On Thu, 13 Sep 2018 12:26:55 -0700
Wayne Thayer via dev-security-policy
<dev-security-policy@lists.mozilla.org> wrote:

> https://wiki.mozilla.org/CA:Visa_Issues

Thanks for this list Wayne, you do a valuable task in assembling lists
like this for us to ponder.

> I would like to request that a representative from Visa engage in this
> discussion and provide responses to these issues.

And I look forward to that. Meanwhile.

For Issue D:

This looks like the problem we saw with CrossCert where nobody is
keeping proper records OR where they know the records they're keeping
are sub-par so they refuse to show them to auditors, which has much the
same effect.

There's a good chance if this CA issues a cert we later conclude was
bogus, they are unable to produce any meaningful evidence of how it
came to be issued, and we're just back to Symantec-style "We've fired
the employee who did it" which is not a basis on which we can have
confidence in the operation of the CA.


Others:

I'd also like to understand whether this CA root exists for the Web PKI
or if in fact Visa operates it for some other reason, and the issuance
of certificates valid in the Web PKI is a secondary or tertiary
function.

That is: CT logs show only a handful per month of new certificates
issued by this CA, but are there in fact more (perhaps far more) issued
that aren't for the Web PKI but are issued by this same root ?

In Bug #1315016 Visa's representative says the certificates discussed
were part of a "Visa product" as distinct from being separately
replaceable components.

To the extent that in fact trust in the Web PKI is orthogonal to Visa's
needs here, it may actually make sense for Visa to take the lead in
separating from the Web PKI rather than waiting to get kicked out of
root programmes. The reason is that we've seen previously (e.g. with
SHA-1) that financial services companies like Visa proactively choose
higher risk profiles than would be acceptable for the Web PKI. But
remaining trusted in the Web PKI means foregoing the economic
incentives for these practices - in practice this will mean Visa gets
itself needlessly into trouble, as happened for Issue C where Visa
decided it had its own "exception policy" that allowed it to violate
the root programme rules.


CT:

My understanding is that Mozilla intends for some future Firefox to do
SCT checking as Chrome does already. It appears Visa either never or
rarely logs certificates, so their sites (these names mostly belong to
Visa, to subsidiary or related organisations) would fail these checks.

It may be that if such SCT checks are in Firefox in the foreseeable
future that has the effect that these certs cease to impact on Firefox
at all. At which point, why would Mozilla keep Visa in the root trust
programme ?


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