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 dev-security-policy@lists.mozilla.org> 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.
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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 [1] 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 [2], 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 [3], 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.” [4]
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 [5], having four independent articles [6][7][8][9] 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 [3] 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 [10] 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 [11]. This issue [12] is part of the
current policy update discussions.
Wayne
[1]
https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/YiybcXciBQAJ
[2] https://bugzilla.mozilla.org/show_bug.cgi?id=1427262
[3]
https://groups.google.com/d/msg/mozilla.dev.security.policy/nnLVNfqgz7g/mJ0EV2eoCgAJ
[4]
https://groups.google.com/d/msg/mozilla.dev.security.policy/58F6FgeGOz8/Zzb-r76wBQAJ
[5]
https://www.washingtonpost.com/blogs/erik-wemple/wp/2018/11/27/bloomberg-is-still-reporting-on-challenged-story-regarding-china-hardware-hack/
[6]
https://theintercept.com/2016/10/24/darkmatter-united-arab-emirates-spies-for-hire/
[7] https://www.reuters.com/investigates/special-report/usa-spying-raven/
[8]
https://www.nytimes.com/2019/03/21/us/politics/government-hackers-nso-darkmatter.html
[9] https://theintercept.com/2019/06/12/darkmatter-uae-hack-intercept/
[10] https://www.mozilla.org/en-US/about/manifesto/
[11]
https://ccadb-public.secure.force.com/mozilla/IntermediateCertsSeparateAudits
[12] https://github.com/mozilla/pkipolicy/issues/169
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