Dear Mozilla Community,

This email relates to the e-Tugra breach that was described in a blog post
by Ian Carroll <https://ian.sh/etugra> and subsequent discussions here
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/yqALPG5PC4s/m/sIkv6eLAAAAJ>
and in CCADB Public
<https://groups.google.com/a/mozilla.org/g/dev-security-policy/c/yqALPG5PC4s/m/sIkv6eLAAAAJ>
and Bugzilla <https://bugzilla.mozilla.org/show_bug.cgi?id=1801345>. We are
grateful for the involvement of various individuals and organizations,
particularly Ian Carroll and Google Chrome, who have contributed their
expertise and resources while investigating this breach.

We are now opening this discussion to help determine whether the e-Tugra
root certificates should be removed from Mozilla’s Root Store. We will
greatly appreciate your thoughtful and constructive feedback on this.

Below are some questions for us to consider in this discussion.

What were the main concerns raised by the community during the discussions
that took place in Bugzilla Bug #1801345
<https://bugzilla.mozilla.org/show_bug.cgi?id=1801345>? (this is not a
complete list; details may be found in the bug)

   -

   Mr. Carroll indicated that he was able to log in and conduct
   reconnaissance on e-Tugra’s email and document storage systems, gaining
   access to customer PII.
   -

      There were security holes in e-Tugra’s internal systems that existed
      because access to internal resources was not adequately secured, namely,
      default passwords on some administrative tools had not been changed, and
      internal applications were left exposed without appropriate
access control
      mechanisms.
      -

      Statements by e-Tugra about the lack of impact were refuted by the
      fact that the contents of 568,647 emails and 251,230 documents were
      accessible, including access to password resets and confirmation codes.
      -

   e-Tugra indicated in their incident report that they would conduct
   additional vulnerability scanning and penetration testing before the end of
   2022. They also said that they were preparing a detailed report of the
   problem and would provide more information.
   -

      None of this information was provided until April 2023.
      -

      The explanations in subsequent reports and executive summaries of
      penetration testing did not fully answer the questions that had
been asked.
      -

   A detailed analysis was not provided, no root cause analysis was ever
   provided, and the output of the penetration test (i.e., reports) did not
   offer any detail addressing concerns raised in the incident report. (The
   penetration test reports only provided brief statements and insufficient
   information to evaluate the security posture of e-Tugra.)

Does the benefit of having e-Tugra root certificates in Mozilla’s Root
Store outweigh the risk?

   -

   The breach that was found by Mr. Carroll may indicate that the CA
   operators may not have the level of expertise necessary to securely operate
   a publicly trusted CA.
   -

   The slow response by e-Tugra may also be an indication that they may not
   be prepared to respond to concerns and incidents in the required timely
   manner.

How would the distrust of e-Tugra affect our users?

   -

   Since the e-Tugra root certificates are not currently being used, there
   would not be any impact to our users.
   -

   e-Tugra is not currently issuing TLS certificates within their own CA
   hierarchy. Instead, e-Tugra has been acting as a reseller for the SSL.com
   CA, which means that all domain validation and certificate issuance is
   being performed by systems operated by the SSL.com CA, so SSL.com is the
   party currently responsible for issuance/security procedures.

If distrusted, could e-Tugra continue to be a reseller for a publicly
trusted CA?

   -

   Yes, as long as the publicly trusted CA ensures correct
   systems/procedures/processes in relation to reselling certificates within
   their CA hierarchy.

If distrusted, could e-Tugra re-apply to have their root certificates
included in Mozilla’s Root Store?

   -

   If we decide to remove the current e-Tugra roots, then in order for
   e-Tugra to apply to have their root certificates included in Mozilla’s Root
   Store again, they would need to:
   -

      Implement an infrastructure that is properly secure and tested, with
      sufficiently detailed artifacts to show that the systems are properly
      configured.
      -

      Then create new root certificates within the properly secured
      infrastructure.
      -

      Then re-apply for inclusion in Mozilla’s root store.
      -

   As always, the onus is on the CA operator to demonstrate their ability
   to operate a publicly trusted CA hierarchy.

How are other root stores addressing this issue?

   -

   Google Chrome announced
   <https://groups.google.com/a/ccadb.org/g/public/c/SXAeHT04TFc/m/TIh1ANmHAwAJ>
   that they will remove the “E-Tugra Global Root CA ECC v3” and “E-Tugra
   Global Root CA RSA v3” roots from the Chrome Root Store.
   -

   Apple stated
   <https://groups.google.com/a/ccadb.org/g/public/c/SXAeHT04TFc/m/B_snEIWZAwAJ>
   that the e-Tugra roots are not in the Apple Root Store.

Given that SSL.com has been the operator of the issuing CA, e-Tugra’s
breach has not necessitated that we take any urgent safeguarding actions.
However, e-Tugra’s problems give us reason to question whether the e-Tugra
CA should continue to be in our root store, based on the level of expertise
required to securely operate a publicly trusted CA infrastructure.
Additionally, e-Tugra’s inadequate responses to the problem and resulting
requests for information, give us reason to question e-Tugra’s commitment
to the important role that CAs have in ensuring security on the web.

We appreciate your engagement and dedication, and we kindly request that
all participants adhere to our Community Participation Guidelines
<https://www.mozilla.org/en-US/about/governance/policies/participation/>,
fostering a respectful and constructive environment for dialogue.

Thanks,

Ben and Kathleen

PS: For your reference, below are excerpts from
https://wiki.mozilla.org/CA/Maintenance_and_Enforcement

CA behavior

   -

   Did the CA notice the error and take appropriate action in a timely
   manner?
   -

      Was the threat or error properly contained?
      -

   Did the CA notice the hacker intrusion and take appropriate action in a
   timely manner?
   -

      Were the CA's defense mechanisms current and sufficient?
      -

      Was the intrusion appropriately contained?
      -

   Was the CA's behavior reckless?
   -

   Did the CA try to cover up the mistake/threat rather than follow
   Mozilla's Security Policy?

In incident response, Mozilla is looking for the following factors:

   -

   A CA takes responsibility for their own actions.
   -

   Incidents are taken with an appropriate level of seriousness.
   -

   Incidents are handled with urgency.
   -

   Root cause analysis is performed.
   -

   Any questions posed, by anyone, are answered quickly and in detail.
   -

   A reasonably-detailed incident report
   <https://wiki.mozilla.org/CA/Responding_To_An_Incident#Incident_Report>
   is made public on what happened, why, and how things have changed to make
   sure it won’t happen again

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