On 10/03/2008 05:37 PM, Iang:
>
> I am not entirely convinced that it is as easy as that. The audit is a
> far more nuanced thing than "auditor checks, it's ok." If you think
> that, then, I've got a subprime to sell you.
>

The WebTrust audit is pretty clear in this respect, not sure what you 
mean really...

>
> In general, I'd agree that even more weak contractual links will not
> help; we should sort out the ones we already have before expanding or
> adding to them.
>

See my reply to Paul Hoffman.

>
> This seems a little black and white. Auditors do not check everything,
> and indeed they do not necessarily check that a particular thing is
> good. What they more do is check that reasonable checks are in place;
> this might be checking of the checking of the checks, rather than
> checking the physical evidence.
>

And how exactly do intent to check the checks that are in place without 
gathering evidence about the effectiveness of those?

> Which is to say, an auditor can check an internal auditing department.
> And lean on that. Or can choose to audit by self. Or some other thing.
> The important thing would be that the method take is clear and obvious
> to all.
>

Self-auditing is part of the EV requirements for example, still a 
third-party audit is done every year. It's best practice and part of the 
controls a CA implements on its own operations. Auditing of the 
sub/cross signed CA by the root is certainly part of the parent CA 
obligations during day-to-day operation, it still would circumvent 
Mozilla's requirement for auditing if the auditor doesn't confirm the 
sub-ordinate CAs.

IMO the controls which we need to be in place in order to be comparable 
to a third-party audit would have to be really, really convincing! 
Basically the CP/CPS would call for auditing those by the third-party 
auditor...

>
> Yes, there is a technical and infrastructure difference, but how much
> does this matter, in a material sense, to a real attack, to a real user?
> Maybe the attacker is just at a different point in the food chain?
>

It's called CA business continuity management amongst others. There is a 
substantial difference between a failure of an RA and a CA.

>
> As to whether the audit is needed ... well, there are *many* issues with
> the overall process. Here's one: what does it offer to the users? How
> much safer to people feel because there are lots of extra audit
> processes these days?
>

I have no intention starting a discussion about the value of audits in 
general. The rest implies the former.

> http://www.sslshopper.com/article-phishing-with-ev-ssl-certificates.html
>

That's out of the scope of what we are doing here.

>
> Ahhh, relying parties, who are they, he asks innocently :)
>

If you'd follow my postings for a while you'd here this very frequently 
from me.... :-)

>
> The current *implication* I would draw is that anything that is
> expressed in the policy applies to all sub CAs. So that particular
> question is covered.
>

This assumption is incorrect - in practice and in policies.

But how do you confirm a particular infrastructure without auditing? 
Assumptions? Because it's in the CPS? Else?

> We would have more of a question about something in a CPS of the primary
> CA, that was reversed in a sub-CA.
>

The issue is about auditing - we know what's in the CPS...

>
> Yes, that's one direction. Internal audit. Another development (which I
> have frequently commented on without any particular favour :) ) is that
> Mozilla itself is auditing the audits. E.g., what's this 40 week
> backlog, if not that process of auditing the audits.

Which shows to me that you've never participated in a real audit...

>
> Have you read the auditor's opinion? It generally starts with something
> like "*management* has put in place procedures and policies..." If you
> don't trust the checks performed by the CA, then you're sunk, because
> the auditor should check the system of checks, not do the checking by self.
>

Same as above...

> These are all standard issues; but they are issues for everyone in the
> food chain. Would an auditor be willing to lose a good paying customer
> because of some "minor deficiencies" ?

No, but the auditor will help correct those (and request some more 
payment perhaps ;-) )

> Does an auditor check every RA
> operation, physically?

No, and he doesn't have to, it's an RA, a function performed many times 
by CAs directly. The RA doesn't control the CA keys, issuance process 
and procedures...basically the RA doesn't control anything really...the 
RA performs part of the process.

> Does an auditor verify the creation of certificates?

Certainly.

-- 
Regards

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