On 14/11/16 15:31, Peter Bowen wrote:
> 1) Auditors are not required to witness key generation ceremonies for
> non-Root CA keys when the new CA is operated by the same entity as the
> parent CA.
> 2) There is no requirement that the binding between CA distinguished name
> and key pair occur during the key generation ceremony
> 3) There is no requirement that each CA have a unique key pair.
> 
> Combine all three of these and there are multiple paths to easy TCSC
> creation.

OK, makes sense, thank you.

Does anyone think that any of these 3 lack-of-requirements presents a
risk? I can't see one immediately but it's worth asking the question.

Gerv

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