our issuance process and still trying to improve 
much more. 
I´m not trying to excuse we had issues but we corrected them.

> 
> - What internal audits have you done to ensure the integrity of your systems?
> If something so critically as the permission to issue certificates in EJBCA is
> only noticed after you explicitly looked for it, what happens if someone
> removes all of your security mechanisms? You will find that out too after you
> misissued thousands of certificates? Quis custodiet ipsos custodes.

Despite all the terrible systems we have, etc. we haven´t misissued thousands 
of certificates, nor hundreds. The issues we had, have been fixed.  Those test 
certs issued directly from the EJBCA was a mistake, explained many times. I 
have nothing to add to what I´ve already said. It was not a good decission, not 
a good practice, and it´s forbidden.

> 
> - The incidents with Diginotar should have made clear that secure, well
> audited and hardened code is absolutely necessary as well as reliable logs.
> The fact that these flaws where not found by your internal team and only
> discovered after an external company tested your systems is deeply
> concerning. What have you done now and what will you do to ensure that
> your systems won't be abused? How do you make sure that the code your
> people write in the future is safe and how do you detect security problems if
> you were unable to do so at the first time?

This is a different example, Diginotar was attacked and the attacker was able 
to enter in their systems, and this is not what happened with StartCom. As 
said, the code that went live is not the same that was audited the first time 
and has been improved since then. The audits are just for that, and we will 
continue doing yearly security audits to improve our systems.
> 
> Though I would love to see StartCom up and running again, I have to agree
> with James that all of these issues do not enwake trust into you and instead
> produce more uncertainties if StartCom is really able to run a PKI itself. 
> But as
> I said before, this is a personal opinion :)
> 
> 
> Am Freitag, 15. September 2017 16:38:25 UTC+2 schrieb Inigo Barreira:
> > > > Yes, you´re right, that was on the table and also suggested by
> > > > Mozilla, but the issue was that people from 360 are used to code
> > > > in PHP and the old one was in Java and 

Re: FW: StartCom inclusion request: next steps

[Eric Mill via dev-security-policy]

I didn't understand the original below comment by StartCom very well about
the cross-sign, but after Ryan's message I understand it better in
retrospect:

> On Thu, Sep 14, 2017 at 11:05 AM, Inigo Barreira via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:
>
> I´ve never said this. In fact, despite having that cross-signed which
were provided to us in july we have never used and provided to any of our
customers to build a trusted path. So none of those 5, or the new ones,
go with the Certinomis path because none have it. But all those 5 certs
are untrusted because we´re not in the Mozilla root, not the new one, and
the old one was distrusted.
>
> In fact, recently, I asked for permission to use the Certinomis
cross-signed certificates and have no response. I don´t know if this is an
administrative silence which may allow me to use it but until having a
clear direction we haven´t used it.

So this appears to be saying that "all those 5 certs are untrusted"
because StartCom didn't provide the full chain to customers, even though
such a chain could be constructed. The cross-signature wasn't published in
CT until August 2nd, but that's not any sort of guarantee that the
cross-signature wasn't discoverable by other means -- its availability
until August 2nd is a function of actions by Certinomis that are not
disclosed. The August 2nd date is also after StartCom's actions were being
publicly questioned, so it suggests the possibility that the
cross-signature would have been kept secret for longer, and was only
submitted to CT once scrutiny had increased.

Whether the cross-cert was issued before the audit report date is also a
mystery, especially if it's possible that either Certinomis or StartCom was
operating under the assumption that the cross-signature is irrelevant until
"delivered" to customers.

StartCom has remarked several times in this thread that they are being
treated unfairly, but I can think of at least one comparison to a previous
distrust event, which is that one of the more significant (in my opinion)
issues with Symantec's now-deprecated PKI is that there existed chains that
brought U.S. Federal PKI certificates into being trusted by Mozilla. Those
chains were, as far as I know, never delivered proactively to customers,
but could easily be constructed by any interested party with sufficient
knowledge of the universe of cross-signatures. For example, Qualys' SSL
Labs reports would automatically construct those chains for sites using
FPKI certs, and let users download the full chain in one click.

The threat model here is not what ordinary inexpert customers do, but what
opportunities an adversary has available to them among the universe of
trusted CAs to obtain certificates. In the Symantec/FPKI case, the problem
was that an adversary could easily use an FPKI certificate to intercept
connections made by Mozilla products, whether or not Symantec or the FPKI
ever advertised or proactively enabled this use case. What made this such a
big issue, in addition to the scope of the technical impact, is that the
issue was not noticed or elevated for years, during which multiple
"generations" of cross-signs had been issued and expired. It brought
Symantec's ability to understand their own PKI into serious question.

So I think the biggest issue here is not so much the technical impact, but
that StartCom was communicating inaccurate information to Mozilla. The
certs were publicly trusted by Certinomis, whether the cross-signature was
delivered to StartCom or to customers or to no one. While presumably this
inaccuracy was unintentional, it was enough to cause Gerv to express public
confusion and doubt about whether the certificates were part of the
cross-signed hierarchy. It also reflects a potentially dangerous difference
of perspective between StartCom and root stores in how StartCom evaluates
the trust and impact of the certificates they issue. For a CA that has been
operating for as long as StartCom has, I think it's fair to describe this
as concerning.

I also think that Certinomis, whose cross-signing practices are now being
scrutinized, should proactively post to this list with a timeline of its
own actions during this process, so that their actions can be understood in
the context of StartCom's.

-- Eric
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Re: StartCom inclusion request: next steps

[mw--- via dev-security-policy]

I want to give you some words from one of the "community side" (this is a 
personal opinion and may vary from other opinions inside the community). 

Trust is not something that you get, it is something that you earn. 
StartCom was distrusted because of serious issues with their old PKI and now 
had the chance to restart - there are serious issues again. I don't think that 
the "community" wants rogue CAs on its list just because they restarted with 
new certificates.

- The fact that you were cross-signed by Certnomis before you had valid 
WebTrust Audits and the permission to issue trusted certificates again and that 
the only thing which prevented you from using the trust path is a PUBLIC 
certificate? Is the only thing that prevents me from entering your datacenter a 
sign which tells me not to do so and the fact that you did not tell me where 
your datacenter is located? 

- Startcom operates/operated multiple CT Log Server itself. There is absolutely 
no reason to use trusted certificates for testing purposes if he does have a 
testing infrastructure. It would be easy for you to add one of your testing 
roots to your CT Logs and then test your CT behaviour. I don't think that 
Googles CTs are different from your own ones. Though your certificates might 
not have been trusted at that time, they would be now and as Gerv said, test 
certificates are not allowed. If you did not care about compliance at that 
time, why should you care about it now? 

- There is a reason why Best Practices are called best practices. Why did you 
reuse your key in root and intermediate certificates? Because there is no money 
for additional HSMs? Because you don't know how to generate new keys? An 
explanation would be great. 

- P-521 are forbidden by Mozilla. Even if there is a discussion to change this 
it does not allow you to take that as a permission to test it. The fact that 
these certificates were reported as unrevoked at the time of reporting (as far 
as I remember) does imply that you do not monitor your certificate issuances 
for policy compliance at all. What do you do to ensure that all of your 
certificates are compliant with all requirements at all times?

- What internal audits have you done to ensure the integrity of your systems? 
If something so critically as the permission to issue certificates in EJBCA is 
only noticed after you explicitly looked for it, what happens if someone 
removes all of your security mechanisms? You will find that out too after you 
misissued thousands of certificates? Quis custodiet ipsos custodes.

- The incidents with Diginotar should have made clear that secure, well audited 
and hardened code is absolutely necessary as well as reliable logs. The fact 
that these flaws where not found by your internal team and only discovered 
after an external company tested your systems is deeply concerning. What have 
you done now and what will you do to ensure that your systems won't be abused? 
How do you make sure that the code your people write in the future is safe and 
how do you detect security problems if you were unable to do so at the first 
time?

Though I would love to see StartCom up and running again, I have to agree with 
James that all of these issues do not enwake trust into you and instead produce 
more uncertainties if StartCom is really able to run a PKI itself. But as I 
said before, this is a personal opinion :) 


Am Freitag, 15. September 2017 16:38:25 UTC+2 schrieb Inigo Barreira:
> > > Yes, you´re right, that was on the table and also suggested by
> > > Mozilla, but the issue was that people from 360 are used to code in
> > > PHP and the old one was in Java and some other for which they are not
> > > so familiar and then was decided to re-write all the code in PHP
> > > trying to keep the same functionality.
> > 
> > Given the quality of code produced,
> 
> I don´t think the quality of the code which is in production now is poor or 
> of bad quality. It wasn´t good initially, that´s true, but not now.
> 
> > it might have been better in hindsight tohire Java experts to work on the 
> > old codebase.
> 
> That was also on the table.
> 
> > 
> > > Furthermore, with this decission, we also wanted to let the community
> > > know that this is totally a new CA system in all aspects, nothing
> > > related to the past, everything from scratch, so new coding, new
> > > programming language, new PKI system, infrastructure, etc. hoping this
> > > would make the community have a better impression of the new Startcom
> > regarding the distrust issue.
> > 
> > "We rewrote everything from scratch" is not actually something which itself
> > inspires confidence.
> 
> What I meant, is that we used a new programming language and then recoded.
> 
>  In the case of WoSign, it was required of them because
> > their old code was clearly terrible and buggy. But the reason the result 
> > would
> > have to be strongly audited (were they to
> > reapply) is that new code is riskier than 

Re: FW: StartCom inclusion request: next steps

[Ryan Sleevi via dev-security-policy]

On Fri, Sep 15, 2017 at 12:30 PM, Inigo Barreira via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> >
> > Hi Inigo,
> >
> > On 14/09/17 16:05, Inigo Barreira wrote:
> > > Those tests were done to check the CT behaviour, there was any other
> > testing of the new systems, just for the CT.
> >
> > Is there any reason those tests could not have been done using a parallel
> > testing hierarchy (other than the fact that you hadn't set one up)?
>
> I think I provided the reasons. We were distrusted, not re-applied yet,
> those certs lived for minutes, ...


Can you point where the Baseline Requirements and/or Root Store policies
exclude "certs lived for minutes" from being in scope? Or where revocation
absolves a CA of the issuance in the first place?


> So, I think these are the reasons. It´s not an excuse and we didn´t expect
> this maremágnum.


I believe the lack of expectation is precisely why there is significant
concern here. CAs are expected to be global stewards of trust, operating
beyond reproach - which generally means assuming all things are forbidden
unless expressly permitted, and even when it seems they _may_ be permitted,
to consider the full implications of the interpretation and to check if
there are multiple interpretations.


> There´s been long discussions about the harm long term certificates can
> make and asked CAs about short term to avoid damages. These certs, that
> it´s true was a mistake, only lived for minutes, so I don´t know what else
> I can add to this matter.
>

I think you've added a lot, and while the engagement has been valuable,
hopefully this clarifies precisely why these responses have been so deeply
concerning towards demonstrating trustworthiness.


> > But it is the job of a CA to be aware of browser policies.
>
> Yes, you´re right. And it was my fault for not have checked in deep this
> particular one.
>

We are not seeking to identify personal blame. We are seeking to understand
what, if any, improvements have been made to address such issues. In
reading this thread, I have difficulty finding any discussion about the
steps that StartCom has proposed to improve its awareness of the
expectations placed upon it as a potential participant in the Mozilla
store. Regardless of who bears responsibility for that, the absence of a
robust process - and, unfortunately, the absence of a deep understanding -
does mean that the restablishing of trust can present a significant risk to
the community.


> > I think lack of monitoring and lack of integrity of logs are serious
> issues.
>
> There wasn´t a lack of integrity and monitoring, of course not. All PKI
> logs were and are signed, it´s just the auditors wanted to add the
> integrity to other systems which is not so clear that should have this
> enabled. For example, if you want to archive database information for not
> managing a big one, the integrity of the logs could be a problem when
> trying to "move" to an archive system. I had some discussions about the
> "scope" of the integrity.


I am wholly uncertain how to interpret what you're saying here.


> Regarding the monitoring, well, we monitor many things, in both data
> centers, 24x7, etc. For this specific issue, it´s true that we didn´t have
> it automatically but manually, but well, and we implement a solution, but
> this is not a lack of monitoring. I think the audits are to correct and
> improve the systems and don´t think any CA at the first time had everything
> correct. So, for example, I thought this finding was good because made us
> improve.
>

I agree that a well-executed audit can help a CA identify areas of
improvement. However, a well-executed audit can also identify issues of
non-compliance or identify issues of risk that the community may find
unacceptable, independent of the auditors own assessment.


> > Repairing them afterwards does not remove the uncertainty.
>
> Well, then any issue that you could find, even repaired or fixed, does not
> provide you any security and hence you should not trust anyone.
>

I do not think this demonstrates a positive awareness of the issues being
discussed. Again, as CAs are expected to be stewards of global trust, it is
expected that CAs seek to both individually improve and rise above 'the
minimum' requirements, and to seek ways to improve those minimums.

> If you said "I left the root certificate private key on a USB stick on
> the desk in my unlocked
> > office over the weekend - but it's OK, I've remediated the problem now,
> and
> > it's back in the safe", that would not remove the uncertainty about
> whether
> > someone had done something with it in the mean time.
>
> Well, I don´t think this is the same "quality" of example.
>

It is useful to know what you think, as it highlights disagreement.
However, it's more useful to know why you think this. I would suggest that,
for most people examining both the information provided on the issues, the
facts, and the discussion so far, it is very 

RE: FW: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

> 
> Hi Inigo,
> 
> On 14/09/17 16:05, Inigo Barreira wrote:
> > Those tests were done to check the CT behaviour, there was any other
> testing of the new systems, just for the CT.
> 
> Is there any reason those tests could not have been done using a parallel
> testing hierarchy (other than the fact that you hadn't set one up)?

I think I provided the reasons. We were distrusted, not re-applied yet, those 
certs lived for minutes, ... So, I think these are the reasons. It´s not an 
excuse and we didn´t expect this maremágnum. There´s been long discussions 
about the harm long term certificates can make and asked CAs about short term 
to avoid damages. These certs, that it´s true was a mistake, only lived for 
minutes, so I don´t know what else I can add to this matter.

> 
> > Some of these "mis-issuances" were due to some incongruencies between
> > the BRs and the Mozilla policy, such as the use of different curves
> > (allowed by the BRs but not for some browsers),
> 
> But it is the job of a CA to be aware of browser policies.

Yes, you´re right. And it was my fault for not have checked in deep this 
particular one.

> 
> > As far as I know, the current manager of Startcom has not been previously
> accused of deception or bad action.
> 
> No, indeed. There is no accusation that you have been deceptive towards
> anyone.
> 
> > Yes, it´s not a policy violation. As explained, this was a problem in the 
> > EJBCA
> with the UTF8 encoding.
> 
> That was the reason for the revocation; it's not the reason for the key reuse.

Yes, right, but this is allowed afaik. It´s mentioned in the BRs.

> 
> >> * The WT/BR/EV audits on StartCom's website are significantly
> >> qualified, and they include lack of controls on issuance. They should
> >> have clean ones done before we permit any inclusion request to proceed.
> The qualifications include:
> >>
> >> - Risk analysis process defined but not implemented
> >> - Business continuity plan defined but not implemented
> >> - Audit logs not guaranteed to have integrity
> >> - Monitoring system cannot detect security-related changes to
> >>   Certificate Systems
> >
> > Yes, this is also true. Our webtrust audits have findings but those are not 
> > so
> significant according to the auditors who signed the reports, so I assume the
> auditors thought that the system is good enough to have the audit report in
> place.
> 
> I think lack of monitoring and lack of integrity of logs are serious issues.

There wasn´t a lack of integrity and monitoring, of course not. All PKI logs 
were and are signed, it´s just the auditors wanted to add the integrity to 
other systems which is not so clear that should have this enabled. For example, 
if you want to archive database information for not managing a big one, the 
integrity of the logs could be a problem when trying to "move" to an archive 
system. I had some discussions about the "scope" of the integrity. Regarding 
the monitoring, well, we monitor many things, in both data centers, 24x7, etc. 
For this specific issue, it´s true that we didn´t have it automatically but 
manually, but well, and we implement a solution, but this is not a lack of 
monitoring. I think the audits are to correct and improve the systems and don´t 
think any CA at the first time had everything correct. So, for example, I 
thought this finding was good because made us improve.

> Repairing them afterwards does not remove the uncertainty.

Well, then any issue that you could find, even repaired or fixed, does not 
provide you any security and hence you should not trust anyone. 

 
> If you said "I left the root certificate private key on a USB stick on the 
> desk in my unlocked
> office over the weekend - but it's OK, I've remediated the problem now, and
> it's back in the safe", that would not remove the uncertainty about whether
> someone had done something with it in the mean time.

Well, I don´t think this is the same "quality" of example.
> 
> > I don´t know how these you mention have applied, but I remember lots of
> issues regarding Google and the acquisition of the Globalsign roots and how
> they proceeded.
> 
> I think "lots of issues" is an overstatement. There was an issue regarding the
> scope of their audits which was raised publicly, but it was something that
> Google has explicitly sought our approval for in advance.

Yes, it´s an overstatement but similar to others. I said that I didn´t know 
what or how they had applied but you put them as examples and just wanted to 
indicate that there were discussions, so maybe was not so smooth, but again, I 
don´t know.

> 
> > Not sure about this. We were distrusted in october 2016, the new system
> started to operate in april 2017, which is not related to the old one which 
> has
> been switched off. None of the new certs are trusted in Mozilla Firefox and
> we notify our users so by messages in the web and applications.
> 
> I may have made a mistake here. I was under the impression that you had
> 

RE: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

> > Yes, you´re right, that was on the table and also suggested by
> > Mozilla, but the issue was that people from 360 are used to code in
> > PHP and the old one was in Java and some other for which they are not
> > so familiar and then was decided to re-write all the code in PHP
> > trying to keep the same functionality.
> 
> Given the quality of code produced,

I don´t think the quality of the code which is in production now is poor or of 
bad quality. It wasn´t good initially, that´s true, but not now.

> it might have been better in hindsight tohire Java experts to work on the old 
> codebase.

That was also on the table.

> 
> > Furthermore, with this decission, we also wanted to let the community
> > know that this is totally a new CA system in all aspects, nothing
> > related to the past, everything from scratch, so new coding, new
> > programming language, new PKI system, infrastructure, etc. hoping this
> > would make the community have a better impression of the new Startcom
> regarding the distrust issue.
> 
> "We rewrote everything from scratch" is not actually something which itself
> inspires confidence.

What I meant, is that we used a new programming language and then recoded.

 In the case of WoSign, it was required of them because
> their old code was clearly terrible and buggy. But the reason the result would
> have to be strongly audited (were they to
> reapply) is that new code is riskier than old, tried-and-tested code.
> 
> I don't know if I ever wrote it down anywhere, but I'm fairly sure that
> switching back from the WoSign codebase to the older StartCom codebase
> (i.e. reversing the change you made after the purchase) was my suggestion for
> how StartCom should proceed after the dis-trust event.

Yes, that was your suggestion.

> That doesn't mean you are required to take my advice,

Yes, I know

> but it might have beena hint that I wouldn't consider "hey, we rewrote 
> everything from scratch!" as
> a positive point.

Well, we thought that it could be. During the distrust issues, I think Ryan 
posted some old issues related to the old Startcom code or procedures (long 
time ago) and then recoding everything was our intent to give a positive 
answer. As said, the term "from scratch" maybe it´s not appropiate, but in the 
end this code has been audited. 
> 
> Gerv



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Re: FW: StartCom inclusion request: next steps

[Alex Gaynor via dev-security-policy]

I'm fairly confused by your answers, if the only thing you tested in
production was CT, why was the system issuing non-compliant certs? Why did
production CT testing come before having established, tested, and verified
a compliant certificate profile?

Alex

On Fri, Sep 15, 2017 at 10:35 AM, Inigo Barreira via dev-security-policy <
dev-security-policy@lists.mozilla.org> wrote:

> > On 15/09/17 11:01, Inigo Barreira wrote:
> > > Considering that we were distrusted, that we didn´t reapply for
> > > inclussion, that CT is only required by Chrome and it´s not included
> > > in the Mozilla policy (even we were requested that all of our certs
> > > had to be CT logged) nor required by Firefox, that those certs were
> > > under our control all the time and lived for some minutes because were
> > > revoked inmediately, at that time, when we did it, we didn´t expect
> > > this reaction for sure.
> >
> > But surely CT testing is not the only sort of testing you've been doing?
>
> Yes, this is the only test we did it in production
>
> > E.g. you made some test certificates with different types of ECC curve,
> which
> > you then had to revoke some of as against browser policies.
>
> No, those weren´t tests. We allowed the use of curves permitted by the BRs
> but this issue came up in the mozilla policy (I think Arkadiusz posted) and
> I also asked about it in the last CABF F2F (I asked Ryan about it) and
> then, with that outcome and as the browsers didn´t accept them, we revoked
> and then not allow the issuance. I think the discussion is still active
> (i.e. the use of P-521).
>
> > If these had been in a testing hierarchy there would have been no
> problem.
> >
> > CAs have been heavily criticised over the past few years for issuing test
> > certificates in public hierarchies (see e.g. Symantec). The danger of
> doing so
> > should be well known to all CAs by now.
>
> Yes, I know. But the only testing we did in production was the one related
> to the CT.
> >
> > Perhaps once a test has been passed and checked in a testing system, and
> if
> > the certificates concerned do not violate any policies, it could be
> repeated on
> > a production system to deal with any possible differences between the
> two.
> > But starting with the production system is not a good idea.
>
> True, but it seems you´re understanding that we have only a production
> system in which we test everything and this is not the case. Before moving
> anything into production, we have tested in development and in the QA
> system.
> >
> > Gerv
>
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Re: FW: StartCom inclusion request: next steps

[Gervase Markham via dev-security-policy]

On 15/09/17 09:24, Inigo Barreira wrote:
> AFAIK, Certinomis only disclosed in the CCADB 

That means it's published and available. As noted in my other reply,
information as to exactly what this cross-sign enables trust for would
be most helpful, as I may have misunderstood previous statements on this
topic.

Gerv
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Re: FW: StartCom inclusion request: next steps

[Gervase Markham via dev-security-policy]

Hi Inigo,

On 14/09/17 16:05, Inigo Barreira wrote:
> Those tests were done to check the CT behaviour, there was any other testing 
> of the new systems, just for the CT. 

Is there any reason those tests could not have been done using a
parallel testing hierarchy (other than the fact that you hadn't set one up)?

> Some of these "mis-issuances" were due to some incongruencies between the BRs 
> and the Mozilla policy, such as the use of different curves (allowed by the 
> BRs but not for some browsers),

But it is the job of a CA to be aware of browser policies.

> As far as I know, the current manager of Startcom has not been previously 
> accused of deception or bad action.

No, indeed. There is no accusation that you have been deceptive towards
anyone.

> Yes, it´s not a policy violation. As explained, this was a problem in the 
> EJBCA with the UTF8 encoding. 

That was the reason for the revocation; it's not the reason for the key
reuse.

>> * The WT/BR/EV audits on StartCom's website are significantly qualified, and
>> they include lack of controls on issuance. They should have clean ones done
>> before we permit any inclusion request to proceed. The qualifications 
>> include:
>>
>> - Risk analysis process defined but not implemented
>> - Business continuity plan defined but not implemented
>> - Audit logs not guaranteed to have integrity
>> - Monitoring system cannot detect security-related changes to
>>   Certificate Systems
> 
> Yes, this is also true. Our webtrust audits have findings but those are not 
> so significant according to the auditors who signed the reports, so I assume 
> the auditors thought that the system is good enough to have the audit report 
> in place.

I think lack of monitoring and lack of integrity of logs are serious
issues. Repairing them afterwards does not remove the uncertainty. If
you said "I left the root certificate private key on a USB stick on the
desk in my unlocked office over the weekend - but it's OK, I've
remediated the problem now, and it's back in the safe", that would not
remove the uncertainty about whether someone had done something with it
in the mean time.

> I don´t know how these you mention have applied, but I remember lots of 
> issues regarding Google and the acquisition of the Globalsign roots and how 
> they proceeded. 

I think "lots of issues" is an overstatement. There was an issue
regarding the scope of their audits which was raised publicly, but it
was something that Google has explicitly sought our approval for in advance.

> Not sure about this. We were distrusted in october 2016, the new system 
> started to operate in april 2017, which is not related to the old one which 
> has been switched off. None of the new certs are trusted in Mozilla Firefox 
> and we notify our users so by messages in the web and applications.

I may have made a mistake here. I was under the impression that you had
told me that your new hierarchy, cross-signed by Certnomis, had issued
50,000 certificates. Did I misunderstand? If so, my apologies.

> Ok, I see this is a new requirement that was not imposed last time in which 
> you recommended and allowed us to be cross-signed as many other CAs have done 
> in the past to be in the business.

Mozilla did not recommend that you be cross-signed. Certnomis raised the
possibility, and we said that it could happen when you had met the BRs
and completed the remediation steps. The plan we "approved" was not a
cross-signing plan. The audits show you haven't yet met the BRs, and we
have not yet signed off on you having completed the remediation steps.

> We´ve met all the conditions, new system, new management, security audit and 
> webtrust audit and CT logging. In those conditions, it was not mentioned that 
> the webtrust audit should be clean 

Isn't that implied?

> I´ve never said this. In fact, despite having that cross-signed which were 
> provided to us in july we have never used and provided to any of our 
> customers to build a trusted path. So none of those 5, or the new ones, 
> go with the Certinomis path because none have it. But all those 5 certs 
> are untrusted because we´re not in the Mozilla root, not the new one, and the 
> old one was distrusted.

So the 50,000 certs you mentioned are issued in your old hierarchy,
which is not cross-signed by Certnomis?

If you could clarify the numbers for your old and new PKI, and confirm
that the Certnomis cross-signs apply only to the new one, that would be
helpful. Again, apologies for any misunderstanding on my part.

> In fact, recently, I asked for permission to use the Certinomis cross-signed 
> certificates and have no response. I don´t know if this is an administrative 
> silence which may allow me to use it but until having a clear direction we 
> haven´t used it. 

Can you remind me how you asked and when?

> I think this has been explained. I don´t understand why you say it´s a "poor 
> quality PHP code". 

Because poor quality PHP code does 

RE: FW: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

> Hi Inigo,
> 
> To add from the last post.
> 
> I know this is unwelcome news to you but I feel that with all these incidents
> happening right now with Symantec and the incidents before, we can't really
> take any more chances. Every incident is eroding trust in this system and if 
> we
> want more people to take up adoption of https in the long term, I feel that
> we need to start operating infrastructure above board and without issues.
> 
> James


James, I share with you this desire. But we´re seeing one day and another that 
issues are still happening, and not all are from StartCom :-) so to avoid 
eroding trust what do you suggest if not give more chances? Remove them all? 


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RE: FW: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

> > >
> > > > Those tests were done to check the CT behaviour, there was any
> > > > other
> > > testing of the new systems, just for the CT. Those certs were under
> > > control all the time and were lived for some minutes because were
> > > revoked inmediately after checking the certs were logged correctly
> > > in the CTs. It´s not a mis- issuance by means of we didn´t know what
> > > happened, we had to investigate, etc. It was not a good practice and
> > > I can´t excuse for that, but it was not related to the regular
> > > issuance procedure as someone suggested. We provided a report in
> > > which indicated all that happened and what we did to not happen this
> again, updating the EJBCA roles permissions.
> > >
> > > 1) Why didn't StartCom build a test hierarchy?
> >
> > Considering that we were distrusted, that we didn´t reapply for inclussion,
> that CT is only required by Chrome and it´s not included in the Mozilla policy
> (even we were requested that all of our certs had to be CT logged) nor
> required by Firefox, that those certs were under our control all the time and
> lived for some minutes because were revoked inmediately, at that time, when
> we did it, we didn´t expect this reaction for sure.
> >
> > Of course if we had known it we hadn´t done it and for sure had built
> > a test hierarchy but there´s nothing we can do now. Only wanted to
> > state that those certs were under our control all the time, and lived
> > for some minutes because were revoked after the test. There were not
> > any other testing of any other nature directly in the production
> > system
> >
> > > 2) Why didn't StartCom use the TestTube CT log for testing CT?
> >
> > We tried to check and test the same behaviour before going live with the CT
> logging, so followed the requirements to use 3 logs, one google and one non-
> google, for the EVs and this is what we did. We used the same settings we
> had before the distrust using the startcom log and the google ones (pilot and
> rocketeer).
> 
> Hi Inigo,
> 
> I'm just trying to get everything straight, cleared up and then we can move
> on.
> 
> I found all of your answers very concerning in the way you've conducted
> testing. I thought that all CAs must have some type of test hierarchy in place
> to test new software,

Well, this is not required. Of course we have a development and a testing 
system, which are not "connected" into production.
As we wanted to check the same behaviour for the CT ecosystem than before the 
distrust, we did it directly in production, but don´t take this as we didn´t 
test it before in our development and testing systems, for sure we did.
 
> requirements and etc before going live but from the answers you've given, 
> StartCom neglected this in favour to test as you go
> along and deal with the problems using a live CA hierarchy.

As said, this wasn´t a "live" CA hierarchy. We were distrusted, nothing issued 
from that "live" CA was trusted, this wasn´t any harm to any of the Mozilla 
users.

 
> All this feels very amateurish and doesn't give me the any confidence at all 
> that your CA is
> proven itself to be a trustworthy part of this infrastructure.

I respect this opinion but can´t agree with it.

> 
> I recommend to Mozilla to require StartCom to start again fresh.
> 
> 1. Build a test hierarchy. Test the software and etc to industry guidelines.
> 2. Build a new production hierarchy (including new HSMs, keys, roots, etc.)
> and then re-apply for inclusion into the Mozilla root program.
> 3. Once approved then you can cross-sign your roots with another CA.
> 
> While this is happening. You can resell certificates from other CAs and build
> up trust in the industry which will benefit you in the long term I feel.
> 
> James
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Re: FW: StartCom inclusion request: next steps

[James Burton via dev-security-policy]

On Friday, September 15, 2017 at 12:30:00 PM UTC+1, James Burton wrote:
> On Friday, September 15, 2017 at 10:56:11 AM UTC+1, Inigo Barreira wrote:
> > > 
> > > > Those tests were done to check the CT behaviour, there was any other
> > > testing of the new systems, just for the CT. Those certs were under 
> > > control all
> > > the time and were lived for some minutes because were revoked inmediately
> > > after checking the certs were logged correctly in the CTs. It´s not a mis-
> > > issuance by means of we didn´t know what happened, we had to investigate,
> > > etc. It was not a good practice and I can´t excuse for that, but it was 
> > > not
> > > related to the regular issuance procedure as someone suggested. We
> > > provided a report in which indicated all that happened and what we did to
> > > not happen this again, updating the EJBCA roles permissions.
> > > 
> > > 1) Why didn't StartCom build a test hierarchy?
> > 
> > Considering that we were distrusted, that we didn´t reapply for inclussion, 
> > that CT is only required by Chrome and it´s not included in the Mozilla 
> > policy (even we were requested that all of our certs had to be CT logged) 
> > nor required by Firefox, that those certs were under our control all the 
> > time and lived for some minutes because were revoked inmediately, at that 
> > time, when we did it, we didn´t expect this reaction for sure.
> > 
> > Of course if we had known it we hadn´t done it and for sure had built a 
> > test hierarchy but there´s nothing we can do now. Only wanted to state that 
> > those certs were under our control all the time, and lived for some minutes 
> > because were revoked after the test. There were not any other testing of 
> > any other nature directly in the production system
> > 
> > > 2) Why didn't StartCom use the TestTube CT log for testing CT?
> > 
> > We tried to check and test the same behaviour before going live with the CT 
> > logging, so followed the requirements to use 3 logs, one google and one 
> > non-google, for the EVs and this is what we did. We used the same settings 
> > we had before the distrust using the startcom log and the google ones 
> > (pilot and rocketeer).
> 
> Hi Inigo,
> 
> I'm just trying to get everything straight, cleared up and then we can move 
> on.
> 
> I found all of your answers very concerning in the way you've conducted 
> testing. I thought that all CAs must have some type of test hierarchy in 
> place to test new software, requirements and etc before going live but from 
> the answers you've given, StartCom neglected this in favour to test as you go 
> along and deal with the problems using a live CA hierarchy. All this feels 
> very amateurish and doesn't give me the any confidence at all that your CA is 
> proven itself to be a trustworthy part of this infrastructure.
> 
> I recommend to Mozilla to require StartCom to start again fresh. 
> 
> 1. Build a test hierarchy. Test the software and etc to industry guidelines.
> 2. Build a new production hierarchy (including new HSMs, keys, roots, etc.) 
> and then re-apply for inclusion into the Mozilla root program.
> 3. Once approved then you can cross-sign your roots with another CA.
> 
> While this is happening. You can resell certificates from other CAs and build 
> up trust in the industry which will benefit you in the long term I feel.
> 
> James

Hi Inigo,

To add from the last post.

I know this is unwelcome news to you but I feel that with all these incidents 
happening right now with Symantec and the incidents before, we can't really 
take any more chances. Every incident is eroding trust in this system and if we 
want more people to take up adoption of https in the long term, I feel that we 
need to start operating infrastructure above board and without issues.

James
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Re: FW: StartCom inclusion request: next steps

[James Burton via dev-security-policy]

On Friday, September 15, 2017 at 10:56:11 AM UTC+1, Inigo Barreira wrote:
> > 
> > > Those tests were done to check the CT behaviour, there was any other
> > testing of the new systems, just for the CT. Those certs were under control 
> > all
> > the time and were lived for some minutes because were revoked inmediately
> > after checking the certs were logged correctly in the CTs. It´s not a mis-
> > issuance by means of we didn´t know what happened, we had to investigate,
> > etc. It was not a good practice and I can´t excuse for that, but it was not
> > related to the regular issuance procedure as someone suggested. We
> > provided a report in which indicated all that happened and what we did to
> > not happen this again, updating the EJBCA roles permissions.
> > 
> > 1) Why didn't StartCom build a test hierarchy?
> 
> Considering that we were distrusted, that we didn´t reapply for inclussion, 
> that CT is only required by Chrome and it´s not included in the Mozilla 
> policy (even we were requested that all of our certs had to be CT logged) nor 
> required by Firefox, that those certs were under our control all the time and 
> lived for some minutes because were revoked inmediately, at that time, when 
> we did it, we didn´t expect this reaction for sure.
> 
> Of course if we had known it we hadn´t done it and for sure had built a test 
> hierarchy but there´s nothing we can do now. Only wanted to state that those 
> certs were under our control all the time, and lived for some minutes because 
> were revoked after the test. There were not any other testing of any other 
> nature directly in the production system
> 
> > 2) Why didn't StartCom use the TestTube CT log for testing CT?
> 
> We tried to check and test the same behaviour before going live with the CT 
> logging, so followed the requirements to use 3 logs, one google and one 
> non-google, for the EVs and this is what we did. We used the same settings we 
> had before the distrust using the startcom log and the google ones (pilot and 
> rocketeer).

Hi Inigo,

I'm just trying to get everything straight, cleared up and then we can move on.

I found all of your answers very concerning in the way you've conducted 
testing. I thought that all CAs must have some type of test hierarchy in place 
to test new software, requirements and etc before going live but from the 
answers you've given, StartCom neglected this in favour to test as you go along 
and deal with the problems using a live CA hierarchy. All this feels very 
amateurish and doesn't give me the any confidence at all that your CA is proven 
itself to be a trustworthy part of this infrastructure.

I recommend to Mozilla to require StartCom to start again fresh. 

1. Build a test hierarchy. Test the software and etc to industry guidelines.
2. Build a new production hierarchy (including new HSMs, keys, roots, etc.) and 
then re-apply for inclusion into the Mozilla root program.
3. Once approved then you can cross-sign your roots with another CA.

While this is happening. You can resell certificates from other CAs and build 
up trust in the industry which will benefit you in the long term I feel.

James
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RE: FW: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

> 
> > Those tests were done to check the CT behaviour, there was any other
> testing of the new systems, just for the CT. Those certs were under control 
> all
> the time and were lived for some minutes because were revoked inmediately
> after checking the certs were logged correctly in the CTs. It´s not a mis-
> issuance by means of we didn´t know what happened, we had to investigate,
> etc. It was not a good practice and I can´t excuse for that, but it was not
> related to the regular issuance procedure as someone suggested. We
> provided a report in which indicated all that happened and what we did to
> not happen this again, updating the EJBCA roles permissions.
> 
> 1) Why didn't StartCom build a test hierarchy?

Considering that we were distrusted, that we didn´t reapply for inclussion, 
that CT is only required by Chrome and it´s not included in the Mozilla policy 
(even we were requested that all of our certs had to be CT logged) nor required 
by Firefox, that those certs were under our control all the time and lived for 
some minutes because were revoked inmediately, at that time, when we did it, we 
didn´t expect this reaction for sure.

Of course if we had known it we hadn´t done it and for sure had built a test 
hierarchy but there´s nothing we can do now. Only wanted to state that those 
certs were under our control all the time, and lived for some minutes because 
were revoked after the test. There were not any other testing of any other 
nature directly in the production system

> 2) Why didn't StartCom use the TestTube CT log for testing CT?

We tried to check and test the same behaviour before going live with the CT 
logging, so followed the requirements to use 3 logs, one google and one 
non-google, for the EVs and this is what we did. We used the same settings we 
had before the distrust using the startcom log and the google ones (pilot and 
rocketeer).





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Re: FW: StartCom inclusion request: next steps

[James Burton via dev-security-policy]

> Those tests were done to check the CT behaviour, there was any other testing 
> of the new systems, just for the CT. Those certs were under control all the 
> time and were lived for some minutes because were revoked inmediately after 
> checking the certs were logged correctly in the CTs. It´s not a mis-issuance 
> by means of we didn´t know what happened, we had to investigate, etc. It was 
> not a good practice and I can´t excuse for that, but it was not related to 
> the regular issuance procedure as someone suggested. We provided a report in 
> which indicated all that happened and what we did to not happen this again, 
> updating the EJBCA roles permissions.

1) Why didn't StartCom build a test hierarchy? 
2) Why didn't StartCom use the TestTube CT log for testing CT? 
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RE: FW: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

> On 14/09/2017 17:05, Inigo Barreira wrote:
> > All,
> >
> > ...
> >>
> >> We should add the existing Certnomis cross-signs to OneCRL to revoke
> >> all the existing certificates. As of 10th August (now a month ago)
> >> StartCom said they have 5 outstanding SSL certs which are valid
> >> due to the Certnomis cross- sign.
> >
> > I´ve never said this. In fact, despite having that cross-signed which were
> provided to us in july we have never used and provided to any of our
> customers to build a trusted path. So none of those 5, or the new ones,
> go with the Certinomis path because none have it. But all those 5 certs
> are untrusted because we´re not in the Mozilla root, not the new one, and the
> old one was distrusted.
> > In fact, recently, I asked for permission to use the Certinomis cross-signed
> certificates and have no response. I don´t know if this is an administrative
> silence which may allow me to use it but until having a clear direction we
> haven´t used it.
> >
> 
> 
> I can't speak for Mozilla, but the obvious point is, that as soon as the cross
> certificate from Certinomis was published in CT-logs or elsewhere, any
> StartCom customer could (and still can) download it and install it on their
> server, thus activating the Certinomis path for their server.
> 

AFAIK, Certinomis only disclosed in the CCADB and even we received it, we have 
not sent to any customer nor posted anywhere. And I know crt.sh includes it and 
when questioned for it Rob answered that crt.sh includes all certs that have 
been submitted to one or more of the monitored CT logs, and includes all trust 
paths that can be built.
I don´t think any StartCom customer has downloaded from wherever it could be 
and installed and created the trusted path. Our customers base are not very 
familiar with this stuff. Usually we need to provide all of them with 
instructions on what and how to do it.

> 
> Enjoy
> 
> Jakob
> --
> Jakob Bohm, CIO, Partner, WiseMo A/S.  https://www.wisemo.com
> Transformervej 29, 2860 Søborg, Denmark.  Direct +45 31 13 16 10 This
> public discussion message is non-binding and may contain errors.
> WiseMo - Remote Service Management for PCs, Phones and Embedded
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RE: FW: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

Yes, there are similar ones everywhere, so I´m familiar with it :-)
And you´re right, I also make contributions in many other places, ETSI, ENISA, 
CABF (used to), ... and not get paid for that, but it´s also true that the way 
the distrust happened didn´t give us time or much time to act accordingly, even 
now people is asking for the distrust or asking for refunds due to the 
distrust. 

And yes, we tried to do it quickly and we know what happened but we didn´t 
re-apply at that time. We got issues and until all of them were fixed and we 
receive the OK we didn´t move forward. We wanted to meet the deadline we 
imposed ourselves and even reached, it was not in a good shape, so, had to 
start again. And that´s what I said internally, that it didn´t matter if we 
could not make it in 6 months as indicated in the sanction and it took us 
nearly 10, taking into account that everything was new.

Best regards

Iñigo Barreira
CEO
StartCom CA Limited


> -Original Message-
> From: dev-security-policy [mailto:dev-security-policy-
> bounces+inigo=startcomca@lists.mozilla.org] On Behalf Of Nick Lamb via
> dev-security-policy
> Sent: viernes, 15 de septiembre de 2017 1:22
> To: mozilla-dev-security-pol...@lists.mozilla.org
> Subject: Re: FW: StartCom inclusion request: next steps
> 
> On Thursday, 14 September 2017 16:00:35 UTC+1, Inigo Barreira  wrote:
> > Well, finally this is a business and I don´t think none on this list is 
> > working
> for free. At the end everyone has his/her salary, etc. But that was not the
> main reason because getting included in the root programs takes time but
> wanted to provide our customers which gave us support for what happened
> with the distrust (which IMHO in the case of Startcom was very aggressive) a
> solution generating a new fresh and clean system.
> 
> I can't speak for other people contributing to m.d.s.policy but of course I am
> not paid to do this. I have a job, but it isn't this. I have never asked my
> employer's permission to contribute here, judging it to be entirely outside
> their purview. My job does include running a (small, private) CA, but then it
> also includes maintaining a DBMS, a web crawler and all sorts of other stuff,
> I'm sure it would be possible to identify some connection to my job for almost
> any technical contribution I could make anywhere.
> 
> There is an proverb in English, I am not sure if you're familiar with it, 
> "More
> haste, less speed". What this means is that in trying to perform a task as
> quickly as possible you may instead cause yourself such extra trouble that in
> the end the task takes even longer to complete. I am sure that even if you
> have not come across a phrase like this before you can see its applicability 
> to
> the situation for StartCom.
> ___
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> dev-security-policy@lists.mozilla.org
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RE: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

Hi Percy,

Yes, you´re right, that was on the table and also suggested by Mozilla, but
the issue was that people from 360 are used to code in PHP and the old one
was in Java and some other for which they are not so familiar and then was
decided to re-write all the code in PHP trying to keep the same
functionality. Besides, the old code had to be integrated with the new PKI
infrastructure, EJBCA, and that was not an easy task.
All in all on the table, integration with new systems, maintenance of the
old code if issues arise due to this integration or any other problem, not
good language knowledge, get used to PHP, etc. made us took that decission. 
Furthermore, with this decission, we also wanted to let the community know
that this is totally a new CA system in all aspects, nothing related to the
past, everything from scratch, so new coding, new programming language, new
PKI system, infrastructure, etc. hoping this would make the community have a
better impression of the new Startcom regarding the distrust issue.

Best regards

Iñigo Barreira
CEO
StartCom CA Limited


> -Original Message-
> From: dev-security-policy [mailto:dev-security-policy-
> bounces+inigo=startcomca@lists.mozilla.org] On Behalf Of Percy via
dev-
> security-policy
> Sent: jueves, 14 de septiembre de 2017 22:13
> To: mozilla-dev-security-pol...@lists.mozilla.org
> Subject: Re: StartCom inclusion request: next steps
> 
> "Conclusion: StartCom's attempt to restart the CA was rushed."
> 
> "It was a very hard task in very few time but the people at 360 tried
> everything to get it done by that date, end of december 2016, and yes, we
> reached the date but with many failures"
> 
> May I ask why StartCom choose to rush everything in PHP from the ground up
> rather than using the more secure system already in place in the old
> StartCom?  From my understanding, the distrust of StartCom is more related
> to the secret acquisition by  WoSign an Qihoo 360 rather than insecure
> infrastructure. So if the deadline is so imminent as you stated and
pressure is
> so high from customers, can't you use the reasonably secure old code base
> rather than rushing everything from the ground up? Then you will have more
> time transition to another system if needed with sufficient time for
secure
> processes?
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Re: FW: StartCom inclusion request: next steps

[Jakob Bohm via dev-security-policy]

On 14/09/2017 17:05, Inigo Barreira wrote:

All,

...


We should add the existing Certnomis cross-signs to OneCRL to revoke all the
existing certificates. As of 10th August (now a month ago) StartCom said they
have 5 outstanding SSL certs which are valid due to the Certnomis cross-
sign.


I´ve never said this. In fact, despite having that cross-signed which were 
provided to us in july we have never used and provided to any of our customers 
to build a trusted path. So none of those 5, or the new ones, go with the 
Certinomis path because none have it. But all those 5 certs are untrusted 
because we´re not in the Mozilla root, not the new one, and the old one was 
distrusted.
In fact, recently, I asked for permission to use the Certinomis cross-signed 
certificates and have no response. I don´t know if this is an administrative 
silence which may allow me to use it but until having a clear direction we 
haven´t used it.




I can't speak for Mozilla, but the obvious point is, that as soon as
the cross certificate from Certinomis was published in CT-logs or
elsewhere, any StartCom customer could (and still can) download it and
install it on their server, thus activating the Certinomis path for
their server.


Enjoy

Jakob
--
Jakob Bohm, CIO, Partner, WiseMo A/S.  https://www.wisemo.com
Transformervej 29, 2860 Søborg, Denmark.  Direct +45 31 13 16 10
This public discussion message is non-binding and may contain errors.
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Re: FW: StartCom inclusion request: next steps

[Nick Lamb via dev-security-policy]

On Thursday, 14 September 2017 16:00:35 UTC+1, Inigo Barreira  wrote:
> Well, finally this is a business and I don´t think none on this list is 
> working for free. At the end everyone has his/her salary, etc. But that was 
> not the main reason because getting included in the root programs takes time 
> but wanted to provide our customers which gave us support for what happened 
> with the distrust (which IMHO in the case of Startcom was very aggressive) a 
> solution generating a new fresh and clean system.

I can't speak for other people contributing to m.d.s.policy but of course I am 
not paid to do this. I have a job, but it isn't this. I have never asked my 
employer's permission to contribute here, judging it to be entirely outside 
their purview. My job does include running a (small, private) CA, but then it 
also includes maintaining a DBMS, a web crawler and all sorts of other stuff, 
I'm sure it would be possible to identify some connection to my job for almost 
any technical contribution I could make anywhere.

There is an proverb in English, I am not sure if you're familiar with it, "More 
haste, less speed". What this means is that in trying to perform a task as 
quickly as possible you may instead cause yourself such extra trouble that in 
the end the task takes even longer to complete. I am sure that even if you have 
not come across a phrase like this before you can see its applicability to the 
situation for StartCom.
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Re: StartCom inclusion request: next steps

[Percy via dev-security-policy]

"Conclusion: StartCom's attempt to restart the CA was rushed."

"It was a very hard task in very few time but the people at 360 tried 
everything to get it done by that date, end of december 2016, and yes, we 
reached the date but with many failures"

May I ask why StartCom choose to rush everything in PHP from the ground up 
rather than using the more secure system already in place in the old StartCom?  
From my understanding, the distrust of StartCom is more related to the secret 
acquisition by  WoSign an Qihoo 360 rather than insecure infrastructure. So if 
the deadline is so imminent as you stated and pressure is so high from 
customers, can't you use the reasonably secure old code base rather than 
rushing everything from the ground up? Then you will have more time transition 
to another system if needed with sufficient time for secure processes?
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FW: StartCom inclusion request: next steps

[Inigo Barreira via dev-security-policy]

All,

Obviously this is not the message we would like to read and will try to explain 
and rebate as much as possible some of the comments posted here.

> 
> The Mozilla CA Certificates team has been considering what the appropriate
> next steps are for the inclusion request from the CA "StartCom".[0] As readers
> will know, this CA has previously been removed from trust[1], and so a re-
> application obviously involves particular scrutiny. In addition, several
> questions have been raised about the way in which the new StartCom PKI has
> been operated technically[2]. This is a proposal for the way forward, on which
> comments are invited.
> 
> Mozilla's considered view is as follows:
> 
> * It should have been obvious to StartCom that testing of their new systems
> needed to be done using a parallel testing hierarchy.

Those tests were done to check the CT behaviour, there was any other testing of 
the new systems, just for the CT. Those certs were under control all the time 
and were lived for some minutes because were revoked inmediately after checking 
the certs were logged correctly in the CTs. It´s not a mis-issuance by means of 
we didn´t know what happened, we had to investigate, etc. It was not a good 
practice and I can´t excuse for that, but it was not related to the regular 
issuance procedure as someone suggested. We provided a report in which 
indicated all that happened and what we did to not happen this again, updating 
the EJBCA roles permissions.

 
> That it was not obvious, is deeply concerning. It is also concerning that 
> someone can sit at a terminal
> and issue random certificates with variable values in lots of fields, in what 
> is
> to become a publicly-trusted hierarchy.

Well, it was possible at that time, but only the CA administrator could do it 
and under many requirements. It´s not like sitting at a terminal and start 
issuing certificates, there were and are security mechanisms to avoid "someone" 
could do that and I can list many. Probably most of the CA administrators of 
the rest of CAs  had this capacity (maybe not now) because the majority of the 
PKI software allows it and it´s needed when building a hierarchy. 
 
> It's not about numbers (e.g. "40 out of 5"), it's about the process.
> 

This number of 40 is about the total of "mis-issuances" discovered, not only 
related to these ones for the CT testing. And some other times, discussed in 
this list, the number matters. Even more, for those 40, most of them were 
"discovered" by us and acted accordingly as per the BRs. We revoked the 
majority of them within the 24 hours of being notified internally. When those 
were posted in the bugzilla, as said, most were revoked and started the 
investigation on what happened and what actions needed to be done. Some of 
these "mis-issuances" were due to some incongruencies between the BRs and the 
Mozilla policy, such as the use of different curves (allowed by the BRs but not 
for some browsers), or about pre-certificates in which is not clear if they 
fall under what requirement as a discussion started by Jeremy on the list. For 
example, is it necessary to revoke also the pre-certificates when a certificate 
is revoked? Are they need to be considered certificates and meet the BRs and/or 
Mozilla policy?
Or about the use of Unicode vs punnycode which is still under discussions, even 
a ballot failed in the CABF. So, those errors we made were also made by some 
others, and not being as an excuse, but it seems that it was not clear for the 
CAs.

We updated our procedure issuance to avoid these issues happening in mid July. 
What did we do?
- Restrict the use of eliptic curves only to those admitted by Mozilla
- Change the certificate profile for not having differences with the key 
encipherment and key agreement
- update the internal db for country codes
- update the sytems for changing all domain names to punnycode
- and recently develop a csr checking tool to avoid the issue with RSA 
parameters because EJBCA didn´t have it at that time (it comes now with the new 
release 6.9.0)


> As JC Jones wrote:
> 
> "This is a professional PKI operation, being overseen by industry veterans. If
> something as concrete as the issuance process had such a glaring quality
> assurance methodology failure, why should anyone believe that something
> much harder -- subscriber validation -- is going to be done correctly?"

Well, this is an opinion. And I fully respect but none is free of failures and 
let´s encrypt (and many others) is also having them as we´re seeing recently 
with weak keys, etc. and I´m none to say they are not professional, or not 
having a quality assurance methodology, ... or for not believing they are not 
acting correctly. For sure they are, but same as us. I can´t critize anyone and 
not because we´re in a weak position at Startcom in which everyone is looking 
deeply what we do, scrutinizing deeply.
For all these failures we acted quickly because our internal 

Re: StartCom inclusion request: next steps

[Jonathan Rudenberg via dev-security-policy]

> On Sep 14, 2017, at 04:49, Gervase Markham via dev-security-policy 
>  wrote:
> 
> We should add the existing Certnomis cross-signs to OneCRL to revoke
> all the existing certificates. As of 10th August (now a month ago)
> StartCom said they have 5 outstanding SSL certs which are valid due
> to the Certnomis cross-sign. Revoking them all by adding intermediates
> to OneCRL would therefore lead to non-negligible disruption. But these
> were issued by an org whose most recent audits are qualified, which is
> under sanction, and about whose issuance practices and process safety
> there is a reasonable amount of doubt. We may allow a grace period for
> customers to replace them with certs from a trusted provider.

I’m not yet convinced a grace period is necessary. StartCom does not list 
Firefox as a compatible browser on their website (they have the logos for 
Internet Explorer, Microsoft Edge, Android, and Windows).

Additionally, there are multiple steps in the StartCom issuance flow that 
contain the following in red text:

> Notice: 
> 1. Mozilla and Google decided to distrust all StartCom root certificates as 
> of 21st of October, 2016, meaning that since January all the SSL certificates 
> issued from that date will no longer be trusted in Firefox and Chrome newest 
> releases. 
> Besides, Google has gone further and as explained here: 
> https://security.googleblog.com/2016/10/distrusting-wosign-and-startcom.html 
> will not trust even those SSL certificates issued before that date until the 
> final disruption. 
> Apple's decision announced on Nov 30th, 2016 was to distrust all StartCom 
> root certificates as of 1st of December, meaning that SSL cert issued after 
> December 1st, 2016 will no longer be trusted in Apple’s systems. 
> 2. Any subscribers that paid the validation fee after Oct. 21st, 2016 can get 
> full refund by request. 
> 3. Currently StartCom is able to provide an interim solution for organization 
> users in case of requested. 
> Meanwhile StartCom is updating all systems and is following all requirements 
> requested by Mozilla to regain the trust in these browsers and re-apply after 
> the 6 months time penalty.

Given this explicit notification, I do not believe that subscribers would ever 
have had the expectation that their certificates would work with Firefox.

Jonathan
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