G’day Folks,
 
As previously discussed on this thread, the DarkMatter Trust Services practice 
(including DarkMatter CAs) has been operated in a separate entity to the DM 
Group, that entity is Digital Trust – Sole Proprietorship L.L.C. 
(“DigitalTrust”) which was established in the United Arab Emirates in 2016.  
DigitalTrust is an affiliate of the DM Group.  It was setup by the parent 
company to exclusively provide the Trust related business and has never been 
owned by DarkMatter LLC as a subsidiary since its incorporation. Up till now 
however, DarkMatter LLC has been involved in facilitating aspects of the Trust 
business, because we had some challenges with the trademarking of the 
independent entity’s original name etc. and it became more efficient to utilize 
the DM entity so as to not delay hiring and contracts etc. for the roll out of 
UAE NPKI services. We have now finalized that issue and will be transitioning 
all aspects of what has been known to the public as DM Trust Services 
(including DarkMatter CAs etc.) to the independent company DigitalTrust. All 
contracts for the CA Business are in the process of being novated over to 
DigitalTrust.
 
DigitalTrust is headed by myself, and I am the key individual responsible for 
management of the CA Business within Digital Trust. The shareholder of Digital 
Trust is DM Investments, and the beneficial owner of DM Investments is Mr. 
Faisal Al Bannai.  Although Legal Ownership of the CA Business is changing (per 
Section 8.1 of the Mozilla Root Policy), the Operational Personnel (Section 
8.2) and Secure Location (Section 8.3) for infrastructure are not changing – it 
is still my team who are the operators and only folks with control of Key 
material. My team consists of professionals from many nations:  Director of 
Networks & Security Infrastructure is from USA; Director of Registration 
Authority and Technical Support is from Sweden; Sr PKI Architect is from 
Portugal; Sr Manager of CA Platform is from USA; other key personnel are from 
Ecuador, India, Philippines, and Belarus. These folks have all re-located here 
to the UAE to be a part of the DigitalTrust CA services.
 
From a program management perspective, the Policy Authority Board for 
DigitalTrust remains the same as it was previously – this consists of 
representation from four key areas of our business services: 1. PKI & 
Technology Expert, 2. Legal Expert, 3. Policy & Risk/Governance Expert, 4. 
Security Expert.
 
DigitalTrust is a private entity that has been engaged by the UAE Government to 
build, operate and maintain – on the Governments behalf – the necessary 
components of a National PKI. The Telecommunications Regulatory Authority (TRA) 
is the relevant authority within the UAE Government for regulatory oversight 
and leadership of the UAE National PKI program, but DigitalTrust has been 
engaged with the following responsibilities:
-          Operation of the NPKI technical infrastructure
-          Advisory services for governance activities
-          Representing the NPKI in Industry Working groups and relevant Trust 
Communities
-          Fulfill compliance and regulatory responsibilities for the NPKI 
operations
 
DigitalTrust will now become the point of contact for the UAE Global Root 
submissions.
 
DigitalTrust would also like withdraw the DarkMatter Root submissions 
previously provided and will replace these with new DigitalTrust Roots that we 
will use as the basis of trust for our commercial business going forward.
 
These actions will be reflected in the data contained in the CCADB.
 
Please advise if additional information relating to this change is required.
 
If anyone has any questions regarding this matter, please do not hesitate to 
contact me.


Regards,
-- 
Scott Rea


On 3/19/19, 10:25 AM, "dev-security-policy on behalf of Scott Rea via 
dev-security-policy" <dev-security-policy-boun...@lists.mozilla.org on behalf 
of dev-security-policy@lists.mozilla.org> wrote:

    G’day Folks,
    
    It was a pleasure meeting many of the Mozilla community face to face at the 
CAB Forum meeting at Apple HQ last week. There are many others of you however, 
whose interface to the community is right here on this list, and so I wanted to 
share my perspective and feedback here on the recent dialogue so that the 
openness and transparency of the community is preserved.
    
    Over the past few weeks, there’s been much debate and shared points of view 
around DarkMatter’s multi-year process to have our CA Roots included in 
Mozilla’s Root Store. Who could have predicted that along the way, the 
community would have such wide-spread impact from the serialNumber entropy 
issue? I do think the BRs are a little ambiguously worded in this regards, and 
this is what certainly tripped us up, but upon learning what was intended by 
the standard, DarkMatter has completed its revocation of every still valid 
affected TLS certificate (~175), and we actioned that immediately, completing 
the process over about 72 hrs (timing over the week-end in the UAE was not 
optimal for us otherwise we could have completed it sooner). We still need to 
re-issue the Issuing CAs and submitted Roots – these are dependent on the 
availability of our WebTrust Auditors, but we expect this to be finalized in 
the next week or so.
    
    Many others in the community are also evaluating replacement of affected 
certificates e.g. see [1] [2] [3], etc. But the volumes these organizations are 
dealing with will make it difficult to meet BR revocation timelines, which is 
why I think Mozilla’s recent acknowledgement of this challenge with a proposal 
for an updated best practice for revocation is the right discussion to have. 
    
    I think this is where the community is at its best: working together to 
identify and manage issues, learning from each other in how best to take action 
and resolving it as quickly as possible while maintaining the security and 
integrity of services for end users. After all, we ultimately share the same 
goal: transparent community-based processes that promote participation, 
accountability and trust [4].  
    
    Resolving this issue together is a good example of this principle in action.
    
    As I reflect on the many discussions in this community, and also with the 
40-odd companies at last week’s CA/B Forum, it is clear that there is quite an 
interest in the DarkMatter story. Unfortunately, the one that has often been 
promoted as evidence in this community – is one that is not based on truth, and 
one that has consistently been refuted by DarkMatter.  I would like to set the 
record straight once and for all, and share with all of you why DarkMatter’s 
story is not what some have claimed, but is, I believe, actually completely 
aligned with Mozilla’s own manifesto. 
    
    DarkMatter Group was founded by Faisal Al Bannai, one of the most 
accomplished business leaders in the Middle East [5], as a commercial business 
entity that specializes in Cyber Security services, and solutions.  Al Bannai 
served as CEO and founder until recently (2018), when he handed over the 
leadership role of the company to Karim Sabbagh, formerly the CEO of the world 
leading satellite fleet operator SES [6].  Al Bannai is the sole beneficial 
shareholder of the DarkMatter Group.  The CA business that I head within the 
DarkMatter Group, and which I will provide further details below, is a 
completely independent business unit housed in a legally separate subsidiary 
company.
    
    The general business of the DarkMatter Group is all centered around 
cybersecurity. DarkMatter is very active in our local constituency [7], [8], 
[9], we have even developed and launched our own mobile phone [10]. The 
Cybersecurity divisions of DarkMatter are fully engaged in and participate in 
identifying and disclosing malicious applications that attack the security and 
privacy of individuals everywhere.  Some recent examples of this are where 
DarkMatter researchers identified and informed Google of a malicious 
application available on the Google play store [11], and DarkMatter researchers 
also made a responsible disclosure to Apple of a significant attack that 
“bypasses all native macOS security measures”, (which findings were also 
presented at Hack-In-the-Box conference in Singapore [12]. This just highlights 
a couple.
    
    For those who have questioned who is really in the driving seat of the 
DarkMatter CAs, I want to assure you that DarkMatter’s PKI business has always 
been operated independently. We are a legally separate entity – housed under a 
subsidiary of the DarkMatter Group. Only myself and my handpicked team ever 
have hands on key material, and no single individual can effect an issuance 
without the validation of a counterpart and always under multiparty and 
multifactor authentication.  We have stringent controls around who is eligible 
to hold a trusted role, and they must continue to meet operational KPIs, 
training and risk evaluation metrics to remain in their role. These are 
validated via process review and audit. 
    
    It’s worth noting why DarkMatter decided to launch our commercial CA three 
years ago - because citizens, residents and visitors to the UAE currently don’t 
have access to local providers who can provide them with digital protections 
all in local dialect and with local support - these are things perhaps taken 
for granted in other parts of the world.  We recognized this and want to make 
sure our community has the same digital protections as everyone else because 
every nation deserves the right to build secure, trusted digital environments 
for the benefit of its citizens. As the operator for the UAE National PKI, 
acceptance of the UAE Global Roots is critical for this nation that is at the 
forefront of driving deployment of smart cities but where only 32% of its 
websites are protected compared to the 65% enjoyed by the rest of the world. 
    
    At DarkMatter, we are committed to ensuring that all HTTP traffic is 
transitioned to HTTPS nation-wide, and region-wide where we can provide 
service. As we work towards the resolution of this issue, it is a good example 
of the principle in action: where individuals’ security and privacy on the 
internet are fundamental and must not be treated as optional [13].
    
    As part of our long-term plan, our certificates will shortly be issued from 
CA’s chaining to Roots of the independent PKI subsidiary – which is currently 
undertaking a rebranding exercise (the original name attracted too many cyber 
squatters).  Once the branding is complete, the DarkMatter CA subsidiary will 
be completely and wholly separate from the DarkMatter Group of companies in 
their entirety, and operations will continue under this independent entity. 
Although we have been planning this for some time, we are expediting the 
process now as the serial number issue has brought about an opportunity to 
rename the DM Roots as we re-issue them. 
    
    The DarkMatter CA subsidiary, is the fourth commercial CA that I have 
contributed my services to for different companies over the course of my 20 
years in this industry.  Over that time, as now, I have seen that the 
commercial involvement in the development of the internet brings many benefits 
and a balance between commercial profit and public benefit is critical [14]. 
The fact that the UAE has decided to outsource the operations of its National 
PKI to a private entity, is I think is clear acknowledgement that the 
principles of trust and transparency don’t change, and it is best accomplished 
by those who have demonstrated expertise. I therefore believe that a sovereign 
UAE CA is a good example of the principle in action where the public benefit to 
digitally securing the nation is overwhelming, especially with the UAE 
experiencing a higher risk of suffering cyber-attacks.  Together we have an 
opportunity to make a real difference in this part of the world and this is 
what I am passionate about and why I’ve been doing this work here for the past 
three years.
    
    Of course underpinning the benefits to the UAE and the rest of the world is 
having free and open source software that promotes the development of the 
internet as a public resource [15]. This goes beyond any company’s direct 
commercial interests and I am committed to working with the community to 
demonstrate this principle in action and the part we can all play in advancing 
a safe and secure internet that is open and accessible to all [16]. I 
understand that today the Mozilla community is not taking advantage of the CT 
Logs as much as other browsers are. Submitting all our TLS certificates to CT 
Logs has been a key initiative of our CA to demonstrate transparency in all 
that we are doing. I would be happy for my team to contribute code back to the 
open source community for validating TLS connections based on CT log data, so 
that FireFox and other Mozilla products have more options for verifying the 
work that we, and other CAs, are doing.
    
    No one is an island in this business of trust – we all swim in the same 
ocean. There should be consistent controls applied for all trust operators and 
I think our current environment of standards communally developed by CAB Forum 
and also codified in the Mozilla Root Store Policy help ensure that. We are 
committed to trust everywhere on the internet and here at the DarkMatter CA, we 
are working to ensure that protections are in place for our local community 
commensurate with the rest of the world. We intend to take a more active role 
in the Mozilla community and are pleased that our goals and objectives are so 
closely aligned.
    
    I hope that in future we can continue to move forward DarkMatter related 
discussions based on fact and transparency. These principles are not only 
necessary, but critical to ensuring the integrity of the trust community that 
Mozilla has built.
     
    Refs:
    1.  
https://www.thesslstore.com/blog/mass-revocation-millions-of-certificates-revoked-by-apple-google-godaddy/
    2.  
https://www.zdnet.com/article/apple-google-godaddy-misissued-tls-certificates-with-weak-serial-numbers/
    3.  https://www.theregister.co.uk/2019/03/13/tls_cert_revoke_ejbca_config/
    4.  https://www.mozilla.org/en-US/about/manifesto/ Principle 8: Transparent 
community-based processes promote participation, accountability and trust
    5.  
https://www.arabianbusiness.com/lists/392531-100-inspiring-leaders-in-the-middle-east-94faisal-al-bannai
    6.  https://spacenews.com/ses-sabbagh-takes-ceo-job-at-uae-cyber-firm/
    7.  
https://gulfnews.com/technology/darkmatter-named-expo-2020s-cybersecurity-solutions-provider-1.2246547
    8.  http://www.itp.net/618203-blockchain-breaks-new-ground-at-gitex
    9.  
https://www.prnewswire.com/news-releases/darkmatter-introduces-blockchain-solutions-for-governments-and-enterprises-in-the-uae-597226021.html
    10. https://www.darkmatter.ae/KATIM/ 
    11.  
https://www.darkmatter.ae/blogs/darkmatter-identifies-app-stealing-personal-information/
 
    12. 
https://www.forbes.com/sites/thomasbrewster/2018/08/30/apple-mac-loophole-breached-in-middle-east-hacks/#7791c17a6fd6
    13. https://www.mozilla.org/en-US/about/manifesto/ Principle 4: 
Individuals’ security and privacy on the internet are fundamental and must not 
be treated as optional
    14. https://www.mozilla.org/en-US/about/manifesto/ Principle 9: Commercial 
involvement in the development of the internet brings many benefits; a balance 
between commercial profit and public benefit is critical
    15. https://www.mozilla.org/en-US/about/manifesto/ Principle 7: Free and 
open source software promotes the development of the internet as a public 
resource
    16. https://www.mozilla.org/en-US/about/manifesto/ Principle 2: the 
internet is a global public resource that must remain open and accessible
    
    
    Regards,
     
    
    -- 
    
    Scott Rea
    
    On 3/6/19, 11:15 PM, "dev-security-policy on behalf of Kathleen Wilson via 
dev-security-policy" <dev-security-policy-boun...@lists.mozilla.org on behalf 
of dev-security-policy@lists.mozilla.org> wrote:
    
        All,
        
        Thank you to those of you that have been providing thoughtful and 
        constructive input into this discussion. I have been carefully reading 
        and contemplating all of the messages posted in the 
        mozilla.dev.security.policy forum.
        
        As the owner of Mozilla’s CA Certificates Module[1] and in an effort to 
        respond to Matthew’s concerns about transparency[2], I would like to 
        share my current thoughts about DarkMatter’s intermediate certificates 
        and root inclusion request. I will make a decision after this 
discussion 
        has run its full course.
        
        I appreciate that representatives of DarkMatter are participating in 
        this discussion, and reiterate that I have not yet come to a decision. 
I 
        would also like to remind everyone that we have not yet started the 
        public discussion phase of DarkMatter’s root inclusion request. This 
        discussion is separate from Mozilla’s root inclusion process, but will 
        determine if the process will continue for DarkMatter’s root inclusion 
        request. If this discussion concludes that DarkMatter’s intermediate 
        certificates should be added to OneCRL, then the root inclusion request 
        will be closed. However, if this discussion concludes that DarkMatter’s 
        intermediate certificates should not be added to OneCRL, then 
        DarkMatter’s root inclusion request will continue to follow the normal 
        process.
        
        == Regarding DarkMatter’s current intermediate certificates ==
        
        The current DarkMatter intermediate certificates are not constrained or 
        technically controlled by the parent CA, as was confirmed by a 
        representative of DigiCert[3]. This means that currently DarkMatter has 
        all of the certificate issuance capability of a root certificate that 
is 
        directly included in Mozilla’s root store. This is why we are having 
        this discussion to determine if DarkMatter’s current intermediate 
        certificates should be added to OneCRL.
        
        In my opinion, there are other options for DarkMatter. For example, a 
CA 
        who is currently included in Mozilla’s program such as Digicert, could 
        issue DarkMatter new intermediate certificates that are owned and 
        controlled by DigiCert and for which DigiCert performs additional 
domain 
        validation before issuance of end-entity certs in that CA hierarchy. I 
        think that an option like this would provide sufficient oversight of 
        DarkMatter’s certificate issuance, if we decide to add DarkMatter’s 
        current intermediate certificates to OneCRL.
        
        == Regarding DarkMatter’s root inclusion request ==
        
        Since I began working on Mozilla’s CA Program in 2008 I have rarely 
seen 
        this much interest and opinions from the media and general public on 
        root inclusion requests, even though all of our process is performed in 
        the open[4]  and includes a public discussion phase[5]. In my opinion, 
        we should pay attention to the messages we're receiving, and subject 
        this CA to additional scrutiny.
        
        As others have already pointed out[6] DarkMatter’s root inclusion 
        request is reminiscent of CNNIC’s root inclusion request in 2009 [7] 
and 
        their request to include an additional root in 2012 [8]. As Ryan 
        reminded us[9] in his excellent analysis, the decisions about the 
        inclusion of the CNNIC root certificates was based on “a rigid 
        application of policy”. In one of my posts[10] about CNNIC’s root 
        inclusion requests I stated:
        “There was a lot of discussion about government, politics, legal 
        jurisdiction, what-if scenarios, and people’s opinions about the 
Chinese 
        government. While I sympathize with people’s feelings about this, 
        Mozilla’s root program is based on policy and evidence. While CNNIC has 
        provided all of the required information to demonstrate their 
compliance 
        with Mozilla’s CA Certificate Policy, no usable evidence has been 
        provided to show non-compliance with Mozilla’s CA Certificate Policy.”
        
        As we all know, in 2015 Mozilla revoked trust in CNNIC certificates[11] 
        after discussion[12] in this forum regarding the discovery that an 
        intermediate CA under the CNNIC root was used to mis-issue TLS 
        certificates for some domains, and subsequently used for MiTM. In that 
        case, rigid application of the policy left our users at risk. This was 
        an important learning experience for us.
        
        Root inclusion requests rarely receive this much attention. Another one 
        that we have been reminded of is TeliaSonera’s root inclusion 
        discussion[13], in which I stated: “Typically this would have been 
        considered a very standard request, but this discussion turned into a 
        political sounding board. Approval of this root-renewal request means 
        that the CA complies with Mozilla’s CA Certificate Policy and provides 
        annual audit statements attesting to their compliance. It in no way 
        reflects my opinion, or that of Mozilla, on the actions of the owner of 
        the CA in regards to their non-CA related businesses and practices.”
        
        Unlike CNNIC, TeliaSonera still has root certificates in Mozilla’s root 
        store. Similar to many CAs in our program, TeliaSonera has had some 
        compliance problems[14], but (to my knowledge) no evidence has been 
        provided of TeliaSonera knowingly issuing certificates without the 
        knowledge of the entities whose information is referenced in the 
        certificates, or knowingly issuing certificates that appear to be 
        intended for fraudulent use. TeliaSonera’s reported compliance problems 
        have not yet been deemed to be egregious enough to warrant removal of 
        their root certificates. Therefore, it is not as simple as saying that 
        this DarkMatter root inclusion request seems similar to the CNNIC 
        situation, so we should not approve DarkMatter’s root inclusion request.
        
        However, I believe that the CNNIC experience is a valuable lesson that 
        should be taken into account when making a decision on DarkMatter. 
        During CNNIC’s root inclusion process, the community expressed grave 
        concerns about the company based on credible reports that they had been 
        involved in interception and surveillance of web traffic, including 
        providing malware products to others such as their government. Even 
with 
        these credible news reports, the community was unable to obtain 
        technical evidence of intentional certificate mis-issuance, so I 
        approved their root inclusion request. In essence this meant ignoring 
        the evidence that had been provided because I deemed that it was not 
        directly applicable to the policy requirements for being a CA in our 
        program. However, it wasn’t until much later that there was sufficient 
        evidence to remove the CNNIC’s root certificate. Therefore, we should 
        not ignore credible news reports regarding DarkMatter.
        
        Matthew correctly stated[15] that he “can not recall use of subjective 
        discretion to deny admission to the program.” As demonstrated in both 
        the CNNIC and TeliaSonera requests I have always tried to be as 
        objective as possible in regards to root inclusion requests. However, 
as 
        Ryan pointed out[16] “the program is, and has always been, inherently 
        subjective and precisely designed to support discretionary decisions.” 
        And Wayne said[17]: “A stronger argument along these lines is that we 
        have plenty of CAs, so there is no good reason to take a risk on one 
        that we lack confidence in.” I do not believe that we should take a 
        certain action just because it is what we have always done. And we 
        should use all of the information that is available to us in analyzing 
        the risk that comes with including new root certificates, even if that 
        means the decision is more subjective than previous decisions. The 
        ultimate purpose of our transparency and our standards is to bolster 
        trust in our CA program. Ignoring information that doesn’t fall within 
        strict criteria does not serve that purpose.
        
        Mozilla’s root store policy[18] says: “We will determine which CA 
        certificates are included in Mozilla's root program based on the risks 
        of such inclusion to typical users of our products.” To me this means 
        that if the risks of including a root certificate appear to outweigh 
the 
        benefits, then we should deny the root inclusion. There are credible 
        reports from multiple sources[19] providing reason to not trust the 
        DarkMatter organization to issue TLS certificates without constraints. 
I 
        think that the decision about DarkMatter should consider if the risk of 
        including DarkMatter’s root certificates outweighs the potential 
benefit 
        to consumers of Mozilla’s root store.
        
        As always, I continue to appreciate your thoughtful and constructive 
input.
        
        Thanks,
        Kathleen
        
        [1] https://wiki.mozilla.org/Modules/All#CA_Certificates
        [2] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/hi3WDHlYAgAJ
        [3] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/I8CYOScMBgAJ
        [4] https://wiki.mozilla.org/CA/Dashboard
        [5] 
https://wiki.mozilla.org/CA/Application_Verification#Public_Discussion
        [6] 
        
https://www.eff.org/deeplinks/2019/02/cyber-mercenary-groups-shouldnt-be-trusted-your-browser-or-anywhere-else
        [7] https://bugzilla.mozilla.org/show_bug.cgi?id=476766
        [8] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/QEwyx6TQ5TM/qzX_WsKwvIgJ
        [9] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/rNWEMEkUAQAJ
        [10] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/QEwyx6TQ5TM/c3GXKsASCX4J
        [11] 
        
https://blog.mozilla.org/security/2015/04/02/distrusting-new-cnnic-certificates/
 
        
        [12] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/czwlDNbwHXM/Fj-LUvhVQYEJ
        [13] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/mirZzYH5_pI/5LJ-X-XfIdwJ
        [14] https://wiki.mozilla.org/CA/Incident_Dashboard
        [15] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/ew5ZnJtVAgAJ
 
        
        [16] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/IfewIb0hAgAJ
        [17] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/joyWkf5TAgAJ
        [18] 
        
https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/
 
        
        [19] 
        
https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/YiybcXciBQAJ
 
        
        
        
        
        
        
        
        
        
        
        
        
        
        
        
        
        
        
        
         
    
    Scott Rea | Senior Vice President - Trust Services 
    Tel: +971 2 417 1417 | Mob: +971 52 847 5093
    scott....@darkmatter.ae
    
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in error, please contact the sender and destroy any copies of this information.
    
     

Scott Rea | Senior Vice President - Trust Services 
Tel: +971 2 417 1417 | Mob: +971 52 847 5093
scott....@darkmatter.ae

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