Re: WISeKey root inclusion request (re-start public discussion)

2008-11-29 Thread Eddy Nigg

On 11/29/2008 06:43 AM, Frank Hecker:

On the WISeKey end, they could mandate use of SAN in BlackBox-issued
certificates (as opposed to just including it in the default template),
and from the NSS end we could disallow use of CN for storing domain
names.



At least you could have made it a requirement in order for the name 
constraints to have any effect with NSS.


In regards to NSS we don't have to disallow subject CN fields, but have 
NSS check also for these attributes in addition to the SAN.


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-29 Thread Eddy Nigg

On 11/29/2008 05:27 PM, Frank Hecker:


Made what a requirement? Mandating use of SAN in BlackBox?


Yes, that's what I actually meant.


But my understanding
(based on your hypothetical scenario) is that this would not be
sufficient, since someone could remove the key material and try to issue
certificates outside the context of the BlackBox product.


Which is correct too...at least in the above scenario misusing the 
system would require a higher effort and can't be performed directly 
from the system.




My impression from Nelson's comments is that checking CN would be
subject to potential errors, since there is no well-defined standard for
what CN should contain. Thus the only foolproof approach would be to
move to a world where we prohibit use of CN in contexts like SSL-enbled
servers and force the use of SAN. But that would be a major undertaking
and one that would likely take several years in order to coordinate
action with other browser vendors and with CAs in general.


Prohibiting the subject line would be a tough call - unrealistic in my 
opinion. But checking for the CN field for SERVER certificate should be 
entirely possible, because that's what NSS does anyway (for domain match).




The bottom line is that I certainly encourage WISeKey to promote correct
use of SAN, including consideration of making its use mandatory in the
BlackBox templates, investigation of why some customers don't use it,
and resolution of any issues relating to use of SAN by BlackBox
customers.


OK, so I guess there will be no follow up later on ;-)


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-29 Thread Kyle Hamilton
OMG, maybe just maybe the OpenSSL folks should perhaps be told of
this issue and concept so they can update!

-Kyle H

On Mon, Nov 24, 2008 at 11:35 AM, Eddy Nigg [EMAIL PROTECTED] wrote:
 On 11/24/2008 07:33 PM, Nelson B Bolyard:

 The only solution to this that is apparent to me is for the web to
 evolve to the point where browsers no longer accept DNS names in
 non-standard locations in the cert, such as in the Subject Common Name.

 Which in itself might create quite some problems. I guess we don't need any
 more problems right now when considering the current UI implementation and
 complaints coming in... Just imagine CN fields wouldn't be checked anymore
 by NSS:

 OMG, my openssl cert doesn't work anymore. Firefox is broken!  :-)

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-28 Thread Frank Hecker

Eddy Nigg wrote:
Frank: I think the critical issues what Mozilla concerns have been 
addressed!


I agree, and am going to proceed with approval of this request.


We need to make sure that naming constraints work as expected.


I read through the thread on that, and will read it again to confirm my 
understanding. However I've already commented on my views regarding name 
constraints.


Frank

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-28 Thread Frank Hecker

Frank Hecker wrote:
Per the CA schedule, the next CA on the list for public comment is 
WISeKey, which has applied to add its (one) root CA certificate to the 
Mozilla root store, as documented in the following bug:


  https://bugzilla.mozilla.org/show_bug.cgi?id=371362

and in the pending certificates list here:

  http://www.mozilla.org/projects/security/certs/pending/#WISeKey


We've now completed the scheduled time for public discussion on this 
request. Based on my reading of the prior material for this request 
(e.g., in the bug and in the newsgroup) and my reading of the discussion 
thread for this discussion period, there were two issues of note:


First is auditing of subordinate CAs as implemented by the BloackBox 
product. As noted by Kevin Blackman, WISeKey now does annual onsite 
audits of BlackBox customers. This satisfies any concerns I might have 
had on the subject of audits.


Second is constraining subordinate CAs to issue certificates only within 
their own domain(s). My understanding from the WISeKey documents and 
from Kevin Blackman's comments is that WISeKey implements both 
contractual and technical constraints in connection with the BlackBox 
products. Based on comments by Eddy, Nelson, et.al., there are 
apparently theoretical cases where such constraints could be evaded and 
the evasion would not be picked up by NSS (based on NSS not checking 
domain constraints on CN or any other values outside of the SAN stuff).


On the WISeKey end, they could mandate use of SAN in BlackBox-issued 
certificates (as opposed to just including it in the default template), 
and from the NSS end we could disallow use of CN for storing domain 
names. These may be good ideas for future consideration, but I can't 
justify holding up this request till they get implemented.



Frank

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-28 Thread Frank Hecker

Frank Hecker wrote:

Frank Hecker wrote:
Per the CA schedule, the next CA on the list for public comment is 
WISeKey, which has applied to add its (one) root CA certificate to the 
Mozilla root store, as documented in the following bug:


  https://bugzilla.mozilla.org/show_bug.cgi?id=371362

and in the pending certificates list here:

  http://www.mozilla.org/projects/security/certs/pending/#WISeKey


We've now completed the scheduled time for public discussion on this 
request. Based on my reading of the prior material for this request 
(e.g., in the bug and in the newsgroup) and my reading of the discussion 
thread for this discussion period, there were two issues of note:


And I forgot to add: In my opinion these issues have been resolved to my 
satisfaction, and I'm therefore officially approving the WISeKey 
request. I've filed bug 467138 against NSS for the actual certificate 
inclusion:


  https://bugzilla.mozilla.org/show_bug.cgi?id=467138

Frank

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-24 Thread Eddy Nigg

On 11/23/2008 12:32 AM, Nelson B Bolyard:


There's no foolproof test for determining if a string is a DNS name or
some other kind of name.  Various heuristics can be devised, but they
all have problems.


This worries me somewhat and I question the usefulness of the 
name-constraints then...


Consider the following scenario at a customer of a blackbox product:

- Employee gains physical access to the machine, shuts down the machine 
by force (removing machine from electricity source).
- He removes the hardware token from the machine and connects it to a 
different system.
- He prints and signs a few certificates for www.paypal.com and 
www.microsoft.com
- Returns the token back to the blackbox. Returns power source and 
starts the machine.


Now in this case, no reporting from the blackbox is done - except that a 
power failure happened perhaps. Nobody will ever know the existence of 
those certificates. Now, name-constrains will fail for those 
certificates under the various scenarios you explained, including the 
cases where no SAN DNS is present in first place :S


Note that no third party (besides the wonderful services of the parent 
CA) ever confirmed the physical controls of the customer above. It's 
still a sub root in the hands of a customer with questionable restraints 
then. Nothing will prevent the customer from misusing the system - even 
if the intentions of Wisekey are sincere.


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-24 Thread Nelson B Bolyard
Eddy Nigg wrote, On 2008-11-24 09:14:
 On 11/23/2008 12:32 AM, Nelson B Bolyard:
 There's no foolproof test for determining if a string is a DNS name or
 some other kind of name.  Various heuristics can be devised, but they
 all have problems.
 
 This worries me somewhat and I question the usefulness of the 
 name-constraints then...
 
 Consider the following scenario at a customer of a blackbox product:
 
 - Employee gains physical access to the machine, shuts down the machine 
 by force (removing machine from electricity source).
 - He removes the hardware token from the machine and connects it to a 
 different system.
 - He prints and signs a few certificates for www.paypal.com and 
 www.microsoft.com

... certificates that do not use standard Subject Alt Names extensions
but rather use the old non-standard Subject Common Name

 - Returns the token back to the blackbox. Returns power source and 
 starts the machine.
 
 [...] Now, name-constrains will fail for those
 certificates under the various scenarios you explained, including the 
 cases where no SAN DNS is present in first place :S

The only solution to this that is apparent to me is for the web to
evolve to the point where browsers no longer accept DNS names in
non-standard locations in the cert, such as in the Subject Common Name.
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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-24 Thread Eddy Nigg

On 11/24/2008 07:33 PM, Nelson B Bolyard:

The only solution to this that is apparent to me is for the web to
evolve to the point where browsers no longer accept DNS names in
non-standard locations in the cert, such as in the Subject Common Name.


Which in itself might create quite some problems. I guess we don't need 
any more problems right now when considering the current UI 
implementation and complaints coming in... Just imagine CN fields 
wouldn't be checked anymore by NSS:


OMG, my openssl cert doesn't work anymore. Firefox is broken!  :-)

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-24 Thread Nelson B Bolyard
Eddy Nigg wrote, On 2008-11-24 11:35:
 On 11/24/2008 07:33 PM, Nelson B Bolyard:
 The only solution to this that is apparent to me is for the web to
 evolve to the point where browsers no longer accept DNS names in
 non-standard locations in the cert, such as in the Subject Common Name.
 
 Which in itself might create quite some problems. I guess we don't need 
 any more problems right now when considering the current UI 
 implementation and complaints coming in... Just imagine CN fields 
 wouldn't be checked anymore by NSS:
 
 OMG, my openssl cert doesn't work anymore. Firefox is broken!  :-)

There are 5 browser makers cooperating now as never before in the area
of SSL.  If they all dropped support for CNs together...
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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-22 Thread kgb
Hi Eddy,
On Nov 21, 10:37 pm, Eddy Nigg [EMAIL PROTECTED] wrote:
 On 11/21/2008 10:12 PM, kgb:



  Only validated and approved domain names can be included
  in a cert, whether in the Subject DN or the SAN.
  It is the default template, and best practice that the SAN
  (e.g. RFC822, dnsName) to be filled in the certificates.
  Its the case for some but not all customers.

  I really hope its not necessary once we can guarantee that
  only validated domains are used in the certificates.

 The issue I care mostly about is, what happens when one if these systems
 get compromised without you (the CA) ever detecting. Since those system
 aren't under your control, this is entirely possible and the risk is
 certainly higher than at your infrastructure. The threats may come from
 unknown source or from the customer himself (or their employees).

 The from you issued CA certificate with a path length of 0 and naming
 constraints limitation is what convinces me as a reasonable protection
 regarding above case. However it would have to be enforced by SAN
 extension. How come your customers can decide if to include the relevant
 alternative name or not? Isn't this something you should control?


We have allowed the inclusion or not of the SAN extension in a
certificate,
because the constraints are always applied, whether the domain name
is in the SAN or in the Subject DN. For us allowing this flexibility
has thus
not caused any issues, till now.

Mandatory inclusion of the SAN extension in a certificate is a policy
we
can apply and monitor in the future.

Regards,
Kevin

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-22 Thread Eddy Nigg

On 11/22/2008 12:32 PM, kgb:

Mandatory inclusion of the SAN extension in a certificate is a policy
we can apply and monitor in the future.



To my understanding NSS ignores the subject line according to the RFC. 
DNS name constraints constrain subject alt name extensions, not CN= 
attributes in subject names. The same applies for email addresses.


(Obviously a compromised system in some form or the other might be able 
to circumvent an SAN policy as well, but makes it perhaps somewhat 
harder still. In the meantime I think the above suggested would be 
sufficient, Frank might look into if NSS should implement non-standard 
behavior and also check for fields in the subject line.)


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-22 Thread Nelson B Bolyard
Eddy Nigg wrote, On 2008-11-22 04:10:
 On 11/22/2008 12:32 PM, kgb:
 Mandatory inclusion of the SAN extension in a certificate is a policy
 we can apply and monitor in the future.
 
 To my understanding NSS ignores the subject line according to the RFC. 

I think you mean subject NAME, not subject line.

 DNS name constraints constrain subject alt name extensions, not CN= 
 attributes in subject names. 

That's right. NSS applies name constraints to DNS names found in subject
alternative names extensions but does not apply them to DNS names found
within the Common Name attributes in cert subject names, per the RFC.

There are several reasons for that.  One is that the RFC only defines
DNS name constraints as applying to DNS names in subject Alt Names.
But the greater reason is that Common Names may legitimately carry
values that are not DNS names.  Indeed, they were never intended to
carry DNS names at all, but rather were intended to carry the names of
persons.  You wouldn't want to reject a cert on the grounds that it
failed the DNS name constraint if the CN contained Eddy Nigg and the
DNS constraint said startcom.org.

 The same applies for email addresses.

The story for email addresses isn't quite as simple as for DNS names.
There are numerous different subject name attributes that can carry
email addresses.  There are two of those types of attributes to which
NSS does apply email name constraints.  They are the attributes commonly
displayed with E= and MAIL=.  But other attributes are not constrained
by email address constraints.

In practice this means that email addresses in subject names are more
likely to be constrained than are DNS names in subject names.  This is
not an issue for certs that are issued in conformance with the RFC,
putting the DNS names and email addresses into the Subject Names.
But certs that put those names SOLELY in the subject name and not in
the subject Alt Name may not be adequately constrained.  Sadly, there
are Many CAs that still put those names ONLY in the subject name, and
not in the subject alt name where they belong.

 Frank might look into if NSS should implement non-standard
 behavior and also check for fields in the subject line.)

There's no foolproof test for determining if a string is a DNS name or
some other kind of name.  Various heuristics can be devised, but they
all have problems. Consider an algorithm that will find the right answer
for all of these strings:
  Eddy Nigg
  www.startcom.org
  Eddy
  www
  e.nigg

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-21 Thread kgb
Hi Eddy,

On Nov 21, 12:36 am, Eddy Nigg [EMAIL PROTECTED] wrote:
 On 11/20/2008 06:34 PM, kb:



    Probably the most important change in stated practice, is that it is
  reflected that every CA is audited at least once annually. This is the
  case for all active CAs.

 Kevin, thanks for clarifying this. It indeed was one of the concerns
 raised last time.

  The company database (such as existing HR, or IDM) of organisation,
  with details of the organisation's users, including their email
  addresses, is the principal source of data for certificates.

 OK.



  Bounce back email verification procedure proving access to the email
  account is also accepted, but this is inefficient in the enterprise
  context...

 That's why I asked... ;-)



  In addition other identity data in the certificate must come from a
  verified source, e.g. HR database of identity data that is well-
  maintained and was created based on face to face or direct
  verification of the person.

 Excellent!



  Currently it is WISeKey that audits all our CAs, we review the CAs at
  least once annually, or more regularly as we are more often present on
  some client sites. In addition to the controls we place on issuance,
  we also place monitoring controls and obtain regular reports.

 Last question: Are there any sub CAs besides the blackbox product (with
 name-constraints) which are external to your physical infrastructure? I
 think there is not, but can you confirm that?


There is not.
There are no sub CAs within our public hierarchy, that are not of the
BlackBox type, which are external to our physical infrastructure.
There are several PRIVATE CAs (linked to a private customer Root CA)
that use our software and practices and processes, including
Government Root and Subordinate CAs.

Regards,
Kevin

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-21 Thread Eddy Nigg

On 11/21/2008 10:57 AM, kgb:


There is not.
There are no sub CAs within our public hierarchy, that are not of the
BlackBox type, which are external to our physical infrastructure.
There are several PRIVATE CAs (linked to a private customer Root CA)
that use our software and practices and processes, including
Government Root and Subordinate CAs.



Which isn't of our concern obviously! Thanks Keven for all your answers.

Frank: I think the critical issues what Mozilla concerns have been 
addressed! We need to make sure that naming constraints work as expected.


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-21 Thread Eddy Nigg

On 11/18/2008 05:31 AM, Eddy Nigg:

On 11/18/2008 03:54 AM, Eddy Nigg:


Frank, I greatly missed the thorough and systematic work of Kathleen in
this bug and it's a pity she didn't perform another round of
information gathering in case some new evidence was provided. Anyhow,
I couldn't find anything new in the bug since the last time. I'm not
sure what is supposed to have changed.



I forgot to mention, that in case inclusion is relevant we should gather
additional information about the auditor and independent confirmation of
the audit report.



Frank, can you also check the above mentioned?


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-21 Thread kgb
Hi Frank,

On Nov 20, 9:21 pm, Frank Hecker [EMAIL PROTECTED] wrote:
 Eddy Nigg wrote:
  The Wisekey case could be where we might draw the line.

 I'm not sure exactly which message (of mine or someone else's) you're
 responding to.

 In any case I don't think there's a bright line between the various
 scenarios involving independently-operated subordinate CAs. However in
 general I would look at the extent to which the subordinates are
 operating within a restricted context. E.g., they're associated with a
 single enterprise, they're technically and contractually constrained to
 operate within a relatively small set of domains, etc. At the other end
 of the spectrum the subordinates are essentially general-purpose public
 CAs, issuing certs to multiple customers, for arbitrary domains, etc.

 Based on the information available to us, WISeKey's subordinate CAs seem
 to be at the restricted context end of the spectrum.


Correct. We are at the extremely restricted context end of the
spectrum.

  Provided that

  - there is a *good compelling reason* for using sub-ordinate
  certificates in first place, limited to the domains under the control of
  the owner (via name-constraints) and with reasonable controls in place
  (like annual site visits, proper CA key generation, distribution and
  storage);


We implement all of the above mentioned controls.

 Based on what Kevin Blackman wrote, one major reason for the approach
 taken by WISeKey is the desire of customers to keep subscriber
 information within enterprise boundaries and/or national borders. Given
 the complexities of, e.g., privacy regulations in the US vs. the EU vs.
 other jurisdictions, this seems to me a good reason for an enterprise to
 operate its own subordinate CA as opposed to, for example, just acting
 as a Registration Authority for a subordinate CA operated elsewhere.


This is exactly right. In fact several clients sensitive to this
issue
(Government Central Bank, Judicial Court, etc.) chose specifically
the
BlackBox system for this purpose. In some instances they also use
managed PKI for issuing certificates to external collaborators. MPKI
uses a CA in our data center and WISeKey performs the the email
verification as it is not within the BB's client's domain.

  - name constraints in certificates are working as expected with NSS and
  Mozilla software *;

 Whether certificate-based name constraints are properly working or not,
 I think this is more our problem than the CA's problem, provided that
 the CA's cert don't cause actual technical errors in NSS/Mozilla. If a
 CA is implementing technical measures we consider sound, then I think
 they have done what we expect and require.


Frank, I agree with you.
Our CA controls, audits, etc. are
designed to ensure that all identities are validated appropriately
prior to
certificate issuance. BlackBox CAs are an extremely
restricted CA context where certificates issued
at the CA are restricted to domains owned by the organisation.
It is not necessary for domain constraints to work in NSS software
for
our Root to be accepted, as the control's primary point of operation
is PRIOR to certificate issuance.
Even if domain constraints are not interpreted properly by NSS today,
they
will be in the future, and the certificates issued by our MPKI system
using
CAs in our DCs will be perfectly unaffected.
I am sure that the name constraints implementation process will be
much further along, and our Root still will not have propogated very
far
through the typical update mechanisms.
On our behalf, I thus submit that it would be
a fairly extreme and an unfair penalty to wait an additional year
(the first discussion period was in January of this year) to be
embedded,
whereas the primary controls and practices we use have not changed
significantly from that point in time.

 (And I should add that if there problems in NSS that need additional
 work to fix them, the Mozilla Foundation does have the ability to fund
 such work.)


Mozilla will have our complete support, especially with QA.

Regards,
Kevin

 Frank

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-21 Thread Eddy Nigg

On 11/21/2008 05:16 PM, kgb:

Frank, I agree with you.
Our CA controls, audits, etc. are
designed to ensure that all identities are validated appropriately
prior to
certificate issuance. BlackBox CAs are an extremely
restricted CA context where certificates issued
at the CA are restricted to domains owned by the organisation.
It is not necessary for domain constraints to work in NSS software
for
our Root to be accepted, as the control's primary point of operation
is PRIOR to certificate issuance.
Even if domain constraints are not interpreted properly by NSS today,
they
will be in the future, and the certificates issued by our MPKI system
using
CAs in our DCs will be perfectly unaffected.
I am sure that the name constraints implementation process will be
much further along, and our Root still will not have propogated very
far
through the typical update mechanisms.
On our behalf, I thus submit that it would be
a fairly extreme and an unfair penalty to wait an additional year
(the first discussion period was in January of this year) to be
embedded,
whereas the primary controls and practices we use have not changed
significantly from that point in time.



Kevin, are you recording all domain names and/or email addresses of the 
subject line also in the subject alt name extension? If yes, the problem 
is solved, if not, could you modify your issuance of end user 
certificates to include all of the validated domain names and/or email 
addresses in the SAN extension?


BTW, this is the information I could gather about the state of NSS, it 
seems to me trivial to achieve adherence and correct functioning of the 
software.



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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-21 Thread kgb
Hi Eddy,

On Nov 21, 8:16 pm, Eddy Nigg [EMAIL PROTECTED] wrote:
 On 11/21/2008 05:16 PM, kgb:





  Frank, I agree with you.
  Our CA controls, audits, etc. are
  designed to ensure that all identities are validated appropriately
  prior to
  certificate issuance. BlackBox CAs are an extremely
  restricted CA context where certificates issued
  at the CA are restricted to domains owned by the organisation.
  It is not necessary for domain constraints to work in NSS software
  for
  ourRootto be accepted, as the control's primary point of operation
  is PRIOR to certificate issuance.
  Even if domain constraints are not interpreted properly by NSS today,
  they
  will be in the future, and the certificates issued by our MPKI system
  using
  CAs in our DCs will be perfectly unaffected.
  I am sure that the name constraints implementation process will be
  much further along, and ourRootstill will not have propogated very
  far
  through the typical update mechanisms.
  On our behalf, I thus submit that it would be
  a fairly extreme and an unfair penalty to wait an additional year
  (the first discussion period was in January of this year) to be
  embedded,
  whereas the primary controls and practices we use have not changed
  significantly from that point in time.

 Kevin, are you recording all domain names and/or email addresses of the
 subject line also in the subject alt name extension? If yes, the problem
 is solved, if not, could you modify your issuance of end user
 certificates to include all of the validated domain names and/or email
 addresses in the SAN extension?

 BTW, this is the information I could gather about the state of NSS, it
 seems to me trivial to achieve adherence and correct functioning of the
 software.


For e.g. S/MIME certs, If you mean if subject alt name email
contains the email address, not just SubjectDN-E, then yes this is
the case with the majority of certificates issued by the
BlackBox CAs, but not all.
I took a quick look at some customer SMIME certificates and
sometimes E is only included in the Subject DN.
Some customers don't include the SAN in their certificate
templates, it seems particularly those that use non-western
character sets.

I am interpreting that you mean
modify the issuance of end user certs to
always include the SAN extension, as well as only validated
domain names and/or email addresses. ?

Only validated and approved domain names can be included
in a cert, whether in the Subject DN or the SAN.
It is the default template, and best practice that the SAN
(e.g. RFC822, dnsName) to be filled in the certificates.
Its the case for some but not all customers.

I really hope its not necessary once we can guarantee that
only validated domains are used in the certificates.

Regards,
Kevin

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-21 Thread Eddy Nigg

On 11/21/2008 10:12 PM, kgb:


Only validated and approved domain names can be included
in a cert, whether in the Subject DN or the SAN.
It is the default template, and best practice that the SAN
(e.g. RFC822, dnsName) to be filled in the certificates.
Its the case for some but not all customers.

I really hope its not necessary once we can guarantee that
only validated domains are used in the certificates.



The issue I care mostly about is, what happens when one if these systems 
get compromised without you (the CA) ever detecting. Since those system 
aren't under your control, this is entirely possible and the risk is 
certainly higher than at your infrastructure. The threats may come from 
unknown source or from the customer himself (or their employees).


The from you issued CA certificate with a path length of 0 and naming 
constraints limitation is what convinces me as a reasonable protection 
regarding above case. However it would have to be enforced by SAN 
extension. How come your customers can decide if to include the relevant 
alternative name or not? Isn't this something you should control?


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-20 Thread kb
On Nov 19, 2:27 am, Eddy Nigg [EMAIL PROTECTED] wrote:

 On 11/19/2008 01:59 AM, kgb:

 Hi Kevin,

  WISeKey has made some changes to its practices, since the last public
  discussion period.

 I'm glad to hear that! Can you point to what specifically has been
 changed since then?


 Probably the most important change in stated practice, is that it is
reflected that every CA is audited at least once annually. This is the
case for all active CAs.

   BlackBox Subordinate CAs are restricted to issue
  certificates for domains that are owned by the company that is
  responsible for them, quite unlike the typical root signing done by
  other companies.

 How are email certificates validated beyond that? Are they validated -
 or is it a catch-all verification for all email certificates under the
 respective domain name(s)?


Email certificates are also restricted to the organisation's domains.
We include a Constraint in the Issuing CA itself, preventing the same
CA software to issue certificates that don’t comply with this Domain
Restriction (web, email, User Principal Name, etc.)

The company database (such as existing HR, or IDM) of organisation,
with details of the organisation's users, including their email
addresses, is the principal source of data for certificates.

Bounce back email verification procedure proving access to the email
account is also accepted, but this is inefficient in the enterprise
context, as the enterprises IT systems are aware of the email address
book.

In addition other identity data in the certificate must come from a
verified source, e.g. HR database of identity data that is well-
maintained and was created based on face to face or direct
verification of the person.

  BlackBox subordinate CAs are also audited onsite at
  least once annually.

 By whom? I remember from the last discussion that you weren't performing
 on-site visits or only randomly, download of the software and CA keys
 were provided via Internet download.


Currently it is WISeKey that audits all our CAs, we review the CAs at
least once annually, or more regularly as we are more often present on
some client sites. In addition to the controls we place on issuance,
we also place monitoring controls and obtain regular reports.

All CA keys are generated within accredited HSMs. No CA private Keys
are provided via Internet download - this has never been the case. CA
keys have, and are always generated within a protected HSM.



  There have been changes to the policies and practices. The CIDClassed
  document is a summary of WK practices and certificate classes.

 OK, I will examine this document further then...

  WISekey's products do not circumvent the audit requirement.
  WISeKey's products conform with the basic requirements of the Mozilla
  CA policy. WISeKey subordinate CAs in the BlackBox category can only
  issue certificates containing domain names that have been validated as
  being owned by the customer. These CAs are audited physically onsite,
  there are technical controls preventing the issuance of certificates
  containing any other domain name, and there are additional monitoring
  controls.

 Did your auditor perform random verifications of those visits, verify
 some of these installations and the technical controls? You don't have
 to answer this question, but it would be nevertheless interesting to
 understand the extend of the audit performed.


Our auditor has reviewed all of our policies and practices, controls,
and has accepted them as being sufficient.  The auditor reviews audit
information from all CAs, and can request to visit any or all CA sites
at any time. Which ones, how many, they have done for the last year,
audit etc., is and remains confidential.

 What are your requirements and controls concerning physical and logical
 access to the system(s)? (pointer to the CPS section is fine)


For systems hosted in our DC, section 4 of the Issuing CA CPSs in the
repository applies (www.wisekey.com/repository).
For TrustCenter (BB) CAs - those CAs on customer sites, the relevant
excerpt is as follows:-
4.PHYSICAL, PROCEDURAL, AND PERSONNEL SECURITY CONTROLS
4.1. Physical Controls for the Issuing CA
The hardware and software for the Issuing CA is maintained on-line in
a secured facility with perimeter security and enforced internal
access controls.
4.2. Procedural Controls
No member of staff is allowed to gain physical access or operate any
component of the Issuing CA without the presence of other designated
members of staff who have the skills required to confirm that no
unauthorized or inappropriate actions are conducted.
Procedures are defined and documented for all operations upon the
Issuing CA. Operating procedures are regularly reviewed in the light
of new operational requirements.
4.3. Personnel Controls
All ISSUING CA OPERATOR staff involved in the operation of the Issuing
CA is subjected to background checks and vetting according to ISSUING
CA 

Re: WISeKey root inclusion request (re-start public discussion)

2008-11-20 Thread kb
Hi Eddy,

On Nov 19, 3:14 am, Eddy Nigg [EMAIL PROTECTED] wrote:
 Frank:

 TheWisekeycase could be where we might draw the line. Provided that

 - there is a *good compelling reason* for using sub-ordinate
 certificates in first place, limited to the domains under the control of
 the owner (via name-constraints) and with reasonable controls in place
 (like annual site visits, proper CA key generation, distribution and
 storage);
 - name constraints in certificates are working as expected with NSS 
 andMozillasoftware *;
 - reasonable verifications are performed of the sub-ordinate certificate
 owner;

 I tend to suggest to exclude the audit requirement for this specific
 case. It should however represent the line between the other cases.

 * One thing I'm not sure about is concerning S/MIME certificates and
 their verification requirements. And do name-constraints work with S/MIME?


Name-constraints work on the level of the CA, and this is what we rely
on together with the audit and monitoring tools. The CA looks at its
certificate, and won't issue a request SMIME or otherwise that
violates the name constraints.

 Kevin (fromWisekey):

 Why is a sub-ordinate CA certificate needed for this product, if it's
 limited to a certain set of domain names? Can't the same be achieved by
 simply issuing from a general sub CA under the control of the parent CA?
 What are the differences for the customer (I mean, it doesn't really
 matter if a site certificate or email certificate is issued from a sub
 CA under the control of the parent CA or from a different sub CA under
 the control of the owner. In the end of the day there may be only a
 certain set of domain names for the same set of web sites)?


We offer both types of delivery. We have many managed PKI customers.
However some agencies don't wish their ID information to leave their
premises, or to cross national borders; or desire to have closer
integration with the ID lifecycle management software and internal
directory, which is far easier and more efficient with the BlackBox
system, and its also far more cost effective especially in large user
populations. There are also other reasons, but those are probably the
most important.

 Nelson:

 Do name-constraints work as expected with NSS and Firefox/Thunderbird
 etc.? I didn't had a chance to test this ever...Are there some test
 cases with correctly and wrongfully issued certificate which would
 demonstrate the correct functioning? What about S/MIME certificates?

 --
 Regards

 Signer: Eddy Nigg, StartCom Ltd.
 Jabber: [EMAIL PROTECTED]
 Blog:  https://blog.startcom.org

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-20 Thread Frank Hecker

Eddy Nigg wrote:

The Wisekey case could be where we might draw the line.


I'm not sure exactly which message (of mine or someone else's) you're 
responding to.


In any case I don't think there's a bright line between the various 
scenarios involving independently-operated subordinate CAs. However in 
general I would look at the extent to which the subordinates are 
operating within a restricted context. E.g., they're associated with a 
single enterprise, they're technically and contractually constrained to 
operate within a relatively small set of domains, etc. At the other end 
of the spectrum the subordinates are essentially general-purpose public 
CAs, issuing certs to multiple customers, for arbitrary domains, etc.


Based on the information available to us, WISeKey's subordinate CAs seem 
to be at the restricted context end of the spectrum.



Provided that

- there is a *good compelling reason* for using sub-ordinate 
certificates in first place, limited to the domains under the control of 
the owner (via name-constraints) and with reasonable controls in place 
(like annual site visits, proper CA key generation, distribution and 
storage);


Based on what Kevin Blackman wrote, one major reason for the approach 
taken by WISeKey is the desire of customers to keep subscriber 
information within enterprise boundaries and/or national borders. Given 
the complexities of, e.g., privacy regulations in the US vs. the EU vs. 
other jurisdictions, this seems to me a good reason for an enterprise to 
operate its own subordinate CA as opposed to, for example, just acting 
as a Registration Authority for a subordinate CA operated elsewhere.


- name constraints in certificates are working as expected with NSS and 
Mozilla software *;


Whether certificate-based name constraints are properly working or not, 
I think this is more our problem than the CA's problem, provided that 
the CA's cert don't cause actual technical errors in NSS/Mozilla. If a 
CA is implementing technical measures we consider sound, then I think 
they have done what we expect and require.


(And I should add that if there problems in NSS that need additional 
work to fix them, the Mozilla Foundation does have the ability to fund 
such work.)


Frank

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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-20 Thread Eddy Nigg

On 11/20/2008 10:21 PM, Frank Hecker:

Eddy Nigg wrote:

The Wisekey case could be where we might draw the line.


I'm not sure exactly which message (of mine or someone else's) you're
responding to.


I refereed to the general discussion about sub roots.



In any case I don't think there's a bright line between the various
scenarios involving independently-operated subordinate CAs.


On the other hand I think we should be clear in relation to the 
requirements placed upon the CAs. We should define them as clearly as 
possible in order to allow CAs prepare accordingly.




Based on the information available to us, WISeKey's subordinate CAs seem
to be at the restricted context end of the spectrum.


Yes. Additionally one of the major concerns have apparently been 
corrected! As I mentioned earlier, I think that name-constraints and 
mandatory self-auditing by the CA seem to me sufficient.




Based on what Kevin Blackman wrote, one major reason for the approach
taken by WISeKey is the desire of customers to keep subscriber
information within enterprise boundaries and/or national borders. Given
the complexities of, e.g., privacy regulations in the US vs. the EU vs.
other jurisdictions, this seems to me a good reason for an enterprise to
operate its own subordinate CA as opposed to, for example, just acting
as a Registration Authority for a subordinate CA operated elsewhere.


I think that argument is somewhat far-fetched as the customer could work 
with a local authority instead. As I understood the subscriber 
information have to be disclosed to the CA anyway (monitoring, evidence 
and audit trail etc), hence I'm not really convinced. Integration into 
enterprise infrastructure however seems to me more logical...



Whether certificate-based name constraints are properly working or not,
I think this is more our problem than the CA's problem, provided that
the CA's cert don't cause actual technical errors in NSS/Mozilla. If a
CA is implementing technical measures we consider sound, then I think
they have done what we expect and require.


In this case, name-constraints are clearly part of the policy regulating 
those sub CAs and in my opinion the most convincing argument in favor 
for self-auditing of those installation as opposed to the general audit 
requirement. If name-constrains don't work as expected, an inclusion 
will have to be conditional on implementation. There shouldn't be a 
situation where the issuance of the sub-CA is based clearly on 
name-constraints regulation and NSS can't support it. Right now it's a 
hypothetical concern because I don't know what the situation is. 
Hopefully Nelson or somebody else will provide this information within 
reasonable time.




(And I should add that if there problems in NSS that need additional
work to fix them, the Mozilla Foundation does have the ability to fund
such work.)



Great!


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-20 Thread Eddy Nigg

On 11/20/2008 06:34 PM, kb:


  Probably the most important change in stated practice, is that it is
reflected that every CA is audited at least once annually. This is the
case for all active CAs.



Kevin, thanks for clarifying this. It indeed was one of the concerns 
raised last time.



The company database (such as existing HR, or IDM) of organisation,
with details of the organisation's users, including their email
addresses, is the principal source of data for certificates.


OK.



Bounce back email verification procedure proving access to the email
account is also accepted, but this is inefficient in the enterprise
context...


That's why I asked... ;-)



In addition other identity data in the certificate must come from a
verified source, e.g. HR database of identity data that is well-
maintained and was created based on face to face or direct
verification of the person.


Excellent!



Currently it is WISeKey that audits all our CAs, we review the CAs at
least once annually, or more regularly as we are more often present on
some client sites. In addition to the controls we place on issuance,
we also place monitoring controls and obtain regular reports.


Last question: Are there any sub CAs besides the blackbox product (with 
name-constraints) which are external to your physical infrastructure? I 
think there is not, but can you confirm that?



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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-19 Thread Michael Ströder

Eddy Nigg wrote:


The Wisekey case could be where we might draw the line. Provided that

- there is a *good compelling reason* for using sub-ordinate 
certificates in first place, limited to the domains under the control of 
the owner (via name-constraints) and with reasonable controls in place 
(like annual site visits, proper CA key generation, distribution and 
storage);


I wonder how you want to limit the domains via name constraint extension 
in current business practice. I have a customer who has ~2 
registered domains. They bought another big company with ~3 
registered domains. They usually register all variants of product names 
under all top-level domains so the number is growing quite fast. For 
each domain there MAY be SSL certs issued by an own sub CA.


In this environment the naming constraints are just defined by contract 
with the root CA owner not by cert extension.


Ciao, Michael.
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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-18 Thread Ian G

Eddy Nigg wrote:
I believe that the policy (and/or other relevant policy guiding 
statements) should be clear in respect what Mozilla requires from the 
CAs.



It's a nice ideal, but I wonder myself whether it can be achieved.  This 
is one of the reasons why we have ended up with the race-to-the-bottom 
in secure browsing;  necessitating (?) the EV thing, etc etc.


Here we are, 14 years after this started, and we still haven't got a 
clear and reasonable regime.  That should tell us something :)


Not that I disagree with your central point that it *should be* clear, 
it is just that I wonder if it can be clear.



This is important for planning and preparing for the CAs 
themselves, it's important for us in order to make the right judgment. I 
think that a case-by-case approach is at least unfair and hardly 
sustainable in the long term. 



Yep, exactly, but...



I think in some cases it might make sense to
require audits for all subordinates, and in some cases it might not.


Can you define those cases?



I think if the subroots were managed by the lead CA, and the CPS said 
they were under the same set of policies, then there would be little 
point in requiring separate audits.


If on the other hand they were managed by other organisations, and they 
were not under some agreement, then there is an open-ended question, so 
it might make sense to say (in a Mozo requirement) that uncontrolled 
subroots are to be separately audited.


The problem then being that between those two points there is an awful 
lot of space.



What are the requirements and where doesn't 
and where does it make sense? How to draw the line? You must be specific 
in order for us to understand the differences!



Well, I suspect Mozo doesn't know.  Demanding a solution isn't going to 
result in a solution, but it might result in a line being drawn.  Then, 
in 2 years we'll be back here challenging that line, and grumbling about 
how some smart CA crossed the line or bent it or broke it or made lotsa 
dosh or something.


In such a circumstance, case-by-case makes sense.  Mozo might benefit by 
letting the market experiment.  That old socialism stuff where we tell 
everyone what they have to do is so out of style these days (although 
you wouldn't know it if you looked at the finance markets ;) .




iang
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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-18 Thread Eddy Nigg

On 11/18/2008 05:14 PM, Ian G:

Eddy Nigg wrote:

I believe that the policy (and/or other relevant policy guiding
statements) should be clear in respect what Mozilla requires from the
CAs.



It's a nice ideal, but I wonder myself whether it can be achieved. This
is one of the reasons why we have ended up with the race-to-the-bottom
in secure browsing; necessitating (?) the EV thing, etc etc.


It's not an ideal, but very real, implementable and actually done not 
only here, but also elsewhere. The trend is not a race to the bottom, 
but higher the overall level of quality of PKI after we reached the 
bottom - for the good of all parties involved.


I'm not in favor to invent unnecessary requirements, but a sound clear 
reasonable policy with the basic security requirements covered. This was 
the intention of the Mozilla CA policy in first place which is very 
reasonable. Of course not everything was understood back then and it's 
time to fix a few points.



Not that I disagree with your central point that it *should be* clear,
it is just that I wonder if it can be clear.


Of course it can and I don't see any reason whatsoever why not.



I think if the subroots were managed by the lead CA, and the CPS said
they were under the same set of policies, then there would be little
point in requiring separate audits.



Exactly. As opposed to sub roots which aren't operated by the CA, not 
physically at the same infrastructure and not under the same 
responsibility. An audit must cover the full infrastructure even in case 
the sub ordinate CA is elsewhere.



The problem then being that between those two points there is an awful
lot of space.



I don't think so and a policy requirement can be clear-cut. More or less 
in one sentence.


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-18 Thread kgb
On Nov 18, 2:54 am, Eddy Nigg [EMAIL PROTECTED] wrote:
 On 11/14/2008 11:12 PM, Frank Hecker:
  ...in the short term I'm going to try to restart CA public

 In this particular case I think that the practice in question doesn't
 meet the requirements of the Mozilla CA policy. This includes in
 particular section 6 and 7 of the Mozilla CA Policy.


I believe that WISeKey's practices and polices do meet the
requirements of section 6 and 7 of Mozilla's CA policy, and a review
of the posted documentation and audit guidelines in the report should
confirm that.
WISeKey has made some changes to its practices, since the last public
discussion period. BlackBox Subordinate CAs are restricted to issue
certificates for domains that are owned by the company that is
responsible for them, quite unlike the typical root signing done by
other companies. BlackBox subordinate CAs are also audited onsite at
least once annually.


  WISeKey has been through an initial comment period a while back, during
  which we got nvolved in a lengthy discussion about WISeKey's Blackbox
  product (a CA in a box product intended for enterprise deployment) and
  whether and how auditing was done for WISeKey's subordinate CAs
  associated with that product. WISeKey supplied more information about
  their arrangements, which you can find in the bug.

 Frank, I greatly missed the thorough and systematic work of Kathleen in
 this bug and it's a pity she didn't perform another round of
 information gathering in case some new evidence was provided. Anyhow,
 I couldn't find anything new in the bug since the last time. I'm not
 sure what is supposed to have changed.


There have been changes to the policies and practices. The CIDClassed
document is a summary of WK practices and certificate classes.

 Since I can't find anything new, I assume that nothing has changed and
 therefore the condition for inclusion didn't change at all. If we
 consider that all recent inclusion requests were specifically tested for
 such practices - most notably CAs like Comodo, but also T-Systems who's
 inclusion has been delayed as a result of it - I can't see any
 particular reason for making an exception here. Not only do their
 products circumvent the audit requirement, they might be in direct
 conflict with the basic requirements of the Mozilla CA policy such as
 email and domain validation (IIRC - see comment 32 in bug 371362).


WISekey's products do not circumvent the audit requirement.
WISeKey's products conform with the basic requirements of the Mozilla
CA policy. WISeKey subordinate CAs in the BlackBox category can only
issue certificates containing domain names that have been validated as
being owned by the customer. These CAs are audited physically onsite,
there are technical controls preventing the issuance of certificates
containing any other domain name, and there are additional monitoring
controls.

 (Additionally, I couldn't confirm that this CA commands any significant
 market share with the information at my disposal. I'm the opinion that
 it would be a mistake to make an exception on the audit requirement for
 sub-CAs, which in the future could serve as an argument in favor for
 similar scenarios.
 It was also pointed out at the bug that this CA is in MS software,
 however I suspect their policies to be also in conflict of the MS root
 program. Just some side-note...)

WISeKey is part of the MS Windows RCA program, and have had extensive
discussions with Microsoft's team prior to joining the program. The
conformance of MS products with the IETF PKIX standard enable its
product to work efficiently and cost effectively. They have supported
WISeKey extensively in testing. WISeKey has signed the Microsoft
Windows Root Certificate Program - CA agreement.


 --
 Regards

 Signer: Eddy Nigg, StartCom Ltd.
 Jabber: [EMAIL PROTECTED]
 Blog:  https://blog.startcom.org


regards,
Kevin Blackman
WISeKey SA
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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-18 Thread Eddy Nigg

On 11/19/2008 01:59 AM, kgb:

Hi Kevin,


WISeKey has made some changes to its practices, since the last public
discussion period.


I'm glad to hear that! Can you point to what specifically has been 
changed since then?



BlackBox Subordinate CAs are restricted to issue
certificates for domains that are owned by the company that is
responsible for them, quite unlike the typical root signing done by
other companies.


How are email certificates validated beyond that? Are they validated - 
or is it a catch-all verification for all email certificates under the 
respective domain name(s)?



BlackBox subordinate CAs are also audited onsite at
least once annually.


By whom? I remember from the last discussion that you weren't performing 
on-site visits or only randomly, download of the software and CA keys 
were provided via Internet download.




There have been changes to the policies and practices. The CIDClassed
document is a summary of WK practices and certificate classes.


OK, I will examine this document further then...


WISekey's products do not circumvent the audit requirement.
WISeKey's products conform with the basic requirements of the Mozilla
CA policy. WISeKey subordinate CAs in the BlackBox category can only
issue certificates containing domain names that have been validated as
being owned by the customer. These CAs are audited physically onsite,
there are technical controls preventing the issuance of certificates
containing any other domain name, and there are additional monitoring
controls.


Did your auditor perform random verifications of those visits, verify 
some of these installations and the technical controls? You don't have 
to answer this question, but it would be nevertheless interesting to 
understand the extend of the audit performed.


What are your requirements and controls concerning physical and logical 
access to the system(s)? (pointer to the CPS section is fine)



WISeKey is part of the MS Windows RCA program, and have had extensive
discussions with Microsoft's team prior to joining the program. The
conformance of MS products with the IETF PKIX standard enable its
product to work efficiently and cost effectively. They have supported
WISeKey extensively in testing. WISeKey has signed the Microsoft
Windows Root Certificate Program - CA agreement.


I think some enterprise scenarios are explicitly disallowed by Microsoft 
which your product however could implement nevertheless, specially since 
it's based on MSCA (as I understood). But this is beyond the scope of 
what we do here, it was only a side note from me.


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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-18 Thread Eddy Nigg

Frank:

The Wisekey case could be where we might draw the line. Provided that

- there is a *good compelling reason* for using sub-ordinate 
certificates in first place, limited to the domains under the control of 
the owner (via name-constraints) and with reasonable controls in place 
(like annual site visits, proper CA key generation, distribution and 
storage);
- name constraints in certificates are working as expected with NSS and 
Mozilla software *;
- reasonable verifications are performed of the sub-ordinate certificate 
owner;


I tend to suggest to exclude the audit requirement for this specific 
case. It should however represent the line between the other cases.


* One thing I'm not sure about is concerning S/MIME certificates and 
their verification requirements. And do name-constraints work with S/MIME?


Kevin (from Wisekey):

Why is a sub-ordinate CA certificate needed for this product, if it's 
limited to a certain set of domain names? Can't the same be achieved by 
simply issuing from a general sub CA under the control of the parent CA? 
What are the differences for the customer (I mean, it doesn't really 
matter if a site certificate or email certificate is issued from a sub 
CA under the control of the parent CA or from a different sub CA under 
the control of the owner. In the end of the day there may be only a 
certain set of domain names for the same set of web sites)?


Nelson:

Do name-constraints work as expected with NSS and Firefox/Thunderbird 
etc.? I didn't had a chance to test this ever...Are there some test 
cases with correctly and wrongfully issued certificate which would 
demonstrate the correct functioning? What about S/MIME certificates?



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Re: WISeKey root inclusion request (re-start public discussion)

2008-11-17 Thread Eddy Nigg

On 11/14/2008 11:12 PM, Frank Hecker:
...in the short term I'm going to try to restart CA public

discussions on a regular schedule.


Nice to see you back here!


First, the general issue of auditing subordinate CAs was something we
didn't think through much when we did our Mozilla CA policy: We were
thinking of a fairly simple model where a CA organization operated both
its root CA(s) and also any subordinate CAs under those roots, with a
CPS and associated audit that covered the both root and subordinates
all. In actual practice things are more complicated, and our policy
didn't really capture that complication.


I'm glad that this issue is recognized as such!



My personal opinion is that it doesn't make sense to try to address this
complication by mandating traditional WebTrust-style audits of any and
all subordinates under a root. I think this approach is impractical, and
I don't think it's necessary. I'd rather look at the overall manner in
which CAs exercise controls over subordinates, legally, technically, and
otherwise, as well as the general nature of the subordinates and how
they function in practice.


Even though your statement would on general issues make sense, we must 
also recognize that it would be very difficult to implement. First of 
all it's a matter of policy and every time the policy didn't address a 
specific issue in the past we were in a Grey area. The problematic 
practices were implemented as a result of it.


I believe that the policy (and/or other relevant policy guiding 
statements) should be clear in respect what Mozilla requires from the 
CAs. This is important for planning and preparing for the CAs 
themselves, it's important for us in order to make the right judgment. I 
think that a case-by-case approach is at least unfair and hardly 
sustainable in the long term. Incidentally those CAs which would be most 
likely acceptable by the terms you outlined above, are usually the ones 
which either audit their whole infrastructure or are not affected by the 
problematic practices of sub-ordinate CAs in first place. But obviously 
it's difficult to draw a clear line...


There are various risks Mozilla needs to be prepared to take in case no 
clear policy is defined, mainly the inclusion-by-proxy of CAs (it rather 
would not have included) and questionable practices of sub-ordinate CAs. 
Additionally I believe that Mozilla shouldn't take the risk of including 
CAs (sub-ordinate or not) *without* having their physical and logical 
infrastructure confirmed and audited. Specially problematic are those 
which are independent entities in relation to the root CA and operate 
their own infrastructure (inclusion by proxy). It makes no sense 
whatsoever to require auditing of a root, if the issuing CA isn't 
audited at all. Recent examples have shown that it's no guaranty for 
adherence to the Mozilla CA policy - despite the fact that the very same 
(cross-signed or sub-ordinate) CAs were actually audited independently!!!


(I refrain from getting into the auditing aspects, but it makes a great 
deal and difference for all parties involved. Otherwise Mozilla and the 
other browsers wouldn't made it a requirement from the beginning.)




I think in some cases it might make sense to
require audits for all subordinates, and in some cases it might not.


Can you define those cases? What are the requirements and where doesn't 
and where does it make sense? How to draw the line? You must be specific 
in order for us to understand the differences!



For purposes of this particular evaluation, my goal is for us to gain a
shared understanding of what WISeKey actually does, including getting
answers to any remaining questions, and then I'll make a judgement call
as to whether what WISeKey is doing meets the general intent of our policy.


In this particular case I think that the practice in question doesn't 
meet the requirements of the Mozilla CA policy. This includes in 
particular section 6 and 7 of the Mozilla CA Policy.




WISeKey has been through an initial comment period a while back, during
which we got nvolved in a lengthy discussion about WISeKey's Blackbox
product (a CA in a box product intended for enterprise deployment) and
whether and how auditing was done for WISeKey's subordinate CAs
associated with that product. WISeKey supplied more information about
their arrangements, which you can find in the bug.



Frank, I greatly missed the thorough and systematic work of Kathleen in 
this bug and it's a pity she didn't perform another round of 
information gathering in case some new evidence was provided. Anyhow, 
I couldn't find anything new in the bug since the last time. I'm not 
sure what is supposed to have changed.


Since I can't find anything new, I assume that nothing has changed and 
therefore the condition for inclusion didn't change at all. If we 
consider that all recent inclusion requests were specifically tested for 
such practices - most notably CAs like Comodo, 

Re: WISeKey root inclusion request (re-start public discussion)

2008-11-17 Thread Eddy Nigg

On 11/18/2008 03:54 AM, Eddy Nigg:


Frank, I greatly missed the thorough and systematic work of Kathleen in
this bug and it's a pity she didn't perform another round of
information gathering in case some new evidence was provided. Anyhow,
I couldn't find anything new in the bug since the last time. I'm not
sure what is supposed to have changed.



I forgot to mention, that in case inclusion is relevant we should gather 
additional information about the auditor and independent confirmation of 
the audit report.



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Signer: Eddy Nigg, StartCom Ltd.
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WISeKey root inclusion request (re-start public discussion)

2008-11-14 Thread Frank Hecker
First, my sincere apologies for being missing from this group over the 
past few weeks. A combination of illness (both my own and family), 
out-of-town trips, and other Mozilla Foundation business kept me from 
having any significant time to devote to CA matters. I am working on 
ways to ensure that I am not the bottleneck in this process in the long 
term; in the short term I'm going to try to restart CA public 
discussions on a regular schedule.


Per the CA schedule, the next CA on the list for public comment is 
WISeKey, which has applied to add its (one) root CA certificate to the 
Mozilla root store, as documented in the following bug:


  https://bugzilla.mozilla.org/show_bug.cgi?id=371362

and in the pending certificates list here:

  http://www.mozilla.org/projects/security/certs/pending/#WISeKey

WISeKey has been through an initial comment period a while back, during 
which we got nvolved in a lengthy discussion about WISeKey's Blackbox 
product (a CA in a box product intended for enterprise deployment) and 
whether and how auditing was done for WISeKey's subordinate CAs 
associated with that product. WISeKey supplied more information about 
their arrangements, which you can find in the bug.


We've had some lengthy discussions about the issue of auditing 
subordinate CAs. I'm not going to rehash all those discussions, I'll 
just summarize my current thinking:


First, the general issue of auditing subordinate CAs was something we 
didn't think through much when we did our Mozilla CA policy: We were 
thinking of a fairly simple model where a CA organization operated both 
its root CA(s) and also any subordinate CAs under those roots, with a 
CPS and associated audit that covered the both root and subordinates 
all. In actual practice things are more complicated, and our policy 
didn't really capture that complication.


My personal opinion is that it doesn't make sense to try to address this 
complication by mandating traditional WebTrust-style audits of any and 
all subordinates under a root. I think this approach is impractical, and 
I don't think it's necessary. I'd rather look at the overall manner in 
which CAs exercise controls over subordinates, legally, technically, and 
otherwise, as well as the general nature of the subordinates and how 
they function in practice. I think in some cases it might make sense to 
require audits for all subordinates, and in some cases it might not.


For purposes of this particular evaluation, my goal is for us to gain a 
shared understanding of what WISeKey actually does, including getting 
answers to any remaining questions, and then I'll make a judgement call 
as to whether what WISeKey is doing meets the general intent of our policy.


Frank

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[EMAIL PROTECTED]
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