Replying from Cybertrust Japan.

Jeremy,
Thank you for comment.  We are going to use pkilint and zlint for pre-issuance 
lint tesitng for CA G5 that is a scope of this public discussion when start 
issuing subscriber certificates.  In fact, we are using those linters for G4, 
that is also a S/MIME CA and had been issuing production EE certificate.

Best regards,
Mo (Masar)

________________________________
差出人: [email protected] <[email protected]> が Jeremy Rowley <[email protected]> 
の代理で送信
送信日時: Saturday, December 21, 2024 1:03:47 AM
宛先: CCADB Public <[email protected]>
CC: Ben Wilson <[email protected]>
件名: Re: Public Discussion of SECOM Externally-Operated S/MIME CA

Hi Ben - one idea is to require all externally operated ICAs to use a linter, 
even of SMIME. Although CTJ is a well-known industry entity, I don't think it 
hurts to require them to pre-lint all SMIME certs before issuing using 
something like pkilint or adding metalint.

On Wednesday, December 18, 2024 at 12:09:06 PM UTC-7 Ben Wilson wrote:

All,

This email commences a public discussion period that will run through Friday, 
January 10, 2025. This is regarding the issuance of S/MIME certificates by 
Cybertrust Japan (CTJ) under an externally-operated subordinate CA issued by 
SECOM (see Mozilla Root Store Policy, Section 
8.4<https://www.mozilla.org/en-US/about/governance/policies/security-group/certs/policy/#84-externally-operated-subordinate-cas>).

Both SECOM and CTJ are included as CA owners/operators in one or more root 
stores, but CTJ does not currently have any of its own root certificates 
enabled for S/MIME issuance. (In the new year, we will commence a 6-week 
discussion period for the CTJ SecureSign Root 
CA16<https://crt.sh/?sha256=4C1CCD24F17E950FC18536B33CAFE32293CFC33E8467B41E1C693055D7F513BF>,
 which CTJ has submitted for inclusion as a root certificate for S/MIME 
issuance.)

The purpose of this public discussion is to promote openness and transparency. 
Each Root Store makes its inclusion decisions independently, on its own 
timelines, and based on its own inclusion criteria. Successful completion of 
this public discussion process does not guarantee any favorable action by any 
root store.

Anyone with concerns or questions is urged to raise them on this CCADB Public 
list by replying directly to this discussion thread. Representatives of SECOM 
or CTJ, as the case may be, will respond directly in this thread to all 
questions that are posted.  However, please note that due to 
internationally-recognized holidays, some responses may be delayed.


Request Details:

Bugzilla Case Number:  # 
1933132<https://bugzilla.mozilla.org/show_bug.cgi?id=1933132> - SECOM’s Request 
re: Cybertrust Japan SureMail CA G5

(Note that signing/issuance of the external Sub CA can occur before completion 
of public discussion and root store approval, as long as the external Sub CA 
does not issue end entity certificates.)


Organization Background:

  *   Owner/Operator of External Sub-CA:  Cybertrust Japan Co., Ltd.
  *   Website: https://www.cybertrust.co.jp/
  *   Address: ARK Hills Sengokuyama Mori Tower 35F, 1-9-10 Roppongi, 
Minato-ku, Tokyo, 106-0032
  *   Problem Reporting Mechanisms:  [email protected]
  *   Organization Type: Private Corporation
  *   Repository URL (Cybertrust Japan SureMail CA G5 (SECOM Subordinate CA)):

https://www.cybertrust.ne.jp/ssl/repository/


Certificate Requested for Approval:

Cybertrust Japan SureMail CA G5 (SECOM Subordinate CA):

  *   Root CA:  SECOM’s Security Communication 
RootCA2<https://crt.sh/?SHA256=513B2CECB810D4CDE5DD85391ADFC6C2DD60D87BB736D2B521484AA47A0EBEF6>
  *   Certificate profile:  
https://bugzilla.mozilla.org/attachment.cgi?id=9439631 (.xlsx)
  *   Use cases served/EKUs:

Secure Email (S/MIME) 1.3.6.1.5.5.7.3.4


Existing Publicly Trusted CAs from SECOM and CTJ:

SECOM and CTJ already have several root CAs included in root stores. The 
requested subordinate CA represent CTJ’s efforts to realize S/MIME issuance 
capabilities. SECOM confirms that it has reviewed and validated CTJ’s policy 
and audit documentation.


Relevant Policy and Practices Documentation:

  *   CTJ S/MIME Certificate Policy (CP)

https://www.cybertrust.ne.jp/ssl/repository/SMCP_English.pdf

  *   CTJ Certification Practice Statement (CPS):

https://www.cybertrust.ne.jp/ssl/repository/CTJCPS_English.pdf (Version 1.10)


Most Recent Self-Assessments:

  *   Cybertrust Japan SureMail CA G5 (SECOM Subordinate CA):

 Assessment of CTJ in Bugzilla Attachment 
#9439634<https://bugzilla.mozilla.org/attachment.cgi?id=9439634> (.xlsx) 
(completed Sept. 24, 2024)


Audit Statements:

  *   Auditor: KPMG
  *   Audit Criteria: WebTrust
  *   Recent Audit Statements:

    https://bugzilla.mozilla.org/attachment.cgi?id=9439632


Incident Summary:

SECOM has previously reported two incidents in Bugzilla related to CTJ. In both 
cases, SECOM and CTJ worked together promptly to investigate and address the 
issues, taking swift action, and successfully closing them.

  *   SECOM: EV certificate mis-issued with the incorrect Registration Number 
by CTJ  
https://bugzilla.mozilla.org/show_bug.cgi?id=1805866
  *   SECOM: CTJ failed to make an annual CPS update 
https://bugzilla.mozilla.org/show_bug.cgi?id=1769222



Also, please let me know if you have any questions concerning this process.


Thank you,

Ben Wilson

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