Frank Hecker wrote [in part]:
> 
> Let's take QuoVadis as an example. QuoVadis
> is not currently officially WebTrust-audited. 
> 
> Instead QuoVadis's current state is as follows:
> 
> * QuoVadis claims conformance to a set of Bermudan government
> regulations relating to CAs:
> 
>    http://www.quovadis.bm/support/library/Bda_CSP.pdf
> 
> and has been certified by the Bermudan government as meeting those
> requirements
> based on an audit conducted by Ernst & Young on behalf of the Bermudan
> government. (The audit report is not a public document, so I can't
> provide a link.)
> 
> * Ernst & Young also did a separate audit to meet the Microsoft
> requirement that the CA "provide an equivalent third-party attestation"
> if it were not officially WebTrust-approved, and provided a letter to
> QuoVadis and Microsoft containing such an attestation. The letter is not
> a public document, so I can't provide a link (although I have seen a
> copy of the letter).
> 
> So, based on the QuoVadis experience I would tentatively define
> "WebTrust-equivalency" as follows:
> 
> * The CA claims conformance to a set of criteria equivalent to those
> used in WebTrust
> 
> * The CA's conformance to these criteria has been attested to by an
> independent third-party (as opposed to the CA doing its own audit).
> 
> * Optionally: The independent third-party in question is authorized to
> perform WebTrust audits, and hence is qualified to render a judgement on
> whether the CA is conforming to criteria equivalent to the WebTrust
> criteria.
> 
> My proposal therefore is that I extend the interim policy to also
> approve requests from CA's meeting "WebTrust-equivalent" requirements as
> defined above.
> 
> Based on the information QuoVadis has supplied to me, I believe that
> they meet those requirements, and under such an extended interim policy
> I would be inclined to approve QuoVadis to have their CA certificate(s)
> included in Mozilla. (My only reservation is that the E&Y letter
> mentioned is not a public document.)

The most important question is whether the Mozilla Foundation has
received a copy of the Ernst & Young letter from Ernst & Young
itself.  The copy could be received under an agreement that it
remain outside the public realm.  However, without the letter --
not from QuoVadis (which would be self-serving) but from Ernst &
Young -- the CA would be approved on hearsay without any real
substantiation.  

The fact that QuoVadis was audited by Bermudan government should
carry only slight weight unless we have a good appreciation of the
quality of that government and its freedom from corruption.  Let's
take a more extreme example:  Would we trust CAs audited by the
Nigerian, Iranian, or Russian governments or any of the governments
in the Pacific islands that are spammer havens?  (I'm not sure I
would even trust CAs audited by the U.S. government given how
military contracts for "rebuilding" Iraq were awarded.)  

-- 

David E. Ross
<http://www.rossde.com/>  

I use Mozilla as my Web browser because I want a browser that 
complies with Web standards.  See <http://www.mozilla.org/>.
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