In my personal capacity, as I review the published facts that exist here, 
there are a few broad things from a BR perspective that stand out to me:

   - 
   
   All CAs are required to have incident response and compromise handling 
   procedures. The timeline presented in Ian’s post suggests that no such 
   plan exists, the plan that exists is insufficient, or the plan is not 
   staffed.
   

   - 
   
   All CAs are required to perform an annual Risk Assessment. The existence 
   of administrative consoles on the internet, default administrative 
   passwords being in use, and the ability to in an uncontrolled fashion add 
   new administrative users tells us this either is not happening or is being 
   performed by individuals with zero understanding of security.
   

   - 
   
   All CAs are required to perform an annual penetration test. The 
   existence of these trivial issues suggests that either this was not 
   happening or it was being performed by individuals with zero understanding 
   of security.
   
While PKI-related auditors tend to have a limited understanding of PKI and 
security, in all my time in this industry they have always demonstrated an 
understanding of IT accounting principles that would be sufficient to 
identify these trivial deficiencies.

I would go so far as to say that these are such basic issues the fact that 
e-Turga has continually been able to acquire a sufficiently clean audit 
report to stay within the various programs suggests either a disqualifying 
skill deficiency or an integrity issue related to the auditing firms.

I also think this incident shows that the current root program requirements 
and BRs are too generous when it comes to trusting CAs to implement 
reasonable incident response procedures.

Some things that should be considered moving forward include:

   1. 
   
   Requiring the availability of a documented method for reporting security 
   concerns.
   2. 
   
   Requiring a minimum response time for the initial response to these 
   reports.
   3. 
   
   Requiring that the final disposition of these reports be communicated to 
   the reporter.
   4. 
   
   Requiring that subscribers be notified of any compromises to the 
   certificate management-related systems.
   5. 
   
   Today only issues related to a security issue requiring revocation of an 
   intermediate or cert chaining to a trusted root require the creation of a 
   bug in Bugzilla, this should be expanded to minimally include compromise of 
   any certificate management-related system.
   6. 
   
   Requiring that all security incidents be summarized in some reasonable 
   detail and made available in CCADB for root program administrators.
   7. 
   
   Requiring the identification of who performed the penetration testing, a 
   summary of what was assessed, and a summary fo their findings.
   
I also believe a common theme in CA failures like these is the lack of 
qualifications and independence of the auditors and security professionals 
used to assess the correctness and conformance of the systems. 

I don’t know how best to address this but this incident also seems to 
suggest that the requirement to use a “qualified auditor” and penetration 
testers with the “skills, tools, proficiency, code of ethics, and 
independence” is not sufficient.


Ryan Hurst

(Personal Capacity)



On Thursday, November 17, 2022 at 2:51:29 PM UTC-8 [email protected] wrote:

> The major issues mentioned in the post are resolved after I notified 
> e-Tugra of them. 
>
> It is important to note that I did not perform an extensive amount of 
> testing of e-Tugra’s systems, given I do not speak Turkish and I found 
> enough issues as it is. Until e-Tugra undertakes a comprehensive security 
> test of their systems, I would assume there are still other vulnerabilities 
> present somewhere else.
>
> On Thu, Nov 17, 2022 at 2:42 PM Kurt Seifried <[email protected]> wrote:
>
>>
>>
>> On Thu, Nov 17, 2022 at 2:59 PM ke ju <[email protected]> wrote:
>>
>>> I agree that something should be done swiftly. If you did this, who else 
>>> could have. Also, has the authority been notified, and have they simply 
>>> changed the passwords yet? Ie could a threat actor watching this list now 
>>> go there and get into the system after the disclosure
>>>
>>
>> To be clear, I'm not the original reporter. They also posted to the old 
>> list which is why I cross-posted it. 
>>  
>> Their blog entry has a timeline:
>>
>>
>>    - Nov 13, 2022 4:10: Initial contact to e-Tugra about administrative 
>>    systems
>>    - Unknown: Administrative systems no longer reachable on the internet
>>    - Nov 13, 2022 18:50: Second set of issues reported to e-Tugra, 
>>    follow-up on initial issues that appeared fixed
>>    - Nov 14, 2022 8:35: Initial reply from e-Tugra saying they are 
>>    working on resolution
>>    - Nov 14, 2022 17:18: Asked how to report security issues in the 
>>    future
>>    - Nov 16, 2022 22:52: Notified e-Tugra of impending disclosure
>>    - Nov 17, 2022: Disclosed this post
>>
>>
>>
>>> On Thursday, November 17, 2022 at 12:52:37 PM UTC-5 [email protected] 
>>> wrote:
>>>
>>>> Normally I would say e-Tugra needs to reissue all their certificates or 
>>>> like in this case; it would appear they need to reestablish that the 
>>>> certificates were issued properly, which means having all their customers 
>>>> re-create them, establish domain validation, etc. 
>>>>
>>>> But in this case, I think it's so severe that they should be removed 
>>>> and be made to re-apply to ensure all their security controls/processes 
>>>> are 
>>>> up to standard because they clearly are not. This isn't a little mistake. 
>>>> this shows a massive failure at all levels, technically and business-wise 
>>>> (not removing default passwords, seriously... that's literally the most 
>>>> basic of the basic, what else did they get wrong?).
>>>>
>>>> Additionally, did an attacker possibly get a whole set of new 
>>>> certificates over the summer for their domain names (just a few days 
>>>> ago, etugra renewed everything using their own CA, but they also did a lot 
>>>> of them in July/August of this year).
>>>>
>>>> https://crt.sh/?q=e-tugra
>>>> https://crt.sh/?q=etugratest.com
>>>>
>>>> Also, should this discussion be moved to 
>>>> https://groups.google.com/a/ccadb.org/g/public ? Added [email protected]
>>>> .
>>>>
>>>> On Thu, Nov 17, 2022 at 10:26 AM Ian Carroll <[email protected]> wrote:
>>>>
>>>>> Hi there,
>>>>>
>>>>> Today I published a blog post at https://ian.sh/etugra, describing 
>>>>> several serious security issues I discovered in the e-Tugra certificate 
>>>>> authority. I was able to obtain access to two e-Tugra administrative 
>>>>> systems using default passwords, which disclosed numerous amounts of 
>>>>> subscriber PII and verification details, and appeared to impact e-Tugra's 
>>>>> domain control validation processes.
>>>>>
>>>>> I am concerned that it is possible for these trivial vulnerabilities 
>>>>> to be present in a publicly-trusted certificate authority. In light of 
>>>>> the recent 
>>>>> Symantec news 
>>>>> <https://symantec-enterprise-blogs.security.com/blogs/threat-intelligence/espionage-asia-governments-cert-authority>,
>>>>>  
>>>>> certificate authorities are clearly being targeted by nation states, but 
>>>>> these vulnerabilities could have been discovered by any amateur security 
>>>>> researcher. From what I have seen, I firmly believe that additional 
>>>>> security issues likely exist in e-Tugra's infrastructure, and they may 
>>>>> already be known to adversaries.
>>>>>
>>>>> The Network and Certificate System Security Requirements require an 
>>>>> annual penetration test, or whenever the CA believes there are material 
>>>>> changes. Based on this issue, I am concerned that this control is not 
>>>>> sufficient to protect certificate authorities against application 
>>>>> security 
>>>>> issues, and I am concerned that e-Tugra is not following this control. I 
>>>>> am 
>>>>> also concerned with the lack of vulnerability disclosure programs and bug 
>>>>> bounty programs that are operated by CAs in general; indeed no 
>>>>> certificate 
>>>>> authority at all appears to run a bug bounty program at the moment.
>>>>>
>>>>> I would suggest that e-Tugra be compelled to take remedial actions 
>>>>> such as performing a comprehensive penetration test on their external 
>>>>> infrastructure, and building processes to ensure that future applications 
>>>>> that they deploy are secure. I also believe e-Tugra should ensure that 
>>>>> these issues did not have the ability to compromise domain-control 
>>>>> validation for any certificates still valid today.
>>>>>
>>>>> -- 
>>>>> You received this message because you are subscribed to the Google 
>>>>> Groups "[email protected]" group.
>>>>> To unsubscribe from this group and stop receiving emails from it, send 
>>>>> an email to [email protected].
>>>>> To view this discussion on the web visit 
>>>>> https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/37cff300-b57a-4b38-82e0-a514b4557b07n%40mozilla.org
>>>>>  
>>>>> <https://groups.google.com/a/mozilla.org/d/msgid/dev-security-policy/37cff300-b57a-4b38-82e0-a514b4557b07n%40mozilla.org?utm_medium=email&utm_source=footer>
>>>>> .
>>>>>
>>>>
>>>>
>>>> -- 
>>>> Kurt Seifried (He/Him)
>>>> [email protected]
>>>>
>>>
>>
>> -- 
>> Kurt Seifried (He/Him)
>> [email protected]
>>
> -- 
> Thanks,
> Ian Carroll
>

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