Sorry, but your #2 below is wrong – James did leave a trace, his name and 
address (and no, that’s not emotion talking, just facts).  To my knowledge, so 
has every EV cert holder – it’s way too much trouble to establish a corporation 
(that’s real) using fake and untraceable information, then establish the same 
false identity in Hoover’s (they require more than self-reporting, and use 
their own antifraud algorithms), and also complete all the other EV 
authentication steps just to obtain and use a EV cert for that fake identity, 
which will then be unusable as soon as the website has been tagged for fraud or 
phishing.  That isn’t happening.

In contrast, anonymous, free, phishing DV certs can be – and are being – used 
and discarded in minutes or hours without a trace, and a new anonymous, free, 
phishing DV cert substituted within minutes as soon as the first website has 
been flagged for fraud.  It’s happening all the time now.

From: Ryan Sleevi [mailto:[email protected]]
Sent: Tuesday, November 28, 2017 1:42 PM
To: Kirk Hall <[email protected]>
Cc: CA/Browser Forum Public Discussion List <[email protected]>
Subject: Re: [EXTERNAL]Re: [cabfpub] Obtaining an EV cert for phishing

I appreciate your arguments about human nature, although from a security 
perspective, we prefer to think about what the 'weakest link' is. I also 
appreciate the appeal to suspend logical discussion, and instead discussion on 
experience and emotion, which can certainly make for good business, but also 
makes for bad security.

The weakest link will always be the most lucrative to attack.

Your argument is that DV is a weak-link, and that EV improves that weak-link.

Ignoring, for a second, that EV and DV are not differentiated in the 
foundational security model of the Web (the origin security model of the same 
origin policy), we have to evaluate two aspects of the claim here:
1) How does one strengthen the weak-link (of DV)
2) Are the claims about EV improving that weak-link (of DV) accurate

James' work shows the misrepresentation of the value of EV with respect to #2. 
That is, an EV certificate can be obtained for 'nefarious' intent without 
leaving a trace. This is especially true given that EVs security itself rests 
on the weakest link of the QIIS, QGIS, and QTIS, and James has shown how 
assumptions of the strength of those links are, to put mildly, incorrect, or to 
put hyperbolically, overblown.

The CA Security Council, which is both not affiliated with the CA/B Forum and, 
charitably, misnamed, advocates that the solution to #1 is "user training", by 
virtue of changes to the user interface. That is, we should make the 
supposed-weak-link look bad (for some sort of activity), while making the 
supposed-strong-link look good (for some sort of activity)

What that activity is varies, of course - If our activity is, say, "phishing", 
then it means every page that takes any form of user details (not just 
passwords, but any form of data collection) should use an EV certificate. If 
our solution is say, "malware", then it it means every page that offers any 
form of download (or runs any form of browser scripting, since that can be used 
to exploit bugs in browsers) should use an EV certificate.

The 'solution' from the CA Security Council is to suggest that users should 
know that all sensitive operations should be OV/EV certificates, and all site 
operators should use OV/EV certificates, with a somewhat dismissive 'still 
allow' of DV for 'blogs' - that is, CAs want to be content police and 
adjudicators, indicating blogs are not important activities but 'commerce' is, 
despite their virtual indistinguishability to impact on everyday life.

This solution rests on the premise that #2 is stronger than DV, because of its 
use of a QIIS and QGIS. Your own reply echoes this belief, conflating both 
correlation with causation and ignoring the conclusions that can be drawn by 
James' work. Unfortunately, this specious reasoning was perhaps most 
compellingly summed up by Lisa Simpson in 
https://www.youtube.com/watch?v=fm2W0sq9ddU

You argue that this works by arguing on the basis of 'false' negatives - 
companies you rejected due to the lack of cross-correlation - but as James has 
pointed out, there's a clear lack of data of the false positives - 
organizations that were issued EV certs but are 'up to no good'. We know false 
positives exists - a former member of the CA/Browser Forum, and (possibly still 
current) member of the CA/Security Council issued quite a few of them over the 
past three years. The argument that there must not be false positives, because 
evil isn't done, is, unfortunately, much like arguing that Lisa's rock repels 
tigers.



On Tue, Nov 28, 2017 at 4:16 PM, Kirk Hall 
<[email protected]<mailto:[email protected]>> wrote:

Moving from pure logical assumptions to actual experience – we have EV-vetted 
thousands of organizations over nearly a ten-year period.  We have never found 
one (either at the time or verification or after the fact) that was fake or 
appeared to include fake address or other information – even though the holder 
of an EV certificate is rewarded by having its identity displayed in the 
browser UI (such as the “Identity Verified” name displayed in the browser UI 
from the EV cert for Mr. Burton’s company – his article seemed to say that 
identity display was important to him as a potential phisher).



Under the EV verification processes that all CAs must follow and be audited to, 
any information contained in the Qualified Government Information Source (QGIS) 
such as Companies House in the UK must be cross-correlated with data found in a 
Qualified Independent Information Source (QIIS), such as Hoover’s.  On several 
occasions we have not been able to complete this cross-correlation for EV 
applicants, often because the company was too new and did not yet have an 
established record with the QIIS, and so were unable to issue the EV cert to 
the applicant.



So again, dealing with actual experience – phishers have not been choosing EV 
certificates when they move their activities to encrypted sites, they have 
overwhelmingly been choosing anonymous DV certificates for obvious reasons.  
It’s simple human nature that people avoid doing bad things when their identity 
will be known, and prefer doing bad things when they can remain anonymous – 
that’s why identity websites (OV and EV) are proving to be much safer for users 
than anonymous websites (DV).



From: Public 
[mailto:[email protected]<mailto:[email protected]>] On 
Behalf Of Ryan Sleevi via Public
Sent: Tuesday, November 28, 2017 10:58 AM
To: Christian Heutger <[email protected]<mailto:[email protected]>>; CA/Browser Forum 
Public Discussion List <[email protected]<mailto:[email protected]>>
Subject: [EXTERNAL]Re: [cabfpub] Obtaining an EV cert for phishing



To be fair, I was grossly simplifying the argument that it is:

a) A crime to mislead a QGIS, QIIS, or QTIS within either the Jurisdiction of 
Incorporation or the Place of Business (as Ben and Kirk suggested)

b) A crime to use cert for 'evil' purposes, as Kirk suggested



There are many other reductions of the arguments being made here that would 
also apply, but I thought it worth pointing out that the argument that it'd be 
a crime to commit crime, is somewhat of a flawed tautology, and by no means a 
way to conclude we'd prevent crime by criminalizing crime.



On Tue, Nov 28, 2017 at 1:35 PM, Christian Heutger via Public 
<[email protected]<mailto:[email protected]>> wrote:

It also means that a crime favours another crime, and that is exactly how 
criminals are caught, because they leave their mark, the more so, the better, 
because it makes it easier to get to the bottom of it. If you were to skip 
steps now, you would also deprive yourself of opportunities to hunt down 
criminals.



Von: Public <[email protected]<mailto:[email protected]>> 
im Auftrag von Ryan Sleevi via Public 
<[email protected]<mailto:[email protected]>>
Antworten an: Ryan Sleevi <[email protected]<mailto:[email protected]>>, 
CA/Browser Forum Public Discussion List 
<[email protected]<mailto:[email protected]>>
Datum: Dienstag, 28. November 2017 um 19:26
An: Ben Wilson <[email protected]<mailto:[email protected]>>, 
CA/Browser Forum Public Discussion List 
<[email protected]<mailto:[email protected]>>
Betreff: Re: [cabfpub] Obtaining an EV cert for phishing



Just to square these comments:



Kirk's position was that EV certificates provide a way of tracking those who'd 
commit crime online because they have to disclose identity.

Gerv and James pointed out that the identity information is only as useful as 
it is vetted, and there's scenarios where the vetting may not be rigorous.

Ben pointed out that it'd be a crime to lie to the government (although, as a 
broad statement, this varies by jurisdiction)



By combining these views, it seems like we're in agreement that criminals who 
are willing to commit crime may need to commit crime to commit crime. That 
doesn't seem like the requirement to commit crime would deter a criminal from 
committing crime, but what do I know - I'm not a criminal (I don't think...)



On Tue, Nov 28, 2017 at 12:50 PM, Ben Wilson via Public 
<[email protected]<mailto:[email protected]>> wrote:

Gerv wrote: I would say that the EV Guidelines allow EV issuers to trust things 
which are QGISes because there's an assumption that information in a Government 
information source will have had some level of checking.

I'd disagree.  QGISes are relied upon because everyone relies on them because 
lying to the government is a crime.


-----Original Message-----
From: Public 
[mailto:[email protected]<mailto:[email protected]>] On 
Behalf Of Gervase Markham via Public
Sent: Tuesday, November 28, 2017 10:46 AM
To: Kirk Hall 
<[email protected]<mailto:[email protected]>>; James 
Burton <[email protected]<mailto:[email protected]>>; CA/Browser Forum 
Public Discussion List <[email protected]<mailto:[email protected]>>
Subject: Re: [cabfpub] Obtaining an EV cert for phishing

Hi Kirk,

On 28/11/17 17:03, Kirk Hall wrote:
> Thanks for the additional information, James.  In the end, the EV
> Guidelines did exactly what they were designed to do – they provided a
> way for the public to find you (as the company owner) if you used your
> EV certificate and domain to do something wrong.

They did, but only because he was honest. He is pointing out that it may not be 
difficult, due to the lack of checking, for a dishonest person to use fake 
information. I do think that's an issue of concern.

I would say that the EV Guidelines allow EV issuers to trust things which are 
QGISes because there's an assumption that information in a Government 
information source will have had some level of checking. But it seems from this 
experience that this is not true in all cases. That concerns me. Do we have to 
agree that Companies House is not a valid QGIS?

This is not a phishing issue, it's a more general "integrity of the EV process" 
issue.

Gerv
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