G’day Folks, DigitalTrust first learned of the Mozilla decision via Reuters. We believe this is emblematic of Mozilla’s approach to our application which appears to have been predetermined from the outset.
We believe yesterday’s decision is unfair and demonstrates an anti-UAE bias where a 2016 media report referring to a single claimed event that aims to falsely implicate DarkMatter (and repeatedly echoed over a span of 4 years) has now outranked Mozilla’s established process of demonstrated technical compliance. This very same compliance has been met by DigitalTrust for three consecutive years with full transparency. The emerging principle here seems to be that 508 WebTrust audit controls are not sufficient to outweigh a single media allegation referring to work we as well as DarkMatter simply don’t do. In fact DarkMatter’s work is focused on the exact opposite of the false claim as evidenced by the continuous work to protect all internet users, for example through on-going disclosure of zero day vulnerabilities to the likes of Cisco, Sony, ABB and others. Mozilla’s new process, based on its own admission, is to ignore technical compliance and instead base its decisions on some yet to be disclosed subjective criterion which is applied selectively. We think everybody in the Trust community should be alarmed by the fact that the new criterion for inclusion of a commercial CA now ignores any qualification of the CA or its ability to demonstrate compliant operations. We fear that in doing so Mozilla is abandoning its foundational principles of supporting safe and secure digital interactions for everyone on the internet. This new process change seems conveniently timed to derail DigitalTrust’s application. By Mozilla’s own admission, DigitalTrust is being held to a new standard which seems to be associated with circular logic – a media bias based on a single claimed event that aims to falsely implicate DarkMatter is then used to inform Mozilla’s opinion, and the media seizes on this outcome to substantiate the very same bias it aimed to introduce in the first place. Additionally, in targeting DigitalTrust and in particularly DarkMatter’s founder Faisal Al Bannai, on the pretense that two companies can’t operate independently if they have the same owner, we fear another dangerous precedent has been set. What’s at stake here is not only denial of the UAE’s Roots but also Mozilla’s denial of the UAE’s existing issuing CAs. This means the nation’s entire Public Trust customer base is now denied the same digital protections that everyone else enjoys. We fear that Mozilla’s action to apply this subjective process selectively to DigitalTrust effectively amounts to incremental tariffs on the internet with Mozilla de-facto promoting anti-competitive behavior in what was once a vaunted open Trust community. Mozilla is now effectively forcing the UAE to protect its citizens by relying on another nation or commercial CA – despite DigitalTrust meeting all of Mozilla’s previously published criteria – thus protecting a select number of operators and excluding or forcing newcomers to pay a premium without the added benefit of control. In conclusion we see only two possible paths going forward. Under the first path, we demand that Mozilla’s new standard be explicitly disclosed and symmetrically applied to every other existing member of the Mozilla Trust Program, with immediate effect. This would cover, based on the precedent of the DigitalTrust case, any CA deemed to be a risk to the Trust community, despite lacking substantive evidence. This would suggest that any CA that serves a national function, is working closely with governments to secure the internet for its citizens, or is associated to other practices covering cyber security capabilities (which would include a large group of countries and companies) would have to be removed. Under the second path, we call on Mozilla to honor its founding principles outlined in its Manifesto that ‘individuals’ security and privacy on the internet are fundamental and must not be treated as optional’. We firmly believe this applies to citizens and residents of the UAE and we demand that Mozilla reverses its decision. In following the second path, Mozilla can right yesterday’s wrong that inspires little confidence in the due process applied in the case of DigitalTrust as it seems to favor a subjective criterion based on a falsely established bias at the expense of rigorous technical controls and policy compliance. In reversing its decision, Mozilla can fulfil its core purpose to protect individual security and privacy on the Internet – in this case for UAE citizens - by enabling the UAE Roots as trusted in their products. And finally, by reversing its decision, Mozilla can find a path back to a balanced and objective approach that will demonstrate integrity to the world and the Trust community. Regards, -Scott On 7/9/19, 7:31 PM, "dev-security-policy on behalf of Wayne Thayer via dev-security-policy" <dev-security-policy-boun...@lists.mozilla.org on behalf of email@example.com> wrote: Caution: This email originated from outside DarkMatter. Do not click links or open attachments unless you recognize the sender and believe the content is safe. ------------------------------------------------------------------------------ I would like to thank everyone for their constructive input on this difficult issue. I would also like to thank DarkMatter representatives for participating in the open, public discussion. I feel that the discussion has now, after more than 4 months, run its course. The question that I originally presented  to this community was about distrusting DarkMatter’s current intermediate CA certificates (6 total) based on credible evidence of spying activities by the company. While a decision to revoke trust in these intermediates would likely result in a denial of DarkMatter’s root inclusion request , the public discussion for that request has not yet begun. A decision not to revoke these intermediates does not necessarily mean that the inclusion request will be approved. Some of this discussion has revolved around compliance issues, the most prominent one being the serial number entropy violations discovered by Corey Bonnell. While these issues would certainly be a consideration when evaluating a root inclusion request, they are not sufficient to have triggered an investigation aimed at revoking trust in the DarkMatter intermediates or QuoVadis roots. Therefore, they are not relevant to the question at hand. Much of the discussion has been about the desire for inclusion and distrust decisions to be made based on objective criteria that must be satisfied. However, if we rigidly applied our existing criteria, we would deny most inclusion requests. As I stated earlier in this thread, every distrust decision has a substantial element of subjectivity. One can argue that we’re discussing a different kind of subjectivity here, but it still amounts to a decision being made based on a collective assessment of all the information at hand rather than a checklist. Some, including DarkMatter representatives , have declared the need to examine and consider the benefits of having DarkMatter as a trusted CA. However, last year we changed our policy to replace the weighing of benefits and risks with “based on the risks of such inclusion to typical users of our products.”  Perhaps the most controversial element in this discussion has been the consideration of “credible evidence”. The first component is the inherent uncertainty over what is “credible”, especially in this day and age. While it has been pointed out that respected news organizations are not beyond reproach , having four independent articles  from reputable sources published years apart does provide some indication that the allegations are credible. These articles are also extensively sourced. If we assume for a second that these allegations are true, then there is still a sincere debate over what role they should play in our decision to trust DarkMatter as a CA. The argument for considering these allegations is akin to the saying “where there’s smoke there’s fire”, while the argument against can be described as “innocent until proven guilty”. DarkMatter has argued  that their CA business has always been operated independently and as a separate legal entity from their security business. Furthermore, DarkMatter states that once a rebranding effort is completed, “the DarkMatter CA subsidiary will be completely and wholly separate from the DarkMatter Group of companies in their entirety.” However, in the same message, DarkMatter states that “Al Bannai is the sole beneficial shareholder of the DarkMatter Group.” and leaves us to assume that Mr. Al Bannai would remain the sole owner of the CA business. More recently, DarkMatter announced that they are transitioning all aspects of the business to DigitalTrust and confirmed that Al Bannai controls this entity. This ownership structure does not assure me that these companies have the ability to operate independently, regardless of their names and legal structure. Mozilla’s principles should be at the heart of this decision. “The Mozilla Manifesto  states: Individuals’ security and privacy on the internet are fundamental and must not be treated as optional.” And our Root Store policy states: “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.” In other words, our foremost responsibility is to protect individuals who rely on Mozilla products. I believe this framing strongly supports a decision to revoke trust in DarkMatter’s intermediate certificates. While there are solid arguments on both sides of this decision, it is reasonable to conclude that continuing to place trust in DarkMatter is a significant risk to our users. I will be opening a bug requesting the distrust of DarkMatter’s subordinate CAs pending Kathleen’s concurrence. I will also recommend denial of the pending inclusion request, and any new requests from DigitalTrust. In the past, we’ve seen CAs attempt to make an end run around adverse trust decisions - through an acquisition, a shell company, etc. We will treat any such attempt as a violation of this decision and act accordingly. Mozilla does welcome DigitalTrust as a “managed” subordinate CA under the oversight of an existing trusted CA that retains control of domain validation and the private keys. This discussion has highlighted an opportunity to improve our review of new externally-operated subordinate CAs . This issue  is part of the current policy update discussions. Wayne  https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/YiybcXciBQAJ  https://bugzilla.mozilla.org/show_bug.cgi?id=1427262  https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/mJ0EV2eoCgAJ  https://groups.google.com/d/msg/mozilla.dev.security.policy/58F6FgeGOz8/Zzb-r76wBQAJ  https://www.washingtonpost.com/blogs/erik-wemple/wp/2018/11/27/bloomberg-is-still-reporting-on-challenged-story-regarding-china-hardware-hack/  https://theintercept.com/2016/10/24/darkmatter-united-arab-emirates-spies-for-hire/  https://www.reuters.com/investigates/special-report/usa-spying-raven/  https://www.nytimes.com/2019/03/21/us/politics/government-hackers-nso-darkmatter.html  https://theintercept.com/2019/06/12/darkmatter-uae-hack-intercept/  https://www.mozilla.org/en-US/about/manifesto/  https://ccadb-public.secure.force.com/mozilla/IntermediateCertsSeparateAudits  https://github.com/mozilla/pkipolicy/issues/169 _______________________________________________ dev-security-policy mailing list firstname.lastname@example.org https://lists.mozilla.org/listinfo/dev-security-policy _______________________________________________ dev-security-policy mailing list email@example.com https://lists.mozilla.org/listinfo/dev-security-policy