Currently, resellers are allowed to submit CSRs on behalf of their
customers and as we've seen this is open to abuse. Maybe it's time to stop
this practice and restrict submission of CSRs to CA portals only.

On Mon, Mar 5, 2018 at 12:51 PM, okaphone.elektronika--- via
dev-security-policy <[email protected]> wrote:

> On Sunday, 4 March 2018 22:44:26 UTC+1, Paul Kehrer  wrote:
> > On March 4, 2018 at 5:06:41 PM, Eric Mill via dev-security-policy (
> > [email protected]) wrote:
> >
> > <snip>
> >
> > It's also clear from the experience that rules of the road for resellers
> > are unclear, and that accountability is limited. It seems possible, or
> > likely, that other resellers may also be mishandling customer keys
> >
> > So, what would useful next steps be to improve security and
> accountability
> > for resellers?
> >
> >
> > As you already suggested an official communication requesting information
> > from the CAs about the way their reseller networks manage subscriber key
> > material would be a good start. Eventually I think it's likely that
> > resellers need to be subject to some limited form of audit (maybe as
> > simplistic as a PCI self-assessment questionnaire?). While that doesn't
> > prevent bad behavior it would generate an evidence trail for termination
> of
> > relationships with incompetent/malicious actors.
>
> I'm not sure that that would be reasonable. After all resellers can have
> resellers, and so on so where would that end? With the end user having to
> accept a "general license agreement"? And distrusting a reseller could also
> be difficult.
>
> I think it will have to be/remain the responsibility of the CA to choose
> their reselllers in such a way that "not too many questions are being
> asked" about them.
>
>
> > Of course, CAs are likely to be reluctant to share a complete list of
> their
> > resellers since they probably consider that competitive information. So,
> it
> > would be nice if we could just make it part of the CA's audits...
> >
> > One way to do that would be that the baseline requirements could be
> updated
> > to create a section defining requirements placed upon resellers
> (especially
> > around subscriber key management). This way CAs would be incentivized to
> > manage their business relationships more carefully since their business
> > partners could cause them audit issues. This has some precedent since in
> > the past some resellers acted as RAs and had their own subordinates -- a
> > practice that was terminated as they came under scrutiny and demands for
> > audits.
> >
> > Mozilla, of course, cannot amend the BRs itself. However, past evidence
> > suggests that if the Mozilla program introduces their own requirements
> > around reseller management and disclosure then the probability of a CABF
> > ballot with similar restrictions passing is relatively high (thus getting
> > it into the audit regime).
> >
> > -Paul
>
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