The other day I snarked about Trustwave’s decision to sell subordinate root (‘skeleton’) certificates to their corporate clients, for the explicit purpose of destabilizing the web’s Public Key Infrastructure ‘legitimately’* intercepting TLS connections. This practice (new to me) is ostensibly only permitted in limited, controlled settings (usually to spy on a company’s employees).

Trustwave argues that the key was always safe inside of a Hardware Security Module and besides, they’re not doing it any more. (Kind of like saying that you handed out the master key to every door on earth but it’s ok ’cause you chained it to a hubcap.)

Unfortunately, the really bad news is that Trustwave may not be the only major CA implicated in this practice. And at least one browser vendor is planning to do something about it:

Dear Certification Authority, 
This note requests a set of immediate actions on your behalf, as a 
participant in the Mozilla root program.  

Please reply by {date 2 weeks out} to confirm completion of the 
following actions or state when these actions will be completed.  

1) Subordinate CAs chaining to CAs in Mozilla’s root program may not be 
used for MITM purposes, regardless of whether it is in a closed and 
controlled environment or not. Please review all of your subordinate CAs 
to make sure that they may not be used for MITM purposes. Any existing 
subordinate CAs that may be used for that purpose must be revoked and 
any corresponding HSMs destroyed by {date TBD}. For each subordinate CA 
that is revoked, send me: 
a) The certificate that signed the subCA. If it is a root certificate in 
NSS, then the root certificate’s subject and SHA1 fingerprint. 
b) The Serial Number of the revoked certificate. 
c) The CRL that contains the serial number of the revoked certificate. 

As a CA in Mozilla’s root program you are ultimately responsible for 
certificates issued by you and your subordinate CAs. After {date TBD} if 
it is found that a subordinate CA is being used for MITM, we will remove 
the corresponding root certificate. Based on Mozilla’s assessment, we 
may also remove any of your other root certificates, and root 
certificates from other organizations that cross-sign your certificates.  

2) Please add a statement to your CP/CPS committing that you will not 
issue a subordinate certificate that may be used for MITM or traffic 
management of domain names or IPs that the party does not legitimately 
own or control. Send me the URL to the updated document(s) and the 
impacted sections or page numbers. 

…

Participation in Mozilla’s root program is at our sole discretion, and 
we will take whatever steps are necessary to keep our users safe. 
Nevertheless, we believe that the best approach to safeguard that 
security is to work with CAs as partners, to foster open and frank 
communication, and to be diligent in looking for ways to improve. Thank 
you for your participation in this pursuit. 

Regards, 
Kathleen Wilson 
Module Owner of Mozilla’s CA Certificates Module 

Now I’m no bomb-thrower, but if it were up to me, {Date TBD} would be yesterday and there would be no re-entry for the CAs caught doing this kind of thing. Still, I’m glad that Mozilla is doing this, and we’re all lucky that they have the independence and browser share to force this kind of change.

But not everything is sunshine and rainbows: