Let's Encrypt’s mission is to create a more secure and privacy-respecting web, except for people residing in countries with the most need for a more secure and privacy-respecting web. Sure, that's great.
That said, pretty sure this is stems from the insane US legal requirement to not export SSL technology to enemy countries. I'm sure some of y'all are old enough to remember when web browsers came in "international friendly" versions that supported 40 bit encryption, or "fancy secure" versions with 128 bit encryption.
Let's Encrypt continues to be available to almost every vulnerable population in the world, including those that need it most. I say almost as I'm hesitant to speak in absolutes regarding a topic as complex as this.
Most of our sanctions-related blocks apply only to the governments of certain sanctioned countries, not their general population.
This subscriber agreement update was intended to better reflect our legal requirements. It does not reflect a major change in the service we provide. Our compliance program does evolve over time, and part of that is communicating about it better in our terms of service. It's clear from some of the comments here that we have more work to do to make that text more understandable, we'll work on that.
> That said, pretty sure this is stems from the insane US legal requirement to not export SSL technology to enemy countries. I'm sure some of y'all are old enough to remember when web browsers came in "international friendly" versions that supported 40 bit encryption, or "fancy secure" versions with 128 bit encryption.
Star Joint Venture is the manager of the .kp TLD and one of DPRK's two email providers (the other is silibank.net.kp) [1], used as the official email for various government bodies ex. ipa817@star-co.net.kp (IP Office), kscost@star-co.net.kp (Sci/Tech Commission), ksf@star-co.net.kp (Ministry of Culture and Sports), mhs-ip@star-co.net.kp (Atomic Energy). It is also widely used by those universities and companies that engage with the outside world.
How did you determine that issuing a certificate to this domain or any .kp domain was compliant with the general ban on exporting goods and services to DPRK?
I only noticed the star net one (not sure if it’s even in use) when writing this. I noticed the Pyongyang Zoo (which shares an IP with the Architects Society—one on 443 and one on 80 lmao) first, just from flipping through their very small IP space on Shodan.
You can see them all on crt.sh, because LE has to upload them to a CT log for browsers to trust them. (That’s how most of those subdomain finder websites work too.) The email servers seem to have gotten certs from a for profit CA back in 2015, but I’m not sure if they ever used them. Most of their webspace seems to be HTTP only. (And it’s a good thing, because some of their Apache versions are potentially old enough to have Heartbleed.)
The architects website has some pretty cool PDF magazines btw. They also have several websites for their insurance company’s (perhaps some intl org needs them to have a website for listing)—that’s a core hard currency stream for them and they previously have been accused of submitting false losses.
> Most of our sanctions-related blocks apply only to the governments of certain sanctioned countries, not their general population.
The agreement very plainly says otherwise:
> You are not a person or entity that is: (a) located in, organized under the
laws of, or ordinarily resident in any country or territory that is the target
of comprehensive U.S. sanctions
The general population of those countries are absolutely "persons" "located in" a "country or territory that is the target of comprehensive U.S. sanctions."
> communicating about it better in our terms of service. It's clear from some of the comments here that we have more work to do to make that text more understandable, we'll work on that.
This tries to frame it as a comprehension issue. It's not.
The wording in your agreement is actually quite clear. I think it's reckless, if not disingenuous to frame this as "we really only mean government entities".
Apropos of anything else, it's also not how US sanctions work - they are absolutely aimed at both the populace as well as the government itself.
They have "clarified" elsewhere on here that the normal citizenry get a legal exemption [waves hands mystically] somehow, and that they're only blocking people when they legally have to.
Obviously (to the rest of us) if the agreement says otherwise, then they're saying that it's LE that is forbidding the citizens of these countries, and it's not (entirely) the government's fault, which completely contradicts what they're trying to say.
We should probably be clear that this document is most likely a backside-covering exercise; it exists so that people can't sue LE for denial of service without a just cause, and so that the US can't prosecute them for intentionally shipping cryptographic services, or some such rubbish.
If you live entirely outside the US legal system, or its multifaceted tendrils, and if you don't make too much noise, you may be fine. Obviously that's a far cry from a "right to free speech" level of protection, but then LE have no obligation to provide that to people outside the US, and arguably non-rich citizens within the US lost that a long time ago.
OFAC sanctions are far more nuanced than what you make them out to be. Very often "general licenses" are carved out for providing IT services or technology to individuals for personal use. The purpose of this is for censorship circumvention, which often supports American interests abroad.
This is not something that you apply for; a general license already applies to everyone. The legalese or restrictions companies use exist because they cannot (or will not) validate everyone is who they say they are. This obviously doesn't apply to companies who deal with controlled exports, where they are responsible for whoever ultimately receives the controlled export.
I get this, but you say "very often", but it's not, and generally, looking at OFAC lists, there's only a few countries with personal carveouts (less than 5 of the countries on the list), usually for remittances, and in a few of those countries only to US persons residing there.
Generally the software carveouts are very limited - it's not just "providing IT services or technology to individuals for personal use", i.e. Sudan:
> software updates for medical devices to Sudan
Indeed, of the software carveouts listed on that page, only two are not related to the operation or update of medical devices:
- provision of Internet services to the people of the Ukraine (read: "Starlink")
- provision of messaging services to members of the Government of Venezuela.
Sounds like "comprehensive" does the heavy-lifting here (in "country or territory that is the target of comprehensive U.S. sanctions"): what countries are under comprehensive sanctions, and which are under non-comprehensive sanctions?
It may be the case that "most of" their sanctions-related blocks apply only to governments (let's say there are 100 such blocks), while they still disallow usage by persons located in a country or territory that is the target of comprehensive US sanctions (let's say there are 50).
Thanks for responding, and to clarify, I am confident that Let's Encrypt is shared as widely as they are able. Could you explain what that requirement does stem from?
> Let's Encrypt continues to be available to almost every vulnerable population in the world, including those that need it most. I say almost as I'm hesitant to speak in absolutes regarding a topic as complex as this.
> Most of our sanctions-related blocks apply only to the governments of certain sanctioned countries, not their general population.
It doesn't work that way.
Blocking governments from getting certs doesn't hurt them in the slightest. The government can just create their own pki.
But it hurts the general population instead. People do not live in vacuum, they still need to access government sites. And thus people are forced to install root certificates of questionable trust.
When Let's Encrypt blocks government entities, it instead puts respective vulnerable population in even less secure environment.
Although, given the current events, I am not sure Let's Encrypt continues to deserve the trust it had.
According to the current administration, almost half of the US is considered a political enemy of the current administration.
Soon they might be pushing for Operating Systems to gather political party preference information, so they can know who should be restricted from the use of strong encryption. The options being:
It'll be interesting when/if they sanction Antifa. Since it doesn't exist, you can't prove that you're not a member of it. So they get to sanction anyone.
> move somewhere more willing to respect international law?
Some of these sanctions are required by international law (i.e. sanctions imposed by UNSC). For the other ones, international law generally lets countries have whatever trade policy they see fit including sanctions, unless they violate some other rule of international law or treaty obligation.
Sanctioning the ICC obviously has nothing to do with trade policy.
The USA signed the Rome Statute but never ratified it, and then withdrew its signatory status. There's an argument to be made that there was a treaty obligation there, but it's pretty weak.
I personally think sanctioning the ICC judges is a disgusting act. However ultimately all sanctions are decisions to refrain from trading with someone, so it is in a sense a trade policy. I think what you're getting at is that usa is implementing that policy to obtain a political/diplomatic goal, which is true, but you could say the same about most trade policies.
I think article 18(a) of the vienna convention of the law of treaties means that once you withdraw your signature, you no longer have any obligations in regards to the treaty.
Maybe you could make some sort of argument that the sanctions violate the purpose of the geneva convention as they are designed to prevent bringing to justice people accused of grave breaches of the geneva convention. Like its an attempt to frustrate the application of article 49 of the first geneva convention [Ianal]
I can't answer why or why not but just in terms of track record the US is fairly egregious. The executive attempts to coerce individual UN officials via sanctions. While it may not be strictly illegal it is clearly flagrantly unethical.
I’m actually old enough to remember how PGP code was exported as a book printout because exporting computer code for cryptography with strong keys in digital form was disallowed but a book was fine (protected by first amendment rights). The printout was scanned abroad to reconstitute the source and build pgp legally.
> pretty sure this is stems from the insane US legal requirement to not export SSL technology to enemy countries
This is most likely OFAC. Lets Encrypt could apply for a license to do business with sanctioned entities, and given their use case it would most likely be approved.
OFAC regulates commerce, not speech. Let's Encrypt is not doing "business", they're operating a free informational service. Lots of organizations interpret any information exchange as subject to OFAC regulation, and you and Let's Encrypt have good company in this interpretation, but I think it's unnecessarily ceding ground.
The government may use as wide of an interpretation of commerce as they can get away with. We've seen this happen before [0]. Sure, Let's Encrypt isn't taking money from the entities they offer certificates to. But the OFAC desk jockey assigned to that case only has to concoct some sufficiently plausible-sounding trail of money connecting the backing 501(c)3 and a sanctioned entity in order to levy penalties, and the legal team will not like that risk, even if it's unlikely for OFAC to win on appeal in a court.
This is true, of course, and I understand why some companies don't want to take the risk. But I would hope that Let's Encrypt would take the opposite stance. They were born out of the EFF and have EFF & ACLU board members! These orgs live for this type of legal fight.
IANAL, but it seems like the argument from Wickard v Filburn would apply to LE. They may not be taking money but they do impact the commerce of the market for certificates.
I disagree with that ruling, and I have some serious problems with sanctions against entire countries/regions, but it definitely makes sense that LE would interpret it as being impacted by OFAC.
Providing information (website, CT log, CRL) is fine, but creating a certificate on request is clearly a service. How is that different than providing a computation or LLM output in response to a prompt? Moreover, it is clearly not just the physical act of signing a CSR, but the verification of ownership that comes with it. That's just as much as service fully automated as if a human were doing it.
Now, does this serve a policy purpose? Perhaps not--US computers trust plenty of non-US CAs that could continue to serve these customers. But that's not how comprehensive sanctions are set up, they are effectively a complete embargo.
A better question is whether telecom carveouts (general licenses) in the sanctions may allow this. That is a country by country question as each one is worded differently.
OFAC has authority to regulate commercial services under the Commerce Clause. Not all services are commercial in nature. There is no economic exchange inherent in running a certificate authority. If LE charged money for certificates, that would be a different matter. LE's differentiating factor from the previous era of CAs is that they are non-commercial.
In an alternate universe, Let’s Encrypt has a chat with someone and then states, publicly, like a speech, that they think that person owns a domain.
In our universe, Let’s Encrypt lets a client open an “account”, enters into a contract with the client (the contract is the topic of this entire post), and gives the client an API by which the client requests a certificate. Then Let’s Encrypt grants the certificate. Maybe the certificate is somehow speech. The rest sure doesn’t sound like speech to me.
Seems in all thing tech at the moment the US legal system is accelearting a great split and erectinga digital iron curtain, from AI models to the more mundane like TLS certs.
Its been standard for a while for many Linux distros based in the US to toe the party line - like RedHat having notices pretty similar to this one by LE.
Seems any meaningful Open Projects will have to choose what path they want to take, be like RISC-V and relocate or LE and others and enforce the divide.
It isn't just the US. China, Russia, the EU, and Australia and probably others are all increasingly trying to create virtual walls of various forms in the internet.
It is in the nature of nation states to assert control over national borders. That the Internet and the globalised flow of information it enables circumvents this is a historical anomaly.
Woah, I had no idea about DARPA and RISC-V. I wonder why they care about RISC-V so much? This is the best explanation that I can find:
> Open source standards provide great benefits to U.S. taxpayers in reducing the cost of advanced military system development, and also increases security by allowing the government to build their own trusted implementations at low cost.
> RISC-V International has not incorporated in Switzerland based on any one country, company, government, or event. This move is reflective of community concern and managing strategic risk for our community investing in RISC-V for the next 50+ years.
So what? If I disagree with the direction any FOSS project (or its maintainers) is taking... I can just fork it. People have done that countless times in the history of FOSS, most notably in the xOffice schism.
No remotely western company will risk US sanctions violations or whatever other regulatory burden by using US technology where it can't be used. Even Chinese companies depending on how state backed they are might not be willing to risk it.
This is the big irony of the current situation: while the US is dependent on China for manufactured goods, China is dependent on the US for external demand for its manufactured goods.
One is the mirror image of the other and neither economy can exist in its current state in isolation.
So China has the US over a barrel when it comes to actually building stuff, rare earths and all of that, but equally US sanctions still have real bite (a lot more than China would like) because China does have to do a huge amount of international trade to export and externalise its surpluses.
I wore the rsa-dolphin t-shirt all over the place and nobody batted an eye back then, but a dolphin made up of ASCII characters is quite a bit less obvious than the one you linked.
OpenBSD being based in Canada ships strong crypto, but has had a sometimes troubled relationship with certain regimes.
> Let's Encrypt’s mission is to create a more secure and privacy-respecting web, except for people residing in countries with the most need for a more secure and privacy-respecting web. Sure, that's great.
If complying with the law gets in the way of the mission I’m not sure that counts as a change to the mission.
Should NRA hand out guns to everyone who can’t get a permit where permits are required? Of course not. If they are against gun permits they have to fight the law, not break it.
The National Rifle Association (NRA) describes itself as America’s longest-standing civil rights organization.
That is a specific US-internal stance.
There's a list of organizations that started in the US, ultimately having had to work around the US legal system, in pursuit of their missions:
re Planned Parenthood Global, WikiLeaks, International Campaign to Ban Landmines, Center for Reproductive Rights, selected programs of the Human Rights Campaign Foundation, et al
This is why, as someone who works in security and encryption and has implemented web server TLS stacks and such, I still oppose the "always-https" idea.
TLS is awesome, one of the most valuable developments in Internet history. But, it is important to undewrstand that it is a double edged sword. Requiring a CA, which in practical terms means requiring a publicly known CA, is a choke point of freedom.
What "backdoor" would Let's Encrypt even implement? That's not how a CA works.
They might be compelled to issue a certificate to an unauthorized (by browser PKI policies, not local law) entity, but that would be very conspicuous due to Certificate Transparency.
How would they do that? The ACME protocol is "take the basic artifacts you use for certificate signing, wrap them in JSON (cryptographically, using standard JWS), then send them over using HTTP + TLS." Every part of that is something for which there exists a buttload of implementations in whatever language you care to use.
> Those methods include covert measures to ensure NSA control over setting of international encryption standards, the use of supercomputers to break encryption with "brute force",
Things that definitely don't happen. Those same encryption standards are used by the US military, and the international cryptography community can pretty readily rule out keyed backdoors.
The thought that supercomputers could break Internet encryption by brute force is laughable. One would have to be innumerate to think such a thing.
Anonymity and encrypted communication are two very, very different things. Have one but not the other and you're essentially handing off your private data incl. passwords to whoever that has a tap on the communication between you and the server can fetch them, too. Have the other but not the one and everyone will know who you are, but they can't eavesdrop.
I've had people straight up serve me malware when you attempt to OSINT them with Tor. Sometimes you need different kinds of anonymity, and I see a lot of one sized fits all proclamations on HN.
I mean, noone is stopping someone to clone letsencrypt - it shouldn't be very hard.
Google had a similar dilemma - do they want to offer a (censored) service in China, and have a hope of keeping some marketshare, or not (and be kicked out immediately).
In this case though, it seems to be an unforced move by letsencrypt ? Or was it compelled by LEAs?
Couldn't LE have a branch in Europe or anywhere outside the USA and its minions?
Because they're betraying their own goals, as stated in their About page: “It is a service run for the public’s benefit. [...] Anyone who owns a domain name can use Let’s Encrypt to obtain a trusted certificate at zero cost. [...] Let’s Encrypt is a joint effort to benefit the community, beyond the control of any one organization.” Now they own they are under the control of a political organization.
Here is the paragraph Let's Encrypt added to their Subscription Agreement on 2026-06-04:
> You are not a person or entity that is:
> (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target
of comprehensive U.S. sanctions;
> (b) a prohibited or restricted party under U.S. or other applicable sanctions and export control laws and regulations;
> or (c) owned or controlled by or acting on behalf of anyone described in (a) or (b).
> You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations.
RISC-V Foundation did.. though they go out of their way to talk about it in terms that try not to piss anyone off..
> "Across 2018-2019, the RISC-V community has reflected on the geo-political landscape and we have heard concerns from around the world that investment in RISC-V must come with IP access continuity to ensure a long-term strategic investment. We first mentioned our intentions to move at the December 2018 summit. Incorporation in Switzerland has the effect of calming concerns of political disruption to the open collaboration model. RISC-V International does not maintain any commercial interest in products or services as a non-profit, membership organization. There have not been any export restrictions on RISC-V in the US and we have complied with all US laws. The move does not circumvent any existing restrictions, but rather alleviates uncertainty going forward.
> In March 2020, the RISC-V International Association was incorporated in Switzerland. Along with this, we shifted to a new, more inclusive membership structure. Members of RISC-V International have access to and participate in the development of the RISC-V ISA specification and extensions as well as related hardware and software. RISC-V has a Board of Directors composed of member representatives as well as a Technical Committee of work group leaders."
> RISC-V International has not incorporated in Switzerland based on any one country, company, government, or event. This move is reflective of community concern and managing strategic risk for our community investing in RISC-V for the next 50+ years.
> The IP contributed and produced by RISC-V International is held under industry and global standard licenses that are already open to leverage by any company regardless of jurisdiction. This licensing is a common open source approach to foster collaboration that is not tied to any geographic regulation. IP in the public domain has not been subject to export control.
The RISC-V foundation and related companies also got a bunch of money from Europe. I am not so sure this was about leaving a repressive regime as much as chasing the European "homegrown computing" money.
This is part of why the EU is looking to move away from US-based infrastructure. The CLOUD Act basically lets Washington have an off-switch on your computing infrastructure as well as giving Washington unlimited access to any data on your computers (or that passes through them).
This is not about countries sanctioning each other. This is the US sanctioning a local company because a foreign company doesn’t follow certain US laws in foreign soil, where such laws don’t apply.
It’s a bit like the US arresting your mom at home in Texas because you ate a baggie of magic truffles in Amsterdam.
You're being very vague. Please explain what you mean? I don't see anything here about the US "sanctioning a local company," and I'm not aware of that being possible under US law.
The way you are using these words seems to indicate you might be confused about how this works.
The US has not "sanctioned" LetsEncrypt or ISRG. The US sanctions foreign entities as punishment for various reasons precisely because they are not subject to US law. That's the entire point of leveraging a sanction -- to pressure those outside of your legal jurisdiction. If they were in your jurisdiction, you'd simply arrest them.
People and organizations basically anywhere not permitted to do business with anyone your country has sanctioned. Anyone who does business internationally should be aware of their country's sanctioned list. That applies no matter where you live on the planet.
This is literally about a company that has a branch in the USA and another branch in another country, where it's bound by that country's laws. If the foreign entity which just so happens to be commercially linked to the one in the USA has any dealings with countries sanctioned by the US, the US branch is punished.
There was a case a few years ago where a public University in Brazil bought lab computers from Dell Brasil. Dell Brasil is a subsidiary of Dell, but it's 100% incorporated in Brazil, the computers were manufactured in Brazil, everything following Brazilian law. The computers were delivered with terms of service that prohibited them from being used for any dealings with US-sanctioned countries such as Iran and Cuba. The University was caught by surprise and questioned it, since they had many academic links with Cuban Universities, and Dell Brasil explained that.
I don't know how the whole ordeal ended. The Brazilian Federal Government got involved, I believe the Ministry of Exterior and the Ministry of Commerce and Industry both got involved and were at one point going to sue Dell Brasil. I suspect it ended with the University returning the computers and purchasing from another supplier.
The suggestion that Let's Encrypt could work around US sanctions by opening a branch in the EU falls under similar conditions, and the US branch would be liable if the EU subsidiary had dealings with US-sanctioned countries.
Incorporating a subsidiary in a foreign country doesn't make the parent company immune to the legal obligations it has in it's home country. It would be absurd if that were the case. Sometimes people try setting up subsidiaries overseas to hide their evasion of the law, but it is illegal to do so.
> Incorporating a subsidiary in a foreign country doesn't make the parent company immune to the legal obligations it has in it's home country.
We're not talking about legal obligations in its home country though. I can buy Jack Daniels at age 19 in my country from their local subsidiary, and no-one thinks that this should be a crime for their US parent company because the US drinking age is higher. (Of course it would be a crime for either the parent or the subsidiary to sell to 19 year olds in the US)
(No-one is blaming Dell or Let's Encrypt here, to be clear, it's the US' excessive extraterritorial laws that are the problem)
If you are in the US you must ensure that your local company, and any sub-entity you control abroad complies with sanctions law. That is US law, and the US can apply that law to Dell the parent company, because it is in the US and controls the subsidary.
> I can buy Jack Daniels at age 19 in my country from their local subsidiary, and no-one thinks that this should be a crime for their US parent company because the US drinking age is higher.
Because there is no US law that says you cannot sell alcohol to people abroad under 19. Heck, there's no US federal law that says Jack Daniels can't sell to people in the US under 19, either. And in fact, there are some places in the US where you can legally drink at 18, e.g. Puerto Rico. But if the US congress wanted to pass one of these laws and enforce it, it could.
US sanctions law saying that you must not transfer X from the US to Iran, directly or indirectly, is reasonable. US sanctions law saying that you must not transfer X from Brazil to Iran is gross overreach. Yes, of course the US can apply its absurdly extraterritorial laws to any parent company in the US, just as Iran could penalise any Iranian company whose US subsidiary distributed a depiction of the prophet or whatever, but that doesn't make it good law or good practice.
But the US isn't really unique in applying their laws extraterritorially. See GDPR, Universal jurisdiction laws, China's National Security Law, etc... Every jurisdiction with sizable power does it. Some of these are even more extraterritorial in scope than US sanctions are.
Only applies to EU citizens' personal data, so while technically extraterritorial it doesn't feel like overreach in the same way.
> Universal jurisdiction laws
Rightly controversial when applied beyond things that are internationally agreed to be crimes against humanity, like torture or genocide.
> China's National Security Law
A perfect example of the kind of thing that the US used to define itself in opposition to.
Nations are sovereign and those with the might to push their requirements on others can do so. But I liked it better when we had a sense of the value of an open international order, where things like internet protocols were shared standards that everyone would collaborate on other than a handful of pariah states.
The difference between any of these is just a matter of opinion on what sovereignty means, what or who or where it applies to, what is a “human rights violation”, and who has the bigger britches to back it up. /shrug
Meh. You can fall back on might makes right and a Hobbesian war of all against all, or you can recognise that the Westphalian system has brought immense value to humanity and is worth trying to preserve and build on. There will always be disputes about how to extend our principles into new domains, but that doesn't mean those disputes are insoluble or that a few disagreements mean we should tear down the whole project.
The GDPR applies to the personal data of anyone physically in the EU, to the extent that the data are processed[0] while they are in the EU.
It also applies to the personal data of anybody anywhere in the world if the data controllers are based in the EU.
The reason why it's different to US sanctions/export controls is that the GDPR doesn't say you can't work with certain people in certain circumstances because of who they are in order to punish those people for whatever reason. It's fundamentally to protect the data subjects.
You may call it a subsidiary all you want, but it's still a company that's wholly incorporated in foreign soil, doing business in foreign soil.
At least in Brazil, companies that operate there must obey local laws. What happens when those laws are in contradiction with US laws, like in the example I cited? Is Brazil supposed to cave? Is Brazil supposed to keep fining Dell Brasil until it folds? Maybe prosecute Dell Brasil's directors for actively and repeatedly disregarding the law and fines?
How does that work on a global scale?
I'll say again, this is not about a US company opening a foreign subsidiary to do things in the US that are forbidden in the US. This is about a company incorporated abroad having to follow US laws while operating wholly abroad. This is a breach of sovereignty however you look at it.
It is plainly routine for a company to have to deal with multiple legal jurisdictions at a time.
Yes, sometimes this causes compliance complication. This isn't unusual, it happens frequently.
Ultimately, every government exercises the laws of their country as they see fit, using the enforcement tools they have available to them. These rules often extend outside of their borders and apply to foreign or partially-foreign entities depending on the situation. The only limits on this are the practical means of enforcing it.
Dell Brazil would have been subject to Cuba sanctions because it was controlled by the US parent company. The US has obvious jurisdiction over Dell Technologies the parent company, and the nexus to enforce it.
Nothing you are are describing is even remotely unique to the US. No country is going to let you set up a foreign subsidiary to launder goods around sanctions law. If they did, everyone would do that and nobody would ever follow sanctions.
I don't know, and to be fair they might have done just that - and it wouldn't surprise me if that happened with the blessings of the Federal Government.
As I mentioned, I didn't follow up on the story and in fact when I searched for it a few years ago, I couldn't even find the original articles any more.
Ah, so it would be like the EU fining a US based company for not following certain GDPR laws even if they don't have a presence in the EU? Definitely would never happen!
If they set up a subsidiary in Europe, they could be held liable for actions of European subsidiary.
If an independent org is stood up in Europe, with European directors, staff and funding, legally independent of US org, and the US org just provides advice/assistance to Europe org without ability to control it-legal liability for US org for Europe org’s decisions is less likely. Of course, ask a lawyer-but if you openly say “we are doing this to work around US sanctions” you could still be liable; if you say “this has nothing to do with sanctions this is about resilience of global digital infrastructure and European digital sovereignty” then under what legal theory is the US org liable?
It shouldn't be located in Europe (because, as you said, US minions are no better than the US itself). Instead it should move to a neutral country, somewhere like Singapore or Uruguay.
You're assuming that satellites are exterritorial. They aren't, they're ab initio the launching state's property and responsibility, barring other agreements to transfer them - and getting one out into a "legal void" isn't going to be trivial.
Over the centuries I am sure there will be random satellites that are defunct that will be hacked or otherwise "taken over" by someone with the right skills. These things are tiny compared to the distances involved and in the future you might end up using them as data reservoirs since in many cases it will be cost prohibitive for any authority to go collect or otherwise stake authority over an old piece of hardware considered junked.
In a hundred years, sure. Current satellites have neither storage nor compute capabilities of note.
That said, they don't have to grab the satellite. They have to grab you. Computer vandalism/sabotage/... laws in a lot of legal systems already apply to the controlling people in their home location regardless of the physical location/origin of the computer activity. Your controlling the computer/satellite/botnet/... is the illegal act, not the network packets leaving those systems.
They'll have to identify you first though, which might give some legal shielding.
A ship in international waters with satellite internet connection would be much cheaper, except it runs into the same problems as described by the sibling comment: https://news.ycombinator.com/item?id=48469397
Let's encrypt is not some code or even a company that you can split into different branches. Their existence is one based on trust relations that let's encrypt has with browsers and operative systems. It is in one part similar to both domain names and IP address space, in that the technical aspects of creating alternative roots is almost trivial in comparison to getting the trust that is required for an alternative root to be accepted by the rest of the world.
Let say someone created an Russian Let's Encrypt. It has all the technical aspects as regular LE in that you can request a certificate and get one through an acme challenge. That is all great and all, but no browser will recognize it as valid. No operative system will recognize it as valid. The Russian state might add the new LE as valid for government computers, but the real work would be to get any other participants in the world to do the same. The issue is not a technical one but rather a social one that is built on trust.
When Russia invaded Ukraine there was a major discussion if IANA/ICANN should have disconnected Russia from domain names and IP addresses. That discussion ended on a decision to not do that because the symbolic benefit was deemed minor compared to the harm to the system in large, especially once the war end. If you got two roots, then a domain name or IP address can now suddenly have two locations, and it would be a massive pain to try fix it even if people wanted to fix it. Certificate Authorities do not share this trait since there can be an almost unlimited number of roots and none of them can conflict with each other (assuming no hash collision). If Russia spins up a new CA then people can use that one today if they want to, and they can continue to do so after the war has ended.
It is a lunacy, complete delusion to think that privately owned (by oligarchy) root CA that trusted by every web browser and OS on the planet is somehow superiorly safer from the point of state actor attack than those explicitly state owned root CA. You must be livin in fairyland.
Iran is blocking internet for months, US ...bans creation of secure connections - that'll show 'em!
Russian quasi-government structures are spending quadrillion of rubles on a TSPU (censorship system) to spy on Russian residents, US ...helps them by making snooping on what is currently encrypted traffic possible by banning accessible encryption!
Sanctions compliance is unfortunately fairly complex.
Let's Encrypt can issue certificates for non-government entities in Iran and Russia due to statutory exemptions protecting personal communications, alongside specific Office of Foreign Assets Control (OFAC) authorizations designed to promote Internet freedom and human rights.
We will look into whether we can make things more easily understandable in the subscriber agreement.
> You are not a person or entity that is: (a) located in, organized under the
laws of, or ordinarily resident in any country or territory that is the target
of comprehensive U.S. sanctions
Seems to be pretty clear that it would include non-government entities in sanctioned countries.
I'm not sure if you're talking generally about sanctions or specifically about Let's Encrypt, but to avoid any doubt: citizens of Crimea are free to use Let's Encrypt. We do not, however, serve government entities in occupied Crimea.
you should update the documents to reflect this stance.
"You are not a person or entity that is: (a) located in, organized under the
laws of, or ordinarily resident in any country or territory that is the target
of comprehensive U.S. sanctions; "
this says nothing (edit: specific) about government (edit: only), and is applicable to normal people in those areas.
[Iranian here]
Completely agreed. Reminds me of how US banned citizens and businesses in Iran from using cloud infrastructure like AWS or digital ocean, leading to people and businesses moving to the government-sponsored local cloud services, and that made it super easy for the government to block internet access whenever they want without essential services like banking, ecommerce, online taxi booking, food delivery etc being disrupted.
TSPU isn't for spying, it's for censorship enforcement and everything else that makes the experience of using the internet here miserable without a VPN. It's SORM that's for spying. And Roskomnadzor is very much part of the government.
This somehow confirms my gut feeling that digital certificates are mainly a means to enforce exclusion on behalf of the certificate authority ownership.
It is a tool to prevent people from taking full ownership and control of whatever is affected by digital certificates, be it software, firmware, hardware, or as in this case SSL/TLS.
That's digital tyranny in disguise.
While it seems like certificate authority has the primary control here, the real control lies in browsers and operative systems in which certificate authorities are trusted. Users also have, at least for the moment, control to add or remove certificate authorities, even if that control is slightly less clear for devices like smart phones.
Digital certificates that signs software packages are used to enforce exclusion by some manufacturers. Let's encrypt is not in that space to my knowledge, but it is a place where you the owner do not have the right to determine which certificate authority should be trusted, and generally the only one that is trusted is the manufacturer. Its arguable if we even should be calling such entities a certificate authority, even if they technically are the owner of the root certificate that signs the package.
I always saw it as a trust-chain and think that anyone is welcomed to create a root certificate and distribute it to whomever trusts them. Most simple services may not need TLS, but with the ISPs eavesdropping on our communication, a form of secure communication is required and the currently best solution we have requires a trust-chain to be built.
It is such a great improvement that ISPs cannot eavesdrop us anymore... only for everyone to terminate TLS at cloudflare so they (and thus US government) can now eavesdrop everyone.
Ultimately, I find it likely that TLS will become a tool to prevent users from accessing foreign content (browsers stubbornly refusing to show untrusted sites in the name of security, slowly getting there), more than a tool to prevent eavesdropping on users secrets.
If you have a service that shares information between people all over the world, a few big companies and one government is for most cases an improvement over all the involved ISPs and all of their respective governments.
>> 99.99999999999999% of internet users have no idea what root CAs even are
that would be like *checks math* less than a human aware of root CA? Can't be right.
anyway, people living in russia are statistically more aware. There was a campaign after new root CA was issued. It was on a news, on the official channels, in the mail and on the posters. A lot of government sites begged to install them whenever you visited.
I trust governments much less that a conglomerate of competing corporations.
With all the problems with Web PKI, at least the bad actors are getting distrusted, and this provides a very strong enforcement on the rest. And Certificate Transparency makes sure the mis-issuance would be caught. It is not perfect by any means, but things are getting better.
With DANE (or other country-issued certificates), every government will absolutely double-issue certificates to police, secret service and friends of goverment, and no one will have any recourse. (In the past I'd say that only countries like Russia would do it.. but with today's climate, I am sure both US and many European countries will do that too)
Companies have run some absolutely outstanding PR then.
I have never worked in any company where I explicitly trust the CEO to always do the right thing in every situation.
There is usually no governance board, or review system to inquire about public harm: those things are usually external and fought against as they are regulatory burden.
So, in practice what tends to happen is that someone in the company just does stuff. Since humans aren't perfect this "doing stuff" is not always super enjoyable. If it's the CEO who "does stuff" then you're cooked because nobody except the board of directors can say anything meaningful: you gotta hope that the media wants to put pressure on.
Our elected officials on the other hand, are supposed to represent us, and thus media pressure is a lot stronger; issues that affect many people are meant to be properly reflected, and their decisions are open by default.
I'm not really in favor of DANE, because DNSSEC is such a mess ... but.
Certificate transparency is nice. Browsers could require it for DANE certificates, just like they require it for current Web PKI certificates.
The people controlling the TLD of interesting can exert control over the domain of interest in order to issue a DANE certificate. But they can also exert control over the domain of interest in order to request a domain control certificate, so widespread use of DANE wouldn't add any new adversaries. If DNSSEC wasn't a mess, and DANE replaced WebPKI, we would eliminate the risk from CAs without adding a new risk --- TLDs (and the DNS root) are existing risks.
And if they don't, DNS is already a database. You could just query domains to check their certificates. People running recursive DNS servers could double-check certificates.
CT seems useless for DANE because the cert is self signed, so anyone can just flood the CT with self signed certs for your website. It's useful with WebPKI because only certs signed by a CA go in CT and it's a big deal if one is mis-issued. Anyone can mis-issue a self-signed cert at home for fun.
You'd have to do something like pre-publish in DNS, submit to CT which verifies that it's in DNS before logging. And the CT could rate limit on domain name or something to reduce abuse.
> every government will absolutely double-issue certificates to police, secret service and friends of goverment, and no one will have any recourse.
Countries already have CA that issue certificates with more legal force than a handwritten signature. I can open a bank account, pay my taxes and sign up to all government services. But I can't use them for a webpage.
> With DANE (or other country-issued certificates)
DANE isn't a country-issued certificate. It's a scheme where you store your public keys on DNS records. Of course, now we have the issue that DNSSEC (signed DNS records) isn't widespread and the whole issue with DNS registries.
DANE is entirely dependent on DNSSEC, and DNSSEC is, by design, under the government control, with all the bureaucratic mess and mistakes this implies.
This would be pretty terrible if anyone actually cared about DNSSEC, but luckily for us, no one cares.. So let's keep things this way.
Domain registries can already get a certificate for your domain by changing the address to their own server temporarily and then doing ACME with LE. So no new vector is introduced by directly putting the cert in DNS.
> I trust governments much less that a conglomerate of competing corporations
Let's not create a world wide PKI based on a political ideology.
> country-issued certificates [...] every government will absolutely double-issue certificates
This is such a strange argument. If you register a .ru domain, do you really think you are safe should the Russian intelligence services ask for a valid certificate? Controlling the actual domain, they could issue ask many domain validated certificates as they wish.
The problem with our current SSL PKI, as so very many people have pointed out over the years, is that any CA is allowed to issue valid certificates for any domain name. There have been proposals to use X.509 extensions to remedy this, but they have seen lesser real world usage than the various certificate revocation schemes, which is very close to zero already.
If there was no way for a Russian CA to issue certificates for .us domains, real world security would improve. A lot. And the other way around, of course.
Feel free to s/Russian/Chinese/ in the above argument or whatever tickles your geopolitical fancies. The argument still stands.
Domain registries decide who owns what domain. That is their literal role. You would think that asserting this ownership cryptographically would be a no-brainer in 2026. Yet we have this discussion over and over again. There are many people whose income quite literally depend on the status quo of our global SSL PKI, which coincidentally also offers no end of possibilities for the various intelligence services around the world.
The next time someone tries to scare you with that governments or intelligence services control DNS and therefore it would be crazy to limit issuance of certificates to them, take a look where they have contracts.
> The problem with our current SSL PKI, as so very many people have pointed out over the years, is that any CA is allowed to issue valid certificates for any domain name. There have been proposals to use X.509 extensions to remedy this, but they have seen lesser real world usage than the various certificate revocation schemes, which is very close to zero already.
Some of the browser root programs include (or have included) restrictions on what tlds a CA is allowed to sign. I think for some of the iffier CAs that nonetheless had a huge marketshare in their country of origin.
No need for the CA itself to include it in their root certificate.
It would be handy if the name restrictions actually worked though. Then you could probably get a CA to sign an intermediate CA authorized only to issue certs for your domain(s). There are some CAs that will do that already where they provide an HSM with the intermediate CA's key that will only sign certs for authorized domains, but the CA cert does not encode the constraint and this is permitted by the ca/b agreement. It just seems like it'd be nicer if it just worked.
It's not that high of a requirement. The sub-CA is allowed to self audit. But the original CA does have to check a percentage of certificates issued by the sub-CA.
So that's not going to be free. But it might be possible to do it if you were big enough to pay for it. I have dreams of having my private CA also signed off on by webpki so apps and browsers could use the same servers without having to include webpki in my apps.
I also started going down this rabbit hole when I wanted my homelab to just work in any device, and for advanced use cases Let's Encrypt isn't enough. I tried long and hard to get a sub-CA certificate, but apparently that's in the realm of «if you need to ask, you can't afford it».
If each country could only sign its own domains it would make sense. If the US could only tamper with .us domains the system could be trusted in general. After all, that's no worse than what they already do by coming to your house and putting a gun to your head.
Yeah, that's why most countries in EU, as well as US, are in a huge dissarray, politicians have all time low approvals, people vote for something and get the opposite, and the economy and social climate turned to shit...
I guess one doing well enough can be oblivious to all this...
Maybe, but then can only do it once. Then they get caught, and their CA is distrusted. See Diginotar [0] for example.
And things only gotten better since - we now have CT logs, and browsers require them, so any mis-issuance can be detected automatically, by any interested third party.
If we go to DANE, we lose this all. "Oops, our CT uploader process failed, we will fix Real Soon(tm) we promise" - and what are browsers going to do? Distrust the entire country?
Side note: “DigiNotar BV was a Dutch certificate authority from 1998 to 2011. It was acquired in January 2011 by VASCO and subsequently declared bankrupt in September of the same year” [1].
I didn’t realize the slapped their face on the pavement right after being acquired.
Apparently the cost of TLS these days is to subject yourself to whatever laws that countries of "free" TLS want to impose on you. That isn't very cheap.
I'd also love TOFU for TLS, at least on .local TLDs, but for publicly hosted websites, I've come around to the idea that maybe encryption without authentication would not help that much these days.
As for who does that authentication: Given all the suggestions in the sibling threads, I really don't think we're in a situation where there's a single entity gatekeeping access by any means.
Philosophically, trust isn't a "solvable" problem. It can only be mitigated to varying degrees. However, some degree of trust is probably better than none.
One thing is sure, pinning trust on trust chains down from Root Certificate Authorities is fundamentally incompatible with our notion of trust and an almost absurd idea to start with. Most people using a browser don't even know any person from such an organization nor would or should they have any rational reason to trust them.
As long as you're human, you don't have a substantially different notion of trust than I do. It's part of human psychology. We had to evolve it as social beings. I've seen very ad hoc CS papers on "trust", though, which IMHO were based on nothing but fantasy. Perhaps you had one of those re-definitions in mind. I tried to contribute to this pointless literature myself for a while until I realized that it's completely fictitious. All you can say from a mathematical perspective is that trust builds up very slowly based on a numerous factors and, if betrayed, goes down very fast and stays there. However, the notion doesn't have enough substance for a fruitful non-psychological modeling; there is just not enough ideal rationality behind it.
> This somehow confirms my gut feeling that digital certificates are mainly a means to enforce exclusion on behalf of the certificate authority ownership. It is a tool to prevent people from taking full ownership and control of whatever is affected by digital certificates, be it software, firmware, hardware, or as in this case SSL/TLS. That's digital tyranny in disguise.
I think the "digital tyranny" is a side effect, not the main goal. They're "mainly a means" to prevent certain kinds of MITM attacks.
Yes actually you still could've. But it would require a pass through the IETF to stabdaddize a DNS record type, and that would delay Netscape's release.
Any DNS-based solution needs something like DNSSEC to work. I believe DNSSEC didn't exist yet when HTTPS was being developed and even if it did, it wasn't anywhere near ubiquitous enough. Is it even these days?
That's kind of like saying that any CA-based solution needs something like a root program. Sure, but that would just be part of creating a DANE-like solution. Both the current CA solution and DANE or another hypothetical DNS-based solution are fundamentally similar on a technical level: hierarchical delegation of authorization backed by public key crypto. The main difference is where on the delegation chain you limit authority for further delegation and who controls the root. The DNS-based approach has the crypto system reflect real ownership while the CA-based approach has browsers makers at the top and whoever pays enough money and hasn't publicly fucked up yet at the middle with delegated authority to sign literally everything.
That's one way to put it. Another way to put it is that the CA system keeps cryptographic trust managed by organizations that can easily be destroyed if they fail, while DANE's trust is practically irrevocable.
It seems that, as soon as you transact with a sanctioned entity, you are globally in breach of the agreement and risking the revocation of all your certificates — also the ones for non-sanctioned countries.
Front matter:
- it is called a "Subscriber Agreement" and not anything that suggests that its scope is a single certificate
- it's a "contract [...] regarding Your [...] rights and duties relating to [...] Certificates" - plural
2.1 "Term":
- "[the agreement] will remain in force during the entire period during which *any* of Your Certificates are valid" - plural
3.1 "Warranties":
- "[by] requesting, accepting, or using *a* Let’s Encrypt Certificate" - plural
While it's certainly possible that ISRG has been served a subpoena because it appears the US DOJ is now a mix of hacks and incompetent buffoons, it wouldn't matter because the whole point is that they don't know anything - what you told them is literally logged publicly for everybody to see without even knowing how to spell "subpoena" let alone issue one.
Some people have this insane idea that somehow the CA has some secret which either they minted and sent to the CA, or the CA minted and gave them a copy and so the US government could get this secret with a subpoena - but the whole fucking point of a Public Key Infrastructure is that we're using Public Key Encryption, if we were OK with everybody having secrets all over the place this entire thing wouldn't be needed.
They could mint certificates, for / about any name. But, those certificates won't work in popular applications unless the certificates include proof of logging.
So to be effective this means a hypothetical bad actor (maybe the US government or anybody else) issues bogus certificates, then either logs them - making a permanent record for everybody to see, or also subverts two or more logs, so that they issue bogus proofs.
This is a very expensive one shot attack on whatever the target would be, I guess it's not stupider than "Let's bomb Iran for no good reason" but it's up there.
I don't subscribe for my personal domains, because who cares, but when I was in charge of certificates for something important I subscribed to notifications from several providers to make sure I didn't miss anything.
I would like to think at least all the high profile destinations have someone watching.
What constitutes the "vast majority" ? Periodically I check mine, and I sometimes have reason to check others, I no longer run my own log auditing (I did when I worked somewhere else because it was close to my main field of interest) but other people do.
How can you check other people's certs? How do you know whether a cert issued is authorized by them or not?
The only one who can check for maliciously published certs is the entity authorized to request them. I think most companies are happy when they manage to have valid, not expired certs and do not care too much about making sure there are not too many of them.
You are right that if the state would start issuing malicious certs en mass that would be found out quickly. But I think very targeted selected operations against entities where they know the entity is unlikely to surveil for unauthorized certs are very much possible.
I'm not arguing for going into conspiratorial thinking and claiming CAs are all compromised and issuing malicious certs all the time. But I do think that it is feasible for states to use CAs under their direct or indirect control to run targeted attacks. I think that is a plausible, serious risk that we do not care enough about and that we should do something about. There is a multitude of precedence starting from LavaBit over the wiretapping of jabber.ru^1, ANOM^2 to CryptoAG^3 that supports this conclusion.
If there's a competent admin or it's just entirely autopilot for some huge generic host you'll see a very boring pattern where there's a cert and then as it gets close to expiring a new cert is issued, e.g. 4-5 days before it expires, or on a Tuesday at about 8am, or whatever - and sure enough you'll see the same pattern in the cert presented when you access their web site.
In these cases it's really obvious if there's anything weird going on. You're correct that we can't know, as a third party why there's something weird. Maybe the server was being replaced and the new server just installed an ACME client and got itself a new cert last Tuesday even though the previous one doesn't expire for weeks. But if there was nothing we don't even need to ask anybody what's up - nothing is.
IMNSHO The statistics don't really work for targeted attacks. The odds you'll get away with it are unknowable and you only have to get unlucky once.
There are red flags you can look for, but you need to confirm with the domain owner to be sure. CAA records can tell you what CAs are supposed to issue a certificate. Many companies always use the same CA, so a change to a different one could be suspect.
For the wiretapping scenario, domain verified certificates do not protect against that scenario. If the wiretap has full control of your server's network, then it can issue a certificate of its own. No need to compromise a CA.
For any target of sufficient value that a government would do that, yes.
Of course it doesn't happen anyway, because governments don't have some kind of secret access to CAs.
> Some people have this insane idea that somehow the CA has some secret which either they minted and sent to the CA, or the CA minted and gave them a copy and so the US government could get this secret with a subpoena
LetsEncrypt certainly doesn't, but I've seen certificate storefronts that generate the key on their side and provide you the key and the certificate, so you don't have to figure out how to generate a key.
The Certificate Authorities are specifically forbidden from doing this because it's so obviously a terrible idea. Many of them also require that their resellers (obviously Let's Encrypt basically doesn't have resellers because that's stupid) also do not do this because it's a terrible idea.
But yes, you're correct that, especially when "cheap SSL" was a thing, outfits which did this really existed. In fact one of the companies which did this, and then deliberately revealed customer keys, resulting in all the affected certificates being revoked, isn't even bankrupt so apparently their customers are so stupid than they're still paying money for a service that's much worse than useless. Not an optimistic thought about humanity.
Now this is very bad, as bad as it can get. As soon as all local services will stop working in sanctioned countries, those countries' governments will force all users to either install a root certificate or lose access to all local services and websites. And then it will be possible to use that root certificate for MITM attacks. In the worst case scenario, after the majority of users will install the root certificate, state DPIs will MITM all traffic and will block all un-MITMable traffic.
Don't understand why you have been downvoted. Russian government have already attempted to push forward their root certificate for banking using Yandex browser, now this.
Is this actually new? Looks like a standard US export restriction for encryption technology to me. These sorts of restrictions have been around since the '90s.
Let's Encrypt becomes subject to US export restrictions on cryptography if they are a US company, or if they post anything to github or post anything to major app stores. Every app I have ever posted to Google Play has had to submit a form to the US government declaring what use they make of cryptography.
These restrictions have been in force since that late 1950s (with a long and complicated history with respect to computer cryptography). This particular text looks like a boilerplate restriction, that's required to comply with US EAR export requirements to me.
A certificate is not cryptography, though, it's a number. The entity requesting the certificate already has the cryptographic software installed on their servers, as do the clients trying to connect to them. There's nothing technologically special about the number, it's all in the realm of the social contract, in that it has been blessed by a chain of trust.
You can represent arbitrary data as a string of numbers, but a certificate is quite literally a number. It's a secret solution to a mathematical equation.
Organisations that are serious about promoting privacy should have been avoiding the US since the '90s and/or '50s, but the second best time to reincorporate in a safe jurisdiction is today.
Gotta love the word 'sanction'. It is it's own antonym!
"The committee sanctioned the new policy." (approved it)
"The committee sanctioned the rogue nation." (penalized it)
I mean really, if you use lets encrypt for anything that runs in a production environment, the responsible thing to do is build a fallback to switch to another provider in case LE has a bad day (or hits a brick wall and needs to say, enforce export restrictions).
Worth noting that Actalis requires you to register an account with them in order to acquire the necessary authorization token for their ACME API. This poses a privacy/anonymity issue for some users. Last I checked, Actalis' free tier didn't support SAN either.
Add.: I created an account just now to see "what's what" and also found the notice, "Activate your free 90 days certificates. At the end of the free year, the services associated with the certificates will expire." which sort of sounds like it's just a 1-year free trial.
can you please suggest any alternatives to switch to? i hardly can find any alternative which provides free service and is a non-profit org at the same time.
Before this, they were all unencrypted and you had to pay to get a cert. I guess we could go back to that - now knowing that every unencrypted connection is being MITMed (the world is so much more hostile now)...
I think the EU should do it regardless of Russia. The EU should invest in its own technology and not depend so much on an increasingly undependable ally.
> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions; (b) a prohibited or restricted party under U.S. or other applicable sanctions and export control laws and regulations;
or (c) owned or controlled by or acting on behalf of anyone described in (a) or (b). You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations
This is not an example of that. It is perfectly within US jurisdiction to prevent US companies from doing business with sanctioned countries. That is the point of a sanction, and US is in good company in choosing to use sanctions as a diplomatic tool.
It is more of an example of how the internet/software industry is too consolidated to the US, and thus other countries are too dependent on the US in those areas. If the internet infrastructure was well distributed, then people in sanction countries could simply get certificates issued by a different CA, and in some cases they can. However, this is complicated by the fact that the list of trusted CAs is dominated by US organizations (Google, Mozilla, Apple, Microsoft). If you want to reach western audience you must use certs from a CA approved by them.
Exactly. Ever since I was a kid I never understood how the US has jurisdiction way beyond their borders.
Then I graduated in International Relations and understood that the hole is much deeper than that.
Now it's pretty obvious with all the shit that trump has been doing, but back then me and much of the people I know were oblivious to what US power really means.
To be fair the US is a bit on an outlier here, as it is not afraid to come down on US companies for things subsidiaries do in other jurisdictions, on questionable grounds. So it would not be enough for Let's Encrypt to operate a European operation to sign European certificates.
Should the US wish to sanction the Hague, somewhat famous for its international court of justice, they would absolutely go after ISRG and it would not be enough for them to sever the ties of the hypothetical Let's Encrypt Europe. That would not be legal or last least highly questionable in most other democratic countries.
US law is something US citizens get to decide. If they think it's "batshit", they should vote accordingly. In this case sanctions seem a pretty good alternative to going to war.
It's clear that those who voted recently for the President are getting what they wanted. Voting made a radical difference, even if the outcome isn't one I like. Whatever "studies" you read are obvious nonsense.
Of course not! just find viable alternatives to Microsoft, Apple, Mozilla, YCombinator, Google, Intel, AMD, ...
In all seriousness, as an American I'd love to see a healthier, more well-distributed tech industry, but I don't see many companies stepping up to provide competing services. It's my understanding that china has alternatives to many of these products/services, but I really don't see how anyone in Europe could possibly use a US-free internet.
> but I don't see many companies stepping up to provide competing services
Maybe because the US dropped most of its anti trust regulations, leading to ridiculously monopolistic practices such as "acquire everything that may be threatening".
When was the last time you heard about a European cellphone manufacturer, or social media network, or web browser being acquired by an American monopoly?
I can only think of Nokia, purchased by microsoft in 2014. Those phones ran windows CE before that even, so you could hardly have avoided the american tech industry.
All I'm trying to say is, it's impossible for Europeans to both A) be on the internet and B) avoid the US tech industry.
In the EU there is the threat of jail time if a user of your service does something bad and you haven't completed the necessary bureaucracy to be immune to it. This is the opposite of the US. See for example pissmail.
that's why the world need to wake up. With the due respect of any political beliefs here, in the course of politics any country can be deemed the US enemy (or any other country's enemy as a matter of fact), so for example firing the 3/4 of the company because we have Claude and ChatGPT (US based) is a major business continuation flaw...
the wikipedia page has links to projects that removed CAcert where reasons are stated. the main one being that CAcert didn't complete a security audit or because they were not yet accepted by mozilla (because of the lack of an audit, but also because CAcert actually withdrew the request to be included). one group removed it because CAcert has a strict root redistribtion license that they can't follow.
Took me a minute to parse the headline -- Sanctioned as as in "imposed penalty" (ie "sanctions"), not as in dictionary definition #2 "official permission or approval".
Perhaps because "US territories" are a thing, perhaps because it's way more newsworthy if LE bans the US, or perhaps im just a dummie.
EU? There’s almost zero information on the company, no privacy policy? The only place I found any mention is the footer, “HID Global Corporation, part of ASSA ABLOY”. Assa Abloy seems Swedish but HID Global is a US company as far as a quick search goes. But without a proper company info page and privacy policy I wouldn’t consider it anywhere near a “good alternative” regardless.
Jumping in here since we’ve been seeing more mentions of ZeroSSL lately, likely related to the recent CA/B Forum discussions around 1‑year certificates and ACME automation.
- We’re based in Austria (ZeroSSL GmbH). The company was acquired by HID in 2024, which is part of Assa Abloy (Sweden).
- We’re not positioning ourselves as a purely EU-based CA substitute, and we generally don’t market it that way.
- For DV certs specifically, we act as a distributor. Under the hood these are Sectigo-issued certificates, similar to how other providers (for example Namecheap) operate.
Sectigo used to be Comodo's CA business. If memory serves, that business was purchased by a US PE firm and renamed "Sectigo". Sectigo Inc.'s corporate headquarters is now in Scottsdale, AZ.
There's no reason to believe they're any less subject to US jurisdiction than LetsEncrypt.
There were reason to believe they were less subject to US juridiction: their Subscriber Agreement is for "Sectigo Limited, a limited company formed
under the laws of England and Wales".
See https://www.sectigo.com/uploads/backgrounds/Certificate-Subs...
Sadly, their United Terms and Conditions in section 8.2 are even more restrictive than LE's.
They reject any entity
"located in, incorporated under the laws of, or owned (meaning 50% or greater ownership interest) or otherwise, directly or indirectly, controlled by, or acting on behalf of, a person located in, residing in, or organized under the laws of any country sanctioned under the laws of the U.S. or E.U."
See https://www.sectigo.com/uploads/backgrounds/United-Terms-and...
From a layman point of view, it could even mean that the ICC and the UN are prohibited from using Sectigo.
The Customer must have no "affiliates, officers, directors, or employees" that are on sanction lists, and the US have sanctioned some high-profile members of the UN and the ICC that spoke about the genocide in Gaza.
If so, we still need to follow guidelines from our parent Assa Abloy, a public company from Sweden, which has itself a list of restricted countries they are doing business in.
If they do business in the US they will be expected to comply with US law - this includes their stock being traded on US stock exchanges.
If they don’t have any business in the US and any financial ties to the US they won’t be subject to the sanctions. But I believe it will create issues if they want to enter the US market.
The privacy policy is under legal in the footer, exactly where I'd expect it to be honest. It also gives the company registration:
> 1.1. We, ZeroSSL GmbH, FN 443956b (the “Company“)
and below that the company address (registered in Austria).
Don't get me wrong, I agree that there is some lack of "who actually runs/controls this", especially on the about page where I expect such things to be.
At the very least it's not as transparent as I'd wish from a CA. E.g their Certificate Agreement is from Sectigo, so are they involved? No mention anywhere else from what I can see.
From their docs[0] this doesn't seem to apply if using ACME, but they don't exactly make that clear...
> By using ZeroSSL's ACME feature, you will be able to generate an unlimited amount of 90-day SSL certificates at no charge, also supporting multi-domain certificates and wildcards. Each certificate you create will be stored in your ZeroSSL account.
Yeah, they don't make it that clear, but you get basically the same functionality as with LetsEncrypt for free, including wildcard certs. You basically only need to pay for manually issued certs, or some of their other additional features.
I use them in some cases to avoid the rate limits on LetsEncrypt, and they have better support for some older platforms (like ancient Android versions), and I'm pretty happy so far. I have a paid account to support them, but it's not a requirement for ACME certs. It works without issue with Kubernetes Certbot, and seamless to switch between ZeroSSL and LetsEncrypt.
I can't comment on the EU part though - not that relevant in my case.
There was some subtle issue with ZeroSSL's implementation of ACME that I ran into with, IIRC, lego and domain certs and there was a ~5 year old lego open issue about it. That was a couple years ago, might be fixed, but my understanding at the time was that it was an issue with Zero's ACME implementation, so there may be dragons.
> Also known as a monster-in-the-middle,[1][2] machine-in-the-middle,[3] meddler-in-the-middle,[4] manipulator-in-the-middle,[5][6] person-in-the-middle[7] (PITM), or adversary-in-the-middle[8] (AITM) attack.
Fun fact: some older articles were originally written using the term man-in-the-middle, but at some point were updated... except that the diagrams still use man-in-the-middle because search-and-replace doesn't work on images.
For all the people commenting, the ITAR rules still apply for TLS, if you want to use TLS in an app for iOS/Android, one of the requirements is to get an ITAR exemption as part of the app review [1].
The US sanctions are imposed on entire nations (eg Iran), so LetsEncrypt have no option but to state in their conditions that their service is not available. They don't have a choice as a US organization operating under US law.
Whether they choose to enforce that through technical means (eg blocking IPs etc) is up to them.
Depends on whether LE is compelled to terminate service to BGP AS numbers hosted in U.S.-sanctioned countries, and whether LE continues operating out of the U.S..
It works like this. The US gov sends LE a nastygram saying they must terminate service to sanctioned entities. LE either does that or several people go to jail. The USgov doesn't care how it happens, as long as they can't find any evidence that any sanctioned entities are LE customers.
Depending on how you are supposed to read "You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations." it could mean that you are not even allowed to use LE certificate to provide services to sanctioned entities as a random non-US company/person.
I had been meaning to post somewhere that they issued a certificate to kza.org.kp a few months ago but didn't really seem worthy of its own thread.
I am no lawyer, but while there do appear to be some exemptions for communication related services, it's not clear that this qualifies as LE isn't actually providing telecommunications, just a certificate file. And it's not even an issue of the encryption itself, North Korea is under a general embargo so any exports or trade whatsoever is restricted by default.
As an aside, many of North Korea's web servers appear to be old enough to have Heartbleed based on their banner versions, but most don't actually have HTTPS in the first place.
To be put in perspective with their push for very short live certificates, like 7 days, with the argument that anyone can easily get certificate from at any time.
But in fact, little by little you have all the stacks needed to be able to isolate some entities from internet at the us request in a very short time
Why when connecting to a TLS website service that does not have a CA signed certificate, I am welcomed with "Secure connection failed, browser not trusting the ceritifate. Do you want to continue?", without showing me the actual certificate fingerprint?
On desktops browser displaying the fingerprint/hash requires clicks, on mobile is not implemented and on native apps practically not existing.
The keys should be shown, so they could be verified manually in person or via other channel. Just like the SSH do. Someone say people would just click "accept" without a thought, but the button is already here, just no information what actually is accepted.
When I read it, I interpreted it as "let's encrypt bans certificate usage in - any territories endorsed by the US". Took me reading a couple comments to understand it actually meant "territories under US sanctions".
I am not well versed in how their systemwide certificate issuance works: If they have to add this to their terms to comply with their government, could the same government use pressure to leverage let’s encrypt to do harm.
This is bullshit on par with the Chinese firewall, meant to effectively prevent the (entire!) western world from information by parties deemed persona non-grata. SSL certificates are supposed to be about security, not geopolitics.
I'm pretty sure a LE server hitting an Iranian or North Korean endpoint and validating a crypto challenge does not break any OFAC or EAR rules, and no money changes hands. And if a non-US entity wants to do it, the US would just sanction them. Microsoft and Mozilla are certainly not going to include a North Korean or Russian state CA in the root trusted certs (and if they did, the US government could just threaten them with sanctions, too).
Hard not to say "we warned you" about making self-signed certs completely unusable in favor of a very centralized approach.
It was a great hack, but it was always just that: a hack. We all always knew that the "certificate authority"-hierarchy is broken and can easily be abused by the ones in power. I appreciate everything that the let's encrypt peeps have done for the world, but the cert authority system really needs an overhaul.
Is Let's Encrypt the only provider of SSL certificates?
Genuine question! Because I assumed there were other places you could get a SSL certificate, but people in this thread seem to be implying that without Let's Encrypt, there's no way for people in those sanctioned territories to get a cert.
If it was a genuine question, the genuine answer is it's the provider that democratised streamlined ACME certificate verification and made it for free
No account, no payment, a single bash command or a certbot that runs regularly and you have your own globally recognised certificate
Historically, providers used to make the most frictions so that they could justify absolutely crazy fees for signing any certificates. It doesn't goes down well in DevOps, it doesn't work with indies who don't have 3 to 4 digits figures to blow in httpS, everyone including organisations ended up making certificates authorities of their own to sign stuff... and let's encrypt was successful at making certificates easy, free and actually secure
We all knew something like this was coming when we decided to centralise the web around Let's Encrypt.
In reality of course you can probably just ignore this as long as you request the certificate from a proxy in a nonsanctioned country and you don't stick out to the government.
Especially since sanctions are transitive. Mozilla and Google, being US companies, are actually not allowed to trust any entity whose purpose is to work around sanctions. Their members could go to jail for that.
I would imagine, as a CA that issues only DV certs, they'd disallow issuance to various ccTLDs, and perhaps stop newAccount registrations with email addresses at those ccTLDs. That's about as much as they could do - IP-blocking by region is ineffective and crude at best.
The question is, will that be enough? If OFAC can demonstrate that even with such restrictions, sanctioned entities are frequently obtaining certificates, they may be forced to require account creation or something else as a means of limiting that.
They also likely would have to implement some kind of domain name screening, just like banks have to block transfers that mention "Havana" or "Tehran".
They are currently not doing anything, even ccTLD blocks. They have issued certificates for .kp domains this month and in August of last year.
A lot of the pushback browser vendors got for locking APIs behind so-called "secure contexts" was because everyone (including them) knew this would happen. If there is a centralized system, some politician will manage to find a way to fuck with it.
Iran and other tyrannical governments can easily set up their own CAs and force their citizens to use them. Iran likely already has this infra in place. This ban does nothing but highlights LE as the liability it is. The decades-old certificate authority scheme is no longer fit for purpose and needs to go.
If you're a web developer, consider offering your site through public key-addressable networks. Reticulum and Tor are good options that work today.
the reach is by rough estimates ~2.5–6 million websites globally, 2–5 million of those in Russia and 0.3-1 million in Iran
Whatever USofA, it's not hard to have their own cosmodrome and certificates.
Tangential, in 2026 website certificates feel like nothing, disposable automation artifact, toxic max-security[1], vehicle for those who rent seek, fingerprint.
All they can do is disable support for certain ccTLDs, but other than that, it's unenforceable.
That's why many tech companies echo these laws overtly and with a lot of fanfare... They know they have no real control over who uses their services, so this is a way to signal their good faith and best effort in advance, in case they end up caught up in some foreign cyberbullshit.
He already announced sanctions against Spain. And took them back when Germany announced that sanctions against one EU country meant sanctions against them all.
The uninteresting version of this is “US entity follows US law.”
The interesting version is that Web PKI is not just cryptographic infrastructure. It is also a policy distribution system. A browser trust store, a CA, a subscriber agreement, revocation rules, export controls, and sanctions law all end up in the request path of "can this site speak HTTPS to normal users?"
That does not make Let’s Encrypt uniquely bad. Any CA has some jurisdiction, owners, contracts, root-program obligations, abuse process, and legal exposure. Moving the CA changes the governance surface; it does not remove governance.
But it does mean "just use Let’s Encrypt" is not a neutral answer when protocols, browsers, APIs, app stores, or regulators effectively require TLS. The operational dependency is not only ACME uptime and certificate issuance. It is also jurisdictional continuity.
The hard product question is what failure mode we want:
1. Web PKI: power concentrates in CAs, browsers, and root programs.
2. DANE/DNSSEC: power shifts toward DNS operators, registries, registrars, and governments.
3. Self-signed / TOFU / pinning: power shifts toward application-specific trust and worse UX.
4. Multiple CAs: better resilience, but still bounded by browser trust stores and legal chokepoints.
There is no apolitical trust system here. There are only different control planes with different failure modes.
The practical ask from Let’s Encrypt should be clarity: issuance vs renewal vs revocation, existing certs vs future certs, domain location vs subscriber location, hosting location vs user location, and how they interpret “use” of a certificate. Without that, operators are left guessing whether this is a narrow compliance clause or a broad infrastructure-risk event.
I had the parent organization of LetsEncrypt (Internet Security Research Group) in my Will, but after reading this, I will remove it immediately. US sanctions harm too many innocent people.
> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target
of comprehensive U.S. sanctions; (b) a prohibited or restricted party under U.S. or other applicable sanctions and export control laws and regulations;
or (c) owned or controlled by or acting on behalf of anyone described in (a) or (b). You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations.
It took me a minute to understand the original post because the verb sanction means both itself and basically the opposite of itself. It would be better to say "any territory that the US has levied sanctions against". I thought LetsEncrypt had banned its usage in the US! The word for words like sanction is contronym.
Europe starts to shield itself from the risk since Nicolas Guillou, the French ICC judge who issued a warrant against bibi got sanctioned (France officially protested about this case)
China is being successful at blocking US firms out of their supply chains (they already use Linux on Loongarch processors with some homemade architecture and pioneer RISC V), since a bunch of their companies also got sanctions for supplying the governement
US stands so much for freedom that it's the first country to refuse immigration to FIFA world cup teams and athletes, with Iranians not allowed to stay between games and Somali goalkeeper being turned away at the border. Germany itself didn't do for the 1936 Olympics.
So at best, they're only shooting themselves in the foot by showing any US component in a supply chain is a risk, while using US clouds were already a risk of loss of revenue from FISA requests to undercut your bid and rot your company and using US dollars for trade was already a liability
In the meantime, US companies can do anything, break any financial law and abuse every human right, they'll just sign DPAs to avoid prosecution
Your comment reads like a thought-terminating cliché. If Russia occupied your city, killed your family and friends and left you homeless, you might reconsider giving freedom to those who take it away from others. Unfortunately, sanctions are often very easy to evade.
it can't happen, they only attack civilians in countries that have weapons of mass destruction or have a evil economic system of socialized healthcare and labor market
They also don't like states that threaten business by turning workers into a commodity that you have to compensate each month ; Spain sunk the Maine ; and they had manifest destiny given from God to get rid of natives
Let's Encrypt’s mission is to create a more secure and privacy-respecting web, except for people residing in countries with the most need for a more secure and privacy-respecting web. Sure, that's great.
That said, pretty sure this is stems from the insane US legal requirement to not export SSL technology to enemy countries. I'm sure some of y'all are old enough to remember when web browsers came in "international friendly" versions that supported 40 bit encryption, or "fancy secure" versions with 128 bit encryption.
Let's Encrypt continues to be available to almost every vulnerable population in the world, including those that need it most. I say almost as I'm hesitant to speak in absolutes regarding a topic as complex as this.
Most of our sanctions-related blocks apply only to the governments of certain sanctioned countries, not their general population.
This subscriber agreement update was intended to better reflect our legal requirements. It does not reflect a major change in the service we provide. Our compliance program does evolve over time, and part of that is communicating about it better in our terms of service. It's clear from some of the comments here that we have more work to do to make that text more understandable, we'll work on that.
> That said, pretty sure this is stems from the insane US legal requirement to not export SSL technology to enemy countries. I'm sure some of y'all are old enough to remember when web browsers came in "international friendly" versions that supported 40 bit encryption, or "fancy secure" versions with 128 bit encryption.
It doesn't.
You issued a certificate for North Korea's email infrastructure as recently as six days ago:
https://crt.sh/?id=26878583197 (06/04/2026 smtp.star-co.net.kp) https://crt.sh/?id=20256841119 (08/11/2025 *.star.net.kp)
Star Joint Venture is the manager of the .kp TLD and one of DPRK's two email providers (the other is silibank.net.kp) [1], used as the official email for various government bodies ex. ipa817@star-co.net.kp (IP Office), kscost@star-co.net.kp (Sci/Tech Commission), ksf@star-co.net.kp (Ministry of Culture and Sports), mhs-ip@star-co.net.kp (Atomic Energy). It is also widely used by those universities and companies that engage with the outside world.
How did you determine that issuing a certificate to this domain or any .kp domain was compliant with the general ban on exporting goods and services to DPRK?
This is incredible. How did you find these certs?
I only noticed the star net one (not sure if it’s even in use) when writing this. I noticed the Pyongyang Zoo (which shares an IP with the Architects Society—one on 443 and one on 80 lmao) first, just from flipping through their very small IP space on Shodan.
You can see them all on crt.sh, because LE has to upload them to a CT log for browsers to trust them. (That’s how most of those subdomain finder websites work too.) The email servers seem to have gotten certs from a for profit CA back in 2015, but I’m not sure if they ever used them. Most of their webspace seems to be HTTP only. (And it’s a good thing, because some of their Apache versions are potentially old enough to have Heartbleed.)
The architects website has some pretty cool PDF magazines btw. They also have several websites for their insurance company’s (perhaps some intl org needs them to have a website for listing)—that’s a core hard currency stream for them and they previously have been accused of submitting false losses.
Thank you. Had to go looking for these magazines.
http://www.koreanarchitecture.gov.kp/index.php?kt=TWFnYXppbm...
> Most of our sanctions-related blocks apply only to the governments of certain sanctioned countries, not their general population.
The agreement very plainly says otherwise:
> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions
The general population of those countries are absolutely "persons" "located in" a "country or territory that is the target of comprehensive U.S. sanctions."
> communicating about it better in our terms of service. It's clear from some of the comments here that we have more work to do to make that text more understandable, we'll work on that.
This tries to frame it as a comprehension issue. It's not.
The wording in your agreement is actually quite clear. I think it's reckless, if not disingenuous to frame this as "we really only mean government entities".
Apropos of anything else, it's also not how US sanctions work - they are absolutely aimed at both the populace as well as the government itself.
They have "clarified" elsewhere on here that the normal citizenry get a legal exemption [waves hands mystically] somehow, and that they're only blocking people when they legally have to.
Obviously (to the rest of us) if the agreement says otherwise, then they're saying that it's LE that is forbidding the citizens of these countries, and it's not (entirely) the government's fault, which completely contradicts what they're trying to say.
We should probably be clear that this document is most likely a backside-covering exercise; it exists so that people can't sue LE for denial of service without a just cause, and so that the US can't prosecute them for intentionally shipping cryptographic services, or some such rubbish.
If you live entirely outside the US legal system, or its multifaceted tendrils, and if you don't make too much noise, you may be fine. Obviously that's a far cry from a "right to free speech" level of protection, but then LE have no obligation to provide that to people outside the US, and arguably non-rich citizens within the US lost that a long time ago.
"Somehow" is addressed in my comment: https://news.ycombinator.com/item?id=48479348
OFAC sanctions are far more nuanced than what you make them out to be. Very often "general licenses" are carved out for providing IT services or technology to individuals for personal use. The purpose of this is for censorship circumvention, which often supports American interests abroad.
This is not something that you apply for; a general license already applies to everyone. The legalese or restrictions companies use exist because they cannot (or will not) validate everyone is who they say they are. This obviously doesn't apply to companies who deal with controlled exports, where they are responsible for whoever ultimately receives the controlled export.
I am not a lawyer and this is not legal advice.
https://ofac.treasury.gov/selected-general-licenses-issued-o...
I get this, but you say "very often", but it's not, and generally, looking at OFAC lists, there's only a few countries with personal carveouts (less than 5 of the countries on the list), usually for remittances, and in a few of those countries only to US persons residing there.
Generally the software carveouts are very limited - it's not just "providing IT services or technology to individuals for personal use", i.e. Sudan:
> software updates for medical devices to Sudan
Indeed, of the software carveouts listed on that page, only two are not related to the operation or update of medical devices:
- provision of Internet services to the people of the Ukraine (read: "Starlink")
- provision of messaging services to members of the Government of Venezuela.
Sounds like "comprehensive" does the heavy-lifting here (in "country or territory that is the target of comprehensive U.S. sanctions"): what countries are under comprehensive sanctions, and which are under non-comprehensive sanctions?
It may be the case that "most of" their sanctions-related blocks apply only to governments (let's say there are 100 such blocks), while they still disallow usage by persons located in a country or territory that is the target of comprehensive US sanctions (let's say there are 50).
I assumed that they meant that they will not enforce it via technical means.
Came here to quote exactly that paragraph.
Thanks for responding, and to clarify, I am confident that Let's Encrypt is shared as widely as they are able. Could you explain what that requirement does stem from?
> Let's Encrypt continues to be available to almost every vulnerable population in the world, including those that need it most. I say almost as I'm hesitant to speak in absolutes regarding a topic as complex as this.
> Most of our sanctions-related blocks apply only to the governments of certain sanctioned countries, not their general population.
It doesn't work that way.
Blocking governments from getting certs doesn't hurt them in the slightest. The government can just create their own pki.
But it hurts the general population instead. People do not live in vacuum, they still need to access government sites. And thus people are forced to install root certificates of questionable trust.
When Let's Encrypt blocks government entities, it instead puts respective vulnerable population in even less secure environment.
Although, given the current events, I am not sure Let's Encrypt continues to deserve the trust it had.
When you say “our legal requirements” do you mean requirements LE imposes in its agreements or requires imposed on LE by governments?
I was referring to the requirements imposed on us. When it comes to sanctions, we do not block anything more than what is required by law.
The current US government sanctions political enemies [0].
Wouldn't the more rational response to this legal situation be to leave the USA and move somewhere more willing to respect international law?
[0] https://www.whitehouse.gov/presidential-actions/2025/02/impo...
According to the current administration, almost half of the US is considered a political enemy of the current administration.
Soon they might be pushing for Operating Systems to gather political party preference information, so they can know who should be restricted from the use of strong encryption. The options being:
1. I love america
2. Radical left looney
3. Neither male nor female.
4. Those that tremble as if they were mad[0]
[0]: https://thewhippet.org/the-whippet-134-those-that-tremble/#c...
It'll be interesting when/if they sanction Antifa. Since it doesn't exist, you can't prove that you're not a member of it. So they get to sanction anyone.
Proof has no relevance if you are prevented from accessing the legal system (e.g. thrown into a concentration camp for immigrants)
> move somewhere more willing to respect international law?
Some of these sanctions are required by international law (i.e. sanctions imposed by UNSC). For the other ones, international law generally lets countries have whatever trade policy they see fit including sanctions, unless they violate some other rule of international law or treaty obligation.
Sanctioning the ICC obviously has nothing to do with trade policy.
The USA signed the Rome Statute but never ratified it, and then withdrew its signatory status. There's an argument to be made that there was a treaty obligation there, but it's pretty weak.
I personally think sanctioning the ICC judges is a disgusting act. However ultimately all sanctions are decisions to refrain from trading with someone, so it is in a sense a trade policy. I think what you're getting at is that usa is implementing that policy to obtain a political/diplomatic goal, which is true, but you could say the same about most trade policies.
I think article 18(a) of the vienna convention of the law of treaties means that once you withdraw your signature, you no longer have any obligations in regards to the treaty.
Maybe you could make some sort of argument that the sanctions violate the purpose of the geneva convention as they are designed to prevent bringing to justice people accused of grave breaches of the geneva convention. Like its an attempt to frustrate the application of article 49 of the first geneva convention [Ianal]
Why would other countries be less likely to impose sanctions on their political enemies?
I can't answer why or why not but just in terms of track record the US is fairly egregious. The executive attempts to coerce individual UN officials via sanctions. While it may not be strictly illegal it is clearly flagrantly unethical.
By whose law? Thailand? China? Germany? Afghanistan?
I’m actually old enough to remember how PGP code was exported as a book printout because exporting computer code for cryptography with strong keys in digital form was disallowed but a book was fine (protected by first amendment rights). The printout was scanned abroad to reconstitute the source and build pgp legally.
> pretty sure this is stems from the insane US legal requirement to not export SSL technology to enemy countries
This is most likely OFAC. Lets Encrypt could apply for a license to do business with sanctioned entities, and given their use case it would most likely be approved.
https://ofac.treasury.gov/ofac-license-application-page
OFAC regulates commerce, not speech. Let's Encrypt is not doing "business", they're operating a free informational service. Lots of organizations interpret any information exchange as subject to OFAC regulation, and you and Let's Encrypt have good company in this interpretation, but I think it's unnecessarily ceding ground.
The government may use as wide of an interpretation of commerce as they can get away with. We've seen this happen before [0]. Sure, Let's Encrypt isn't taking money from the entities they offer certificates to. But the OFAC desk jockey assigned to that case only has to concoct some sufficiently plausible-sounding trail of money connecting the backing 501(c)3 and a sanctioned entity in order to levy penalties, and the legal team will not like that risk, even if it's unlikely for OFAC to win on appeal in a court.
[0]: https://en.wikipedia.org/wiki/Wickard_v._Filburn
This is true, of course, and I understand why some companies don't want to take the risk. But I would hope that Let's Encrypt would take the opposite stance. They were born out of the EFF and have EFF & ACLU board members! These orgs live for this type of legal fight.
IANAL, but it seems like the argument from Wickard v Filburn would apply to LE. They may not be taking money but they do impact the commerce of the market for certificates.
I disagree with that ruling, and I have some serious problems with sanctions against entire countries/regions, but it definitely makes sense that LE would interpret it as being impacted by OFAC.
Providing information (website, CT log, CRL) is fine, but creating a certificate on request is clearly a service. How is that different than providing a computation or LLM output in response to a prompt? Moreover, it is clearly not just the physical act of signing a CSR, but the verification of ownership that comes with it. That's just as much as service fully automated as if a human were doing it.
Now, does this serve a policy purpose? Perhaps not--US computers trust plenty of non-US CAs that could continue to serve these customers. But that's not how comprehensive sanctions are set up, they are effectively a complete embargo.
A better question is whether telecom carveouts (general licenses) in the sanctions may allow this. That is a country by country question as each one is worded differently.
OFAC has authority to regulate commercial services under the Commerce Clause. Not all services are commercial in nature. There is no economic exchange inherent in running a certificate authority. If LE charged money for certificates, that would be a different matter. LE's differentiating factor from the previous era of CAs is that they are non-commercial.
GitHub was recently granted a license from OFAC to allow there services to be used from Iran. You can read about it here: https://github.com/github/site-policy/blob/main/Policies/oth...
And here: https://github.blog/news-insights/policy-news-and-insights/a...
IANAL, but this seems wrong.
In an alternate universe, Let’s Encrypt has a chat with someone and then states, publicly, like a speech, that they think that person owns a domain.
In our universe, Let’s Encrypt lets a client open an “account”, enters into a contract with the client (the contract is the topic of this entire post), and gives the client an API by which the client requests a certificate. Then Let’s Encrypt grants the certificate. Maybe the certificate is somehow speech. The rest sure doesn’t sound like speech to me.
Wasn't there news a bit ago about some people being suddenly excluded from Linux kernel development for presumably similar reasons?
Seems in all thing tech at the moment the US legal system is accelearting a great split and erectinga digital iron curtain, from AI models to the more mundane like TLS certs. Its been standard for a while for many Linux distros based in the US to toe the party line - like RedHat having notices pretty similar to this one by LE. Seems any meaningful Open Projects will have to choose what path they want to take, be like RISC-V and relocate or LE and others and enforce the divide.
It isn't just the US. China, Russia, the EU, and Australia and probably others are all increasingly trying to create virtual walls of various forms in the internet.
It is in the nature of nation states to assert control over national borders. That the Internet and the globalised flow of information it enables circumvents this is a historical anomaly.
The RISC-V move was laughable. It’s still US tech, developed largely with DARPA funds.
Woah, I had no idea about DARPA and RISC-V. I wonder why they care about RISC-V so much? This is the best explanation that I can find:
You can read more about it here: https://riscv.org/about/ -> See section "DARPA Influence"About their move to Switzerland, they say:
So what? If I disagree with the direction any FOSS project (or its maintainers) is taking... I can just fork it. People have done that countless times in the history of FOSS, most notably in the xOffice schism.
No remotely western company will risk US sanctions violations or whatever other regulatory burden by using US technology where it can't be used. Even Chinese companies depending on how state backed they are might not be willing to risk it.
This is the big irony of the current situation: while the US is dependent on China for manufactured goods, China is dependent on the US for external demand for its manufactured goods.
One is the mirror image of the other and neither economy can exist in its current state in isolation.
So China has the US over a barrel when it comes to actually building stuff, rare earths and all of that, but equally US sanctions still have real bite (a lot more than China would like) because China does have to do a huge amount of international trade to export and externalise its surpluses.
They're stuck in this unhappy marriage
> They're stuck in this unhappy marriage
Who says they’re stuck or unhappy?
This is politics. We’re all just bait. In reality they’re friends.
US and China have made more gains by pretending to be enemies than friends and they likely plotted it all together.
It doesn't matter what technology is used, sanctions are imposed when USA doesn't like something.
Some (well, at least one) of us are old enough to have owned one of these:
http://www.cypherspace.org/adam/uk-shirt.html
A t-shirt with a Perl script that implemented RSA encryption strong enough to be technically illegal to export from the US.
(I must sadly admit to being too cowardly/sensible to have taken that shirt to the US in the late 90s...)
I wore the rsa-dolphin t-shirt all over the place and nobody batted an eye back then, but a dolphin made up of ASCII characters is quite a bit less obvious than the one you linked.
OpenBSD being based in Canada ships strong crypto, but has had a sometimes troubled relationship with certain regimes.
https://www.openbsd.org/lyrics.html#34
DeCSS printed on stuff was a thing for a while, too.
And if you missed the original run, you can buy a reprint from Adam's current company: https://store.blockstream.com/products/rsa-t-shirt
> Let's Encrypt’s mission is to create a more secure and privacy-respecting web, except for people residing in countries with the most need for a more secure and privacy-respecting web. Sure, that's great.
If complying with the law gets in the way of the mission I’m not sure that counts as a change to the mission.
> If complying with a law gets in the way of the mission I’m not sure that counts as a change to the mission.
It's already illegal to use in NK, but if it's the US, well it's time to steer the mission around it? Gross.
For an American enterprise? Yes, obviously.
Should NRA hand out guns to everyone who can’t get a permit where permits are required? Of course not. If they are against gun permits they have to fight the law, not break it.
The National Rifle Association (NRA) describes itself as America’s longest-standing civil rights organization.
That is a specific US-internal stance.
There's a list of organizations that started in the US, ultimately having had to work around the US legal system, in pursuit of their missions:
re Planned Parenthood Global, WikiLeaks, International Campaign to Ban Landmines, Center for Reproductive Rights, selected programs of the Human Rights Campaign Foundation, et al
This is why, as someone who works in security and encryption and has implemented web server TLS stacks and such, I still oppose the "always-https" idea.
TLS is awesome, one of the most valuable developments in Internet history. But, it is important to undewrstand that it is a double edged sword. Requiring a CA, which in practical terms means requiring a publicly known CA, is a choke point of freedom.
http://www.geekytattoos.com/illegal-tattoos-rsa-tattoos
tattoo yourself with crypto code to become munitions
It could also be an easy way to not have to implement backdoors for the government/military.
What "backdoor" would Let's Encrypt even implement? That's not how a CA works.
They might be compelled to issue a certificate to an unauthorized (by browser PKI policies, not local law) entity, but that would be very conspicuous due to Certificate Transparency.
I suspect any "backdoor" would be inserted at the protocol level. See https://web.archive.org/web/20130918135152/http://www.thegua...
How would they do that? The ACME protocol is "take the basic artifacts you use for certificate signing, wrap them in JSON (cryptographically, using standard JWS), then send them over using HTTP + TLS." Every part of that is something for which there exists a buttload of implementations in whatever language you care to use.
> How would they do that?
Let me introduce you to the phrase "I don't see a mechanism."
>Let me introduce you to the phrase "I don't see a mechanism."
I'm not familiar with this phrase, but I think I did a good job citing a comparable example in my original post.
> Those methods include covert measures to ensure NSA control over setting of international encryption standards, the use of supercomputers to break encryption with "brute force",
Things that definitely don't happen. Those same encryption standards are used by the US military, and the international cryptography community can pretty readily rule out keyed backdoors.
The thought that supercomputers could break Internet encryption by brute force is laughable. One would have to be innumerate to think such a thing.
If you truly need a secure and private web you should be using tor.
Say what, now?
Anonymity and encrypted communication are two very, very different things. Have one but not the other and you're essentially handing off your private data incl. passwords to whoever that has a tap on the communication between you and the server can fetch them, too. Have the other but not the one and everyone will know who you are, but they can't eavesdrop.
I've had people straight up serve me malware when you attempt to OSINT them with Tor. Sometimes you need different kinds of anonymity, and I see a lot of one sized fits all proclamations on HN.
I've found lots on Iranians on tor.
I mean, noone is stopping someone to clone letsencrypt - it shouldn't be very hard.
Google had a similar dilemma - do they want to offer a (censored) service in China, and have a hope of keeping some marketshare, or not (and be kicked out immediately).
In this case though, it seems to be an unforced move by letsencrypt ? Or was it compelled by LEAs?
Couldn't LE have a branch in Europe or anywhere outside the USA and its minions?
Because they're betraying their own goals, as stated in their About page: “It is a service run for the public’s benefit. [...] Anyone who owns a domain name can use Let’s Encrypt to obtain a trusted certificate at zero cost. [...] Let’s Encrypt is a joint effort to benefit the community, beyond the control of any one organization.” Now they own they are under the control of a political organization.
Here is the paragraph Let's Encrypt added to their Subscription Agreement on 2026-06-04:
> You are not a person or entity that is:
> (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions;
> (b) a prohibited or restricted party under U.S. or other applicable sanctions and export control laws and regulations;
> or (c) owned or controlled by or acting on behalf of anyone described in (a) or (b).
> You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations.
They could, but if the branch didn’t follow these laws, the main US branch would still be liable.
It's about time SOME entities start moving from US entirely.
RISC-V Foundation did.. though they go out of their way to talk about it in terms that try not to piss anyone off..
> "Across 2018-2019, the RISC-V community has reflected on the geo-political landscape and we have heard concerns from around the world that investment in RISC-V must come with IP access continuity to ensure a long-term strategic investment. We first mentioned our intentions to move at the December 2018 summit. Incorporation in Switzerland has the effect of calming concerns of political disruption to the open collaboration model. RISC-V International does not maintain any commercial interest in products or services as a non-profit, membership organization. There have not been any export restrictions on RISC-V in the US and we have complied with all US laws. The move does not circumvent any existing restrictions, but rather alleviates uncertainty going forward.
> In March 2020, the RISC-V International Association was incorporated in Switzerland. Along with this, we shifted to a new, more inclusive membership structure. Members of RISC-V International have access to and participate in the development of the RISC-V ISA specification and extensions as well as related hardware and software. RISC-V has a Board of Directors composed of member representatives as well as a Technical Committee of work group leaders."
> RISC-V International has not incorporated in Switzerland based on any one country, company, government, or event. This move is reflective of community concern and managing strategic risk for our community investing in RISC-V for the next 50+ years.
> The IP contributed and produced by RISC-V International is held under industry and global standard licenses that are already open to leverage by any company regardless of jurisdiction. This licensing is a common open source approach to foster collaboration that is not tied to any geographic regulation. IP in the public domain has not been subject to export control.
https://riscv.org/about/
The RISC-V foundation and related companies also got a bunch of money from Europe. I am not so sure this was about leaving a repressive regime as much as chasing the European "homegrown computing" money.
This is part of why the EU is looking to move away from US-based infrastructure. The CLOUD Act basically lets Washington have an off-switch on your computing infrastructure as well as giving Washington unlimited access to any data on your computers (or that passes through them).
[flagged]
Other countries sanction each other too.
They mostly don't.
Or rather, when other countries say "sanctions", they are almost always talking about something completely different than the United States.
This is not about countries sanctioning each other. This is the US sanctioning a local company because a foreign company doesn’t follow certain US laws in foreign soil, where such laws don’t apply.
It’s a bit like the US arresting your mom at home in Texas because you ate a baggie of magic truffles in Amsterdam.
You're being very vague. Please explain what you mean? I don't see anything here about the US "sanctioning a local company," and I'm not aware of that being possible under US law.
Please see my answer to the sibling comment.
"Clarifying Lawful Overseas Use of Data (CLOUD) Act."
The way you are using these words seems to indicate you might be confused about how this works.
The US has not "sanctioned" LetsEncrypt or ISRG. The US sanctions foreign entities as punishment for various reasons precisely because they are not subject to US law. That's the entire point of leveraging a sanction -- to pressure those outside of your legal jurisdiction. If they were in your jurisdiction, you'd simply arrest them.
People and organizations basically anywhere not permitted to do business with anyone your country has sanctioned. Anyone who does business internationally should be aware of their country's sanctioned list. That applies no matter where you live on the planet.
This is not that though.
This is literally about a company that has a branch in the USA and another branch in another country, where it's bound by that country's laws. If the foreign entity which just so happens to be commercially linked to the one in the USA has any dealings with countries sanctioned by the US, the US branch is punished.
There was a case a few years ago where a public University in Brazil bought lab computers from Dell Brasil. Dell Brasil is a subsidiary of Dell, but it's 100% incorporated in Brazil, the computers were manufactured in Brazil, everything following Brazilian law. The computers were delivered with terms of service that prohibited them from being used for any dealings with US-sanctioned countries such as Iran and Cuba. The University was caught by surprise and questioned it, since they had many academic links with Cuban Universities, and Dell Brasil explained that.
I don't know how the whole ordeal ended. The Brazilian Federal Government got involved, I believe the Ministry of Exterior and the Ministry of Commerce and Industry both got involved and were at one point going to sue Dell Brasil. I suspect it ended with the University returning the computers and purchasing from another supplier.
The suggestion that Let's Encrypt could work around US sanctions by opening a branch in the EU falls under similar conditions, and the US branch would be liable if the EU subsidiary had dealings with US-sanctioned countries.
Incorporating a subsidiary in a foreign country doesn't make the parent company immune to the legal obligations it has in it's home country. It would be absurd if that were the case. Sometimes people try setting up subsidiaries overseas to hide their evasion of the law, but it is illegal to do so.
> Incorporating a subsidiary in a foreign country doesn't make the parent company immune to the legal obligations it has in it's home country.
We're not talking about legal obligations in its home country though. I can buy Jack Daniels at age 19 in my country from their local subsidiary, and no-one thinks that this should be a crime for their US parent company because the US drinking age is higher. (Of course it would be a crime for either the parent or the subsidiary to sell to 19 year olds in the US)
(No-one is blaming Dell or Let's Encrypt here, to be clear, it's the US' excessive extraterritorial laws that are the problem)
If you are in the US you must ensure that your local company, and any sub-entity you control abroad complies with sanctions law. That is US law, and the US can apply that law to Dell the parent company, because it is in the US and controls the subsidary.
> I can buy Jack Daniels at age 19 in my country from their local subsidiary, and no-one thinks that this should be a crime for their US parent company because the US drinking age is higher.
Because there is no US law that says you cannot sell alcohol to people abroad under 19. Heck, there's no US federal law that says Jack Daniels can't sell to people in the US under 19, either. And in fact, there are some places in the US where you can legally drink at 18, e.g. Puerto Rico. But if the US congress wanted to pass one of these laws and enforce it, it could.
US sanctions law saying that you must not transfer X from the US to Iran, directly or indirectly, is reasonable. US sanctions law saying that you must not transfer X from Brazil to Iran is gross overreach. Yes, of course the US can apply its absurdly extraterritorial laws to any parent company in the US, just as Iran could penalise any Iranian company whose US subsidiary distributed a depiction of the prophet or whatever, but that doesn't make it good law or good practice.
That's a fair opinion to have.
But the US isn't really unique in applying their laws extraterritorially. See GDPR, Universal jurisdiction laws, China's National Security Law, etc... Every jurisdiction with sizable power does it. Some of these are even more extraterritorial in scope than US sanctions are.
> GDPR
Only applies to EU citizens' personal data, so while technically extraterritorial it doesn't feel like overreach in the same way.
> Universal jurisdiction laws
Rightly controversial when applied beyond things that are internationally agreed to be crimes against humanity, like torture or genocide.
> China's National Security Law
A perfect example of the kind of thing that the US used to define itself in opposition to.
Nations are sovereign and those with the might to push their requirements on others can do so. But I liked it better when we had a sense of the value of an open international order, where things like internet protocols were shared standards that everyone would collaborate on other than a handful of pariah states.
The difference between any of these is just a matter of opinion on what sovereignty means, what or who or where it applies to, what is a “human rights violation”, and who has the bigger britches to back it up. /shrug
Meh. You can fall back on might makes right and a Hobbesian war of all against all, or you can recognise that the Westphalian system has brought immense value to humanity and is worth trying to preserve and build on. There will always be disputes about how to extend our principles into new domains, but that doesn't mean those disputes are insoluble or that a few disagreements mean we should tear down the whole project.
>Only applies to EU citizens' personal data
That's not true.
The GDPR applies to the personal data of anyone physically in the EU, to the extent that the data are processed[0] while they are in the EU.
It also applies to the personal data of anybody anywhere in the world if the data controllers are based in the EU.
The reason why it's different to US sanctions/export controls is that the GDPR doesn't say you can't work with certain people in certain circumstances because of who they are in order to punish those people for whatever reason. It's fundamentally to protect the data subjects.
[0] which includes collection of said data
You may call it a subsidiary all you want, but it's still a company that's wholly incorporated in foreign soil, doing business in foreign soil.
At least in Brazil, companies that operate there must obey local laws. What happens when those laws are in contradiction with US laws, like in the example I cited? Is Brazil supposed to cave? Is Brazil supposed to keep fining Dell Brasil until it folds? Maybe prosecute Dell Brasil's directors for actively and repeatedly disregarding the law and fines?
How does that work on a global scale?
I'll say again, this is not about a US company opening a foreign subsidiary to do things in the US that are forbidden in the US. This is about a company incorporated abroad having to follow US laws while operating wholly abroad. This is a breach of sovereignty however you look at it.
It is plainly routine for a company to have to deal with multiple legal jurisdictions at a time.
Yes, sometimes this causes compliance complication. This isn't unusual, it happens frequently.
Ultimately, every government exercises the laws of their country as they see fit, using the enforcement tools they have available to them. These rules often extend outside of their borders and apply to foreign or partially-foreign entities depending on the situation. The only limits on this are the practical means of enforcing it.
Dell Brazil would have been subject to Cuba sanctions because it was controlled by the US parent company. The US has obvious jurisdiction over Dell Technologies the parent company, and the nexus to enforce it.
Nothing you are are describing is even remotely unique to the US. No country is going to let you set up a foreign subsidiary to launder goods around sanctions law. If they did, everyone would do that and nobody would ever follow sanctions.
Why didn't the university just ignore the terms of service?
I don't know, and to be fair they might have done just that - and it wouldn't surprise me if that happened with the blessings of the Federal Government.
As I mentioned, I didn't follow up on the story and in fact when I searched for it a few years ago, I couldn't even find the original articles any more.
Ah, so it would be like the EU fining a US based company for not following certain GDPR laws even if they don't have a presence in the EU? Definitely would never happen!
It depends on the legal structure.
If they set up a subsidiary in Europe, they could be held liable for actions of European subsidiary.
If an independent org is stood up in Europe, with European directors, staff and funding, legally independent of US org, and the US org just provides advice/assistance to Europe org without ability to control it-legal liability for US org for Europe org’s decisions is less likely. Of course, ask a lawyer-but if you openly say “we are doing this to work around US sanctions” you could still be liable; if you say “this has nothing to do with sanctions this is about resilience of global digital infrastructure and European digital sovereignty” then under what legal theory is the US org liable?
What if the branch in Iran was the main branch?
Just close down completely in the US and move to the EU
And then what? Be subject to similar sanctions from a different governing body?
e.g. https://www.consilium.europa.eu/en/policies/sanctions-agains...
So simple, just uproot your lives and move to a different continent 4heads!
Why, so they can be forced to enforce content restrictions on any provider that wants an SSL restriction?
It shouldn't be located in Europe (because, as you said, US minions are no better than the US itself). Instead it should move to a neutral country, somewhere like Singapore or Uruguay.
Suddenly the idea of having a CA hosted in space on a satellite issuing certs seems like a good idea.
You're assuming that satellites are exterritorial. They aren't, they're ab initio the launching state's property and responsibility, barring other agreements to transfer them - and getting one out into a "legal void" isn't going to be trivial.
Over the centuries I am sure there will be random satellites that are defunct that will be hacked or otherwise "taken over" by someone with the right skills. These things are tiny compared to the distances involved and in the future you might end up using them as data reservoirs since in many cases it will be cost prohibitive for any authority to go collect or otherwise stake authority over an old piece of hardware considered junked.
In a hundred years, sure. Current satellites have neither storage nor compute capabilities of note.
That said, they don't have to grab the satellite. They have to grab you. Computer vandalism/sabotage/... laws in a lot of legal systems already apply to the controlling people in their home location regardless of the physical location/origin of the computer activity. Your controlling the computer/satellite/botnet/... is the illegal act, not the network packets leaving those systems.
They'll have to identify you first though, which might give some legal shielding.
A ship in international waters with satellite internet connection would be much cheaper, except it runs into the same problems as described by the sibling comment: https://news.ycombinator.com/item?id=48469397
You don't get 1,361 W/m² of continuous free energy when you're Earth bound and all those pesky water molecules.
> free energy
It is free only if you ignore the cost of getting the thing into the orbit in the first place.
Edit: also, AFAIK, normal microchips (without special radiation hardening) don't last that long in space
Also, pirates
New startup idea: Starlink for TLS.
completely independent entity would be far better option. Protocol is open after all, just need pointing to different vendor
Let's encrypt is not some code or even a company that you can split into different branches. Their existence is one based on trust relations that let's encrypt has with browsers and operative systems. It is in one part similar to both domain names and IP address space, in that the technical aspects of creating alternative roots is almost trivial in comparison to getting the trust that is required for an alternative root to be accepted by the rest of the world.
Let say someone created an Russian Let's Encrypt. It has all the technical aspects as regular LE in that you can request a certificate and get one through an acme challenge. That is all great and all, but no browser will recognize it as valid. No operative system will recognize it as valid. The Russian state might add the new LE as valid for government computers, but the real work would be to get any other participants in the world to do the same. The issue is not a technical one but rather a social one that is built on trust.
When Russia invaded Ukraine there was a major discussion if IANA/ICANN should have disconnected Russia from domain names and IP addresses. That discussion ended on a decision to not do that because the symbolic benefit was deemed minor compared to the harm to the system in large, especially once the war end. If you got two roots, then a domain name or IP address can now suddenly have two locations, and it would be a massive pain to try fix it even if people wanted to fix it. Certificate Authorities do not share this trait since there can be an almost unlimited number of roots and none of them can conflict with each other (assuming no hash collision). If Russia spins up a new CA then people can use that one today if they want to, and they can continue to do so after the war has ended.
Russia already has its own root CA, the issue is that state-owned root CAs are by definition not safe from MITM attacks by the same government.
It is a lunacy, complete delusion to think that privately owned (by oligarchy) root CA that trusted by every web browser and OS on the planet is somehow superiorly safer from the point of state actor attack than those explicitly state owned root CA. You must be livin in fairyland.
There are other non-US equivalents to Lets Encrypt.
Iran is blocking internet for months, US ...bans creation of secure connections - that'll show 'em!
Russian quasi-government structures are spending quadrillion of rubles on a TSPU (censorship system) to spy on Russian residents, US ...helps them by making snooping on what is currently encrypted traffic possible by banning accessible encryption!
Let's Encrypt certificates continue to be available in both Iran and Russia, just not for the Iranian and Russian governments.
The terms of service update to clarify what we have always done, comply with relevant law, has not changed the situation for either country.
> Let's Encrypt certificates continue to be available in both Iran and Russia, just not for the Iranian and Russian governments.
According to https://news.ycombinator.com/item?id=48457280 it affects all people ordinarily resident in those territories, not just their governments:
> You are not a person or entity that is:
> (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions;
> [other 'or' conditions]
Sanctions compliance is unfortunately fairly complex.
Let's Encrypt can issue certificates for non-government entities in Iran and Russia due to statutory exemptions protecting personal communications, alongside specific Office of Foreign Assets Control (OFAC) authorizations designed to promote Internet freedom and human rights.
We will look into whether we can make things more easily understandable in the subscriber agreement.
> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions
Seems to be pretty clear that it would include non-government entities in sanctioned countries.
I wonder what "ordinarily resident" means legally. Like has a permanent address there, even if they don't live there physically..?
Yes. If you are, for example, even a US citizen, permanently living in Crimea, you are still subject to limitations, imposed by sanctions.
I'm not sure if you're talking generally about sanctions or specifically about Let's Encrypt, but to avoid any doubt: citizens of Crimea are free to use Let's Encrypt. We do not, however, serve government entities in occupied Crimea.
you should update the documents to reflect this stance.
"You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions; "
this says nothing (edit: specific) about government (edit: only), and is applicable to normal people in those areas.
A government falls under "entity". So it's about normal people AND governments (and other entities).
Still needs updating if it's supposed to only apply to governments, though.
[Iranian here] Completely agreed. Reminds me of how US banned citizens and businesses in Iran from using cloud infrastructure like AWS or digital ocean, leading to people and businesses moving to the government-sponsored local cloud services, and that made it super easy for the government to block internet access whenever they want without essential services like banking, ecommerce, online taxi booking, food delivery etc being disrupted.
TSPU isn't for spying, it's for censorship enforcement and everything else that makes the experience of using the internet here miserable without a VPN. It's SORM that's for spying. And Roskomnadzor is very much part of the government.
You could look at it equally as the USA saving those citizens because if the authoritarian discover they are using LE they could suffer imprisonment
wait until you find out about Facebook!
This somehow confirms my gut feeling that digital certificates are mainly a means to enforce exclusion on behalf of the certificate authority ownership. It is a tool to prevent people from taking full ownership and control of whatever is affected by digital certificates, be it software, firmware, hardware, or as in this case SSL/TLS. That's digital tyranny in disguise.
While it seems like certificate authority has the primary control here, the real control lies in browsers and operative systems in which certificate authorities are trusted. Users also have, at least for the moment, control to add or remove certificate authorities, even if that control is slightly less clear for devices like smart phones.
Digital certificates that signs software packages are used to enforce exclusion by some manufacturers. Let's encrypt is not in that space to my knowledge, but it is a place where you the owner do not have the right to determine which certificate authority should be trusted, and generally the only one that is trusted is the manufacturer. Its arguable if we even should be calling such entities a certificate authority, even if they technically are the owner of the root certificate that signs the package.
> the real control lies in browsers and operative systems in which certificate authorities are trusted
Wasn't Let's encrypt a Mozilla child ?
The real control lies at who defines what is trusted.
Local control, maybe. But not the power.
I always saw it as a trust-chain and think that anyone is welcomed to create a root certificate and distribute it to whomever trusts them. Most simple services may not need TLS, but with the ISPs eavesdropping on our communication, a form of secure communication is required and the currently best solution we have requires a trust-chain to be built.
It is such a great improvement that ISPs cannot eavesdrop us anymore... only for everyone to terminate TLS at cloudflare so they (and thus US government) can now eavesdrop everyone.
Ultimately, I find it likely that TLS will become a tool to prevent users from accessing foreign content (browsers stubbornly refusing to show untrusted sites in the name of security, slowly getting there), more than a tool to prevent eavesdropping on users secrets.
If you have a service that shares information between people all over the world, a few big companies and one government is for most cases an improvement over all the involved ISPs and all of their respective governments.
That's not the trade-off you make though.
The involved ISP and respective governments do still see everything, but also cloudflare and the US ISPs they use see it in the clear.
Also the US has a history of abusing its position here, even with less honeypot like companies.
The problem is that finding a root source of trust aren't easy this days. LE was neutral, now nobody is.
Russian government issued their new root certificate years ago.
Nobody trusted it enough to request a certificate from them or install it on their computers. Including almost all of the russian residents.
If Let's Encrypt enforces the rules, as written in pdf, a lot of people would lose a choice.
Frankly, even publishing a statement like that would make the scales of trust tip for some.
> Nobody trusted it
Let's be real here… 99.99999999999999% of internet users have no idea what root CAs even are. It's the browser vendor mafia that makes the decision.
Force the people and then give them simple instructions to install certificate. And it's done.
Forcing is as easy, as blocking access to important services behind the certificate wall.
>> 99.99999999999999% of internet users have no idea what root CAs even are
that would be like *checks math* less than a human aware of root CA? Can't be right.
anyway, people living in russia are statistically more aware. There was a campaign after new root CA was issued. It was on a news, on the official channels, in the mail and on the posters. A lot of government sites begged to install them whenever you visited.
It's not like they released it silently.
> I always saw it as a trust-chain and think that anyone is welcomed to create a root certificate and distribute it to whomever trusts them.
Note that phones already try to prevent you from using a certificate that you provide yourself.
"Try to prevent"? What does that mean?
It means they prevent, unless you perform several undocumented arcane rituals.
In this case, you have to compile the OS yourself and patch the trusted certificate store.
We could, and should, switch to DANE. Or else, switch to how X.509 was supposed to be used, with each country running a CA for their nationals.
I trust governments much less that a conglomerate of competing corporations.
With all the problems with Web PKI, at least the bad actors are getting distrusted, and this provides a very strong enforcement on the rest. And Certificate Transparency makes sure the mis-issuance would be caught. It is not perfect by any means, but things are getting better.
With DANE (or other country-issued certificates), every government will absolutely double-issue certificates to police, secret service and friends of goverment, and no one will have any recourse. (In the past I'd say that only countries like Russia would do it.. but with today's climate, I am sure both US and many European countries will do that too)
Companies have run some absolutely outstanding PR then.
I have never worked in any company where I explicitly trust the CEO to always do the right thing in every situation.
There is usually no governance board, or review system to inquire about public harm: those things are usually external and fought against as they are regulatory burden.
So, in practice what tends to happen is that someone in the company just does stuff. Since humans aren't perfect this "doing stuff" is not always super enjoyable. If it's the CEO who "does stuff" then you're cooked because nobody except the board of directors can say anything meaningful: you gotta hope that the media wants to put pressure on.
Our elected officials on the other hand, are supposed to represent us, and thus media pressure is a lot stronger; issues that affect many people are meant to be properly reflected, and their decisions are open by default.
They key is multiple, competing companies. As long as they don't collude, if one company misbehaves, others will catch it.
Hows that going for…
… browsers
… phones
… operating systems
… network appliances
… payment transaction systems
I feel like if it fails so often then it can’t be relied on.
I'm not really in favor of DANE, because DNSSEC is such a mess ... but.
Certificate transparency is nice. Browsers could require it for DANE certificates, just like they require it for current Web PKI certificates.
The people controlling the TLD of interesting can exert control over the domain of interest in order to issue a DANE certificate. But they can also exert control over the domain of interest in order to request a domain control certificate, so widespread use of DANE wouldn't add any new adversaries. If DNSSEC wasn't a mess, and DANE replaced WebPKI, we would eliminate the risk from CAs without adding a new risk --- TLDs (and the DNS root) are existing risks.
And if they don't, DNS is already a database. You could just query domains to check their certificates. People running recursive DNS servers could double-check certificates.
If the DNS takeover is limited in scope, the legitimate owner wouldn't be able to query it.
CT addresses scoped attacks by making all webpki trusted certificates public knowledge. You would want something similar with DANE.
CT seems useless for DANE because the cert is self signed, so anyone can just flood the CT with self signed certs for your website. It's useful with WebPKI because only certs signed by a CA go in CT and it's a big deal if one is mis-issued. Anyone can mis-issue a self-signed cert at home for fun.
You'd have to do something like pre-publish in DNS, submit to CT which verifies that it's in DNS before logging. And the CT could rate limit on domain name or something to reduce abuse.
> every government will absolutely double-issue certificates to police, secret service and friends of goverment, and no one will have any recourse.
Countries already have CA that issue certificates with more legal force than a handwritten signature. I can open a bank account, pay my taxes and sign up to all government services. But I can't use them for a webpage.
> With DANE (or other country-issued certificates)
DANE isn't a country-issued certificate. It's a scheme where you store your public keys on DNS records. Of course, now we have the issue that DNSSEC (signed DNS records) isn't widespread and the whole issue with DNS registries.
DANE is entirely dependent on DNSSEC, and DNSSEC is, by design, under the government control, with all the bureaucratic mess and mistakes this implies.
This would be pretty terrible if anyone actually cared about DNSSEC, but luckily for us, no one cares.. So let's keep things this way.
Domain registries can already get a certificate for your domain by changing the address to their own server temporarily and then doing ACME with LE. So no new vector is introduced by directly putting the cert in DNS.
You obviously don't know how DNSSEC works. The DNS root of trust is ICANN, not a government.
That's worse, because ICANN is effectively the US government.
I'm the first to admit ICANN has issues, but US government control doesn't seem to be one of them.
> I trust governments much less that a conglomerate of competing corporations
Let's not create a world wide PKI based on a political ideology.
> country-issued certificates [...] every government will absolutely double-issue certificates
This is such a strange argument. If you register a .ru domain, do you really think you are safe should the Russian intelligence services ask for a valid certificate? Controlling the actual domain, they could issue ask many domain validated certificates as they wish.
The problem with our current SSL PKI, as so very many people have pointed out over the years, is that any CA is allowed to issue valid certificates for any domain name. There have been proposals to use X.509 extensions to remedy this, but they have seen lesser real world usage than the various certificate revocation schemes, which is very close to zero already.
If there was no way for a Russian CA to issue certificates for .us domains, real world security would improve. A lot. And the other way around, of course.
Feel free to s/Russian/Chinese/ in the above argument or whatever tickles your geopolitical fancies. The argument still stands.
Domain registries decide who owns what domain. That is their literal role. You would think that asserting this ownership cryptographically would be a no-brainer in 2026. Yet we have this discussion over and over again. There are many people whose income quite literally depend on the status quo of our global SSL PKI, which coincidentally also offers no end of possibilities for the various intelligence services around the world.
The next time someone tries to scare you with that governments or intelligence services control DNS and therefore it would be crazy to limit issuance of certificates to them, take a look where they have contracts.
> The problem with our current SSL PKI, as so very many people have pointed out over the years, is that any CA is allowed to issue valid certificates for any domain name. There have been proposals to use X.509 extensions to remedy this, but they have seen lesser real world usage than the various certificate revocation schemes, which is very close to zero already.
Some of the browser root programs include (or have included) restrictions on what tlds a CA is allowed to sign. I think for some of the iffier CAs that nonetheless had a huge marketshare in their country of origin.
No need for the CA itself to include it in their root certificate.
It would be handy if the name restrictions actually worked though. Then you could probably get a CA to sign an intermediate CA authorized only to issue certs for your domain(s). There are some CAs that will do that already where they provide an HSM with the intermediate CA's key that will only sign certs for authorized domains, but the CA cert does not encode the constraint and this is permitted by the ca/b agreement. It just seems like it'd be nicer if it just worked.
Unfortunately the CA/B Forum has high requirements for constrained subordinate CA certificates[1], which to me sounds a lot like regulatory capture.
[1] https://community.letsencrypt.org/t/sub-ca-with-wildcard-cer...
It's not that high of a requirement. The sub-CA is allowed to self audit. But the original CA does have to check a percentage of certificates issued by the sub-CA.
So that's not going to be free. But it might be possible to do it if you were big enough to pay for it. I have dreams of having my private CA also signed off on by webpki so apps and browsers could use the same servers without having to include webpki in my apps.
Not that I really work on such things anymore.
I also started going down this rabbit hole when I wanted my homelab to just work in any device, and for advanced use cases Let's Encrypt isn't enough. I tried long and hard to get a sub-CA certificate, but apparently that's in the realm of «if you need to ask, you can't afford it».
Yeah, not gonna happen for a homelab. Need to be a big company so that it might be worth spending the money.
> I trust governments much less that a conglomerate of competing corporations.
There’s no essential difference between the two from my perspective. Why are these my only choices?
One, in a democracy, is accountable to adults in the same jurisdiction. The other is only accountable to those with financial ties to its success.
>One, in a democracy, is accountable to adults in the same jurisdiction
Or so they say. How's that been working out in practice?
If each country could only sign its own domains it would make sense. If the US could only tamper with .us domains the system could be trusted in general. After all, that's no worse than what they already do by coming to your house and putting a gun to your head.
Pretty well, in my experience.
Yeah, that's why most countries in EU, as well as US, are in a huge dissarray, politicians have all time low approvals, people vote for something and get the opposite, and the economy and social climate turned to shit...
I guess one doing well enough can be oblivious to all this...
Try to read less tabloids.
LOL, talk about out of touch. You need the press to tell you that?
You can also just read "prestige press" - it will tell you the same. Or socio-economic indicators.
What other choices are there?
An international body might work, or just move the issue one step back.
Pretty much any big government has a CA they can exert direct control over whenever needed.
Maybe, but then can only do it once. Then they get caught, and their CA is distrusted. See Diginotar [0] for example.
And things only gotten better since - we now have CT logs, and browsers require them, so any mis-issuance can be detected automatically, by any interested third party.
If we go to DANE, we lose this all. "Oops, our CT uploader process failed, we will fix Real Soon(tm) we promise" - and what are browsers going to do? Distrust the entire country?
[0] https://blog.mozilla.org/security/2011/09/02/diginotar-remov...
Side note: “DigiNotar BV was a Dutch certificate authority from 1998 to 2011. It was acquired in January 2011 by VASCO and subsequently declared bankrupt in September of the same year” [1].
I didn’t realize the slapped their face on the pavement right after being acquired.
[1] https://en.wikipedia.org/wiki/DigiNotar
The Dutch government didn't exercise control over Diginotar.
In the Dutch hacker scene, Diginotar was a meme. Everyone knew it was a mess there.
Do we also need to put all our letters into strongboxes before we send them?
Maybe we should have solve the ISP snooping problem by making that illegal instead.
This just leaves every single public Wifi network - which used to mess with traffic a lot
Guys, we live in a society.
> Do we also need to put all our letters into strongboxes before we send them?
If it were as cheap and efficient as TLS these days, yes, absolutely
> Maybe we should have solve the ISP snooping problem by making that illegal instead.
We could do both! ISP snooping is still a problem for metadata (SNI).
Apparently the cost of TLS these days is to subject yourself to whatever laws that countries of "free" TLS want to impose on you. That isn't very cheap.
I'd also love TOFU for TLS, at least on .local TLDs, but for publicly hosted websites, I've come around to the idea that maybe encryption without authentication would not help that much these days.
As for who does that authentication: Given all the suggestions in the sibling threads, I really don't think we're in a situation where there's a single entity gatekeeping access by any means.
The entire point of a trust model is to exclude people. That's the stated goal.
If you want encryption without trust, just use self-signed certs.
The problem is that the current trust model is totally untrustworthy.
Philosophically, trust isn't a "solvable" problem. It can only be mitigated to varying degrees. However, some degree of trust is probably better than none.
One thing is sure, pinning trust on trust chains down from Root Certificate Authorities is fundamentally incompatible with our notion of trust and an almost absurd idea to start with. Most people using a browser don't even know any person from such an organization nor would or should they have any rational reason to trust them.
> our notion of trust
I suspect I may have a different notion of trust than you
> Most people using a browser don't even know any person from such an organization nor would or should they have any rational reason to trust them.
Back up one step further -- most people using a browser don't understand the problem set we're talking about even exists
As long as you're human, you don't have a substantially different notion of trust than I do. It's part of human psychology. We had to evolve it as social beings. I've seen very ad hoc CS papers on "trust", though, which IMHO were based on nothing but fantasy. Perhaps you had one of those re-definitions in mind. I tried to contribute to this pointless literature myself for a while until I realized that it's completely fictitious. All you can say from a mathematical perspective is that trust builds up very slowly based on a numerous factors and, if betrayed, goes down very fast and stays there. However, the notion doesn't have enough substance for a fruitful non-psychological modeling; there is just not enough ideal rationality behind it.
If you don't care about who you're talking to, why use certificates at all?
If you don't care about who you're talking to, why use encryption at all?
> This somehow confirms my gut feeling that digital certificates are mainly a means to enforce exclusion on behalf of the certificate authority ownership. It is a tool to prevent people from taking full ownership and control of whatever is affected by digital certificates, be it software, firmware, hardware, or as in this case SSL/TLS. That's digital tyranny in disguise.
I think the "digital tyranny" is a side effect, not the main goal. They're "mainly a means" to prevent certain kinds of MITM attacks.
You could that with a much saner approach like DANE.
Not back when SSL and the PKI ecosystem was developed.
Yes actually you still could've. But it would require a pass through the IETF to stabdaddize a DNS record type, and that would delay Netscape's release.
Any DNS-based solution needs something like DNSSEC to work. I believe DNSSEC didn't exist yet when HTTPS was being developed and even if it did, it wasn't anywhere near ubiquitous enough. Is it even these days?
No, fewer than 5% of North American DNS names are signed, and the number has gone down over some recent years.
That's kind of like saying that any CA-based solution needs something like a root program. Sure, but that would just be part of creating a DANE-like solution. Both the current CA solution and DANE or another hypothetical DNS-based solution are fundamentally similar on a technical level: hierarchical delegation of authorization backed by public key crypto. The main difference is where on the delegation chain you limit authority for further delegation and who controls the root. The DNS-based approach has the crypto system reflect real ownership while the CA-based approach has browsers makers at the top and whoever pays enough money and hasn't publicly fucked up yet at the middle with delegated authority to sign literally everything.
That's one way to put it. Another way to put it is that the CA system keeps cryptographic trust managed by organizations that can easily be destroyed if they fail, while DANE's trust is practically irrevocable.
I always thought the main goal was to force people to pay money for certificates.
Let's Encrypt certificates are free.
It seems that, as soon as you transact with a sanctioned entity, you are globally in breach of the agreement and risking the revocation of all your certificates — also the ones for non-sanctioned countries.
Front matter:
2.1 "Term": 3.1 "Warranties":I said hi to an Iranian today. Lets see if LE revokes my website.
Is this a canary?
What's gonna happen if I were to begin or continue using one letsencrypt certificate from ... Greenland? Cuba? The EU?
Has letsencrypt been served with a subpoena?
> Has letsencrypt been served with a subpoena?
While it's certainly possible that ISRG has been served a subpoena because it appears the US DOJ is now a mix of hacks and incompetent buffoons, it wouldn't matter because the whole point is that they don't know anything - what you told them is literally logged publicly for everybody to see without even knowing how to spell "subpoena" let alone issue one.
Some people have this insane idea that somehow the CA has some secret which either they minted and sent to the CA, or the CA minted and gave them a copy and so the US government could get this secret with a subpoena - but the whole fucking point of a Public Key Infrastructure is that we're using Public Key Encryption, if we were OK with everybody having secrets all over the place this entire thing wouldn't be needed.
They have the secret of the private keys used to sign certificates.
Looking at LavaBit^1 I really would not be so comfortable. The world and especially the US has not gotten more free since then.
[1]https://en.wikipedia.org/wiki/Lavabit
They could mint certificates, for / about any name. But, those certificates won't work in popular applications unless the certificates include proof of logging.
So to be effective this means a hypothetical bad actor (maybe the US government or anybody else) issues bogus certificates, then either logs them - making a permanent record for everybody to see, or also subverts two or more logs, so that they issue bogus proofs.
This is a very expensive one shot attack on whatever the target would be, I guess it's not stupider than "Let's bomb Iran for no good reason" but it's up there.
For the vast majority of cases, would anyone notice these malicious certificates being created and logged?
I don't subscribe for my personal domains, because who cares, but when I was in charge of certificates for something important I subscribed to notifications from several providers to make sure I didn't miss anything.
I would like to think at least all the high profile destinations have someone watching.
What constitutes the "vast majority" ? Periodically I check mine, and I sometimes have reason to check others, I no longer run my own log auditing (I did when I worked somewhere else because it was close to my main field of interest) but other people do.
How can you check other people's certs? How do you know whether a cert issued is authorized by them or not?
The only one who can check for maliciously published certs is the entity authorized to request them. I think most companies are happy when they manage to have valid, not expired certs and do not care too much about making sure there are not too many of them.
You are right that if the state would start issuing malicious certs en mass that would be found out quickly. But I think very targeted selected operations against entities where they know the entity is unlikely to surveil for unauthorized certs are very much possible.
I'm not arguing for going into conspiratorial thinking and claiming CAs are all compromised and issuing malicious certs all the time. But I do think that it is feasible for states to use CAs under their direct or indirect control to run targeted attacks. I think that is a plausible, serious risk that we do not care enough about and that we should do something about. There is a multitude of precedence starting from LavaBit over the wiretapping of jabber.ru^1, ANOM^2 to CryptoAG^3 that supports this conclusion.
[1]https://notes.valdikss.org.ru/jabber.ru-mitm/ [2]https://en.wikipedia.org/wiki/Operation_Trojan_Shield [3]https://en.wikipedia.org/wiki/Crypto_AG
If there's a competent admin or it's just entirely autopilot for some huge generic host you'll see a very boring pattern where there's a cert and then as it gets close to expiring a new cert is issued, e.g. 4-5 days before it expires, or on a Tuesday at about 8am, or whatever - and sure enough you'll see the same pattern in the cert presented when you access their web site.
In these cases it's really obvious if there's anything weird going on. You're correct that we can't know, as a third party why there's something weird. Maybe the server was being replaced and the new server just installed an ACME client and got itself a new cert last Tuesday even though the previous one doesn't expire for weeks. But if there was nothing we don't even need to ask anybody what's up - nothing is.
IMNSHO The statistics don't really work for targeted attacks. The odds you'll get away with it are unknowable and you only have to get unlucky once.
> How can you check other people's certs?
There are red flags you can look for, but you need to confirm with the domain owner to be sure. CAA records can tell you what CAs are supposed to issue a certificate. Many companies always use the same CA, so a change to a different one could be suspect.
For the wiretapping scenario, domain verified certificates do not protect against that scenario. If the wiretap has full control of your server's network, then it can issue a certificate of its own. No need to compromise a CA.
For any target of sufficient value that a government would do that, yes. Of course it doesn't happen anyway, because governments don't have some kind of secret access to CAs.
> Some people have this insane idea that somehow the CA has some secret which either they minted and sent to the CA, or the CA minted and gave them a copy and so the US government could get this secret with a subpoena
LetsEncrypt certainly doesn't, but I've seen certificate storefronts that generate the key on their side and provide you the key and the certificate, so you don't have to figure out how to generate a key.
The Certificate Authorities are specifically forbidden from doing this because it's so obviously a terrible idea. Many of them also require that their resellers (obviously Let's Encrypt basically doesn't have resellers because that's stupid) also do not do this because it's a terrible idea.
But yes, you're correct that, especially when "cheap SSL" was a thing, outfits which did this really existed. In fact one of the companies which did this, and then deliberately revealed customer keys, resulting in all the affected certificates being revoked, isn't even bankrupt so apparently their customers are so stupid than they're still paying money for a service that's much worse than useless. Not an optimistic thought about humanity.
Neither Greenland nor the EU has been sanctioned by the US.
They haven't been sanctioned, yet, but we live in a time where that's a real possibility.
Have you heard about the judge from international court or whatever it is called?
https://www.france24.com/en/americas/20250820-us-hits-icc-wi...
Are you saying the ICC is the EU? Or that it's Greenland?
I think the point is people are getting sanctioned for arbitrarily stupid reasons these days.
It wasn't made very well.
Yet.
It is not exactly an outlandish suggestion that this may happen.
So far
Now this is very bad, as bad as it can get. As soon as all local services will stop working in sanctioned countries, those countries' governments will force all users to either install a root certificate or lose access to all local services and websites. And then it will be possible to use that root certificate for MITM attacks. In the worst case scenario, after the majority of users will install the root certificate, state DPIs will MITM all traffic and will block all un-MITMable traffic.
Sounds like the sanctions worked.
Don't understand why you have been downvoted. Russian government have already attempted to push forward their root certificate for banking using Yandex browser, now this.
Is this actually new? Looks like a standard US export restriction for encryption technology to me. These sorts of restrictions have been around since the '90s.
Let's Encrypt becomes subject to US export restrictions on cryptography if they are a US company, or if they post anything to github or post anything to major app stores. Every app I have ever posted to Google Play has had to submit a form to the US government declaring what use they make of cryptography.
These restrictions have been in force since that late 1950s (with a long and complicated history with respect to computer cryptography). This particular text looks like a boilerplate restriction, that's required to comply with US EAR export requirements to me.
A certificate is not cryptography, though, it's a number. The entity requesting the certificate already has the cryptographic software installed on their servers, as do the clients trying to connect to them. There's nothing technologically special about the number, it's all in the realm of the social contract, in that it has been blessed by a chain of trust.
Everything is a number.
You can represent arbitrary data as a string of numbers, but a certificate is quite literally a number. It's a secret solution to a mathematical equation.
Organisations that are serious about promoting privacy should have been avoiding the US since the '90s and/or '50s, but the second best time to reincorporate in a safe jurisdiction is today.
Gotta love the word 'sanction'. It is it's own antonym! "The committee sanctioned the new policy." (approved it) "The committee sanctioned the rogue nation." (penalized it)
There are many autoantonyms in traditional English, e.g. cleave.
Maybe consolidating ~60% of the web's certificates on to a single provider was a mistake.
Well good thing everyone using the provider is using an open protocol and it's stupid easy to switch
Which free CA should I use instead of lets encrypt that has same browser support?
Actalis, based in Italy offers a free tier, with ACME https://www.actalis.com/subscription
ZeroSSL from Austria also has a limited free tier. https://zerossl.com/pricing/
I mean really, if you use lets encrypt for anything that runs in a production environment, the responsible thing to do is build a fallback to switch to another provider in case LE has a bad day (or hits a brick wall and needs to say, enforce export restrictions).
Worth noting that Actalis requires you to register an account with them in order to acquire the necessary authorization token for their ACME API. This poses a privacy/anonymity issue for some users. Last I checked, Actalis' free tier didn't support SAN either.
Add.: I created an account just now to see "what's what" and also found the notice, "Activate your free 90 days certificates. At the end of the free year, the services associated with the certificates will expire." which sort of sounds like it's just a 1-year free trial.
ZeroSSL / BuyPass
Buypass no longer issues TLS certs since last year.
can you please suggest any alternatives to switch to? i hardly can find any alternative which provides free service and is a non-profit org at the same time.
Before this, they were all unencrypted and you had to pay to get a cert. I guess we could go back to that - now knowing that every unencrypted connection is being MITMed (the world is so much more hostile now)...
This should be one of those things that should be an quick EU win. Running Let's Encrypt is $3-4mill a year, the EU probably uses that on pencils.
The EU could easily bootstrap a Let's Encrypt competitor if it truly cared about removing dependencies on US based entities.
Yes, but EU would have to convince Google and Apple to get a new root certificate to browsers.
Not really. They just have to convince an existing CA that cross-signing their CA won't make Google and Apple mad.
Cross-signed roots are common. Just takes money and maybe audits, but it's the same audit they'd need to get in the browser root stores anyway.
Do you really think the EU wants to sign up for PR that’s essentially “the US is being too mean to Russia” right now?
I think the EU should do it regardless of Russia. The EU should invest in its own technology and not depend so much on an increasingly undependable ally.
The EU is more likely to issue fines to the ISRG and all involved parties.
> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions; (b) a prohibited or restricted party under U.S. or other applicable sanctions and export control laws and regulations; or (c) owned or controlled by or acting on behalf of anyone described in (a) or (b). You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations
Makes sense, they are US company. I am surprised it took them that long.
"US company must obey US law" doesn't make for a very interesting headline.
"The world should stop trusting the US companies" OTOH...
more optimistic would be "World should decentralize America's trust"
The headline is more « US law is batshit and extends well beyond its borders with real world consequences »
This is not an example of that. It is perfectly within US jurisdiction to prevent US companies from doing business with sanctioned countries. That is the point of a sanction, and US is in good company in choosing to use sanctions as a diplomatic tool.
It is more of an example of how the internet/software industry is too consolidated to the US, and thus other countries are too dependent on the US in those areas. If the internet infrastructure was well distributed, then people in sanction countries could simply get certificates issued by a different CA, and in some cases they can. However, this is complicated by the fact that the list of trusted CAs is dominated by US organizations (Google, Mozilla, Apple, Microsoft). If you want to reach western audience you must use certs from a CA approved by them.
Exactly. Ever since I was a kid I never understood how the US has jurisdiction way beyond their borders.
Then I graduated in International Relations and understood that the hole is much deeper than that.
Now it's pretty obvious with all the shit that trump has been doing, but back then me and much of the people I know were oblivious to what US power really means.
The only countries that do not have sanctions are the ones who lack the economic leverage to do so. All developed countries have them.
This is not specific to US law ...
To be fair the US is a bit on an outlier here, as it is not afraid to come down on US companies for things subsidiaries do in other jurisdictions, on questionable grounds. So it would not be enough for Let's Encrypt to operate a European operation to sign European certificates.
Should the US wish to sanction the Hague, somewhat famous for its international court of justice, they would absolutely go after ISRG and it would not be enough for them to sever the ties of the hypothetical Let's Encrypt Europe. That would not be legal or last least highly questionable in most other democratic countries.
US law is something US citizens get to decide. If they think it's "batshit", they should vote accordingly. In this case sanctions seem a pretty good alternative to going to war.
The US is an oligarchy. Voting in the US is completely irrelevant to which laws pass - there have been studies about this.
It's clear that those who voted recently for the President are getting what they wanted. Voting made a radical difference, even if the outcome isn't one I like. Whatever "studies" you read are obvious nonsense.
It is however a reminder that "just use LE" is not a valid response to concerns about protocols/APIs/browsers/etc requiring TLS.
That's just another reminder that no one from outside of US should deal with US companies.
Of course not! just find viable alternatives to Microsoft, Apple, Mozilla, YCombinator, Google, Intel, AMD, ...
In all seriousness, as an American I'd love to see a healthier, more well-distributed tech industry, but I don't see many companies stepping up to provide competing services. It's my understanding that china has alternatives to many of these products/services, but I really don't see how anyone in Europe could possibly use a US-free internet.
> but I don't see many companies stepping up to provide competing services
Maybe because the US dropped most of its anti trust regulations, leading to ridiculously monopolistic practices such as "acquire everything that may be threatening".
When was the last time you heard about a European cellphone manufacturer, or social media network, or web browser being acquired by an American monopoly?
I can only think of Nokia, purchased by microsoft in 2014. Those phones ran windows CE before that even, so you could hardly have avoided the american tech industry.
All I'm trying to say is, it's impossible for Europeans to both A) be on the internet and B) avoid the US tech industry.
Nokia phones ran mostly on SymbianOS
Sorry, I stand corrected
In the EU there is the threat of jail time if a user of your service does something bad and you haven't completed the necessary bureaucracy to be immune to it. This is the opposite of the US. See for example pissmail.
that's why the world need to wake up. With the due respect of any political beliefs here, in the course of politics any country can be deemed the US enemy (or any other country's enemy as a matter of fact), so for example firing the 3/4 of the company because we have Claude and ChatGPT (US based) is a major business continuation flaw...
Actalis https://actalis.com/ is a good EU alternative.
No it isn't. Not unless it's free.
This is the main reason letsencrypt is so popular.
They do have a free plan with unlimited ACME DV certs, though! Not marketed very well and no wildcard certs, but it does exist.
Had to look for but found: https://www.actalis.com/activate-free-plan
Oh, I stand corrected, thank you. I actually looked and couldn't find it. Indeed they could market it better.
There is a free offering.
Can anyone explain me what went wrong with http://www.cacert.org/ and why they are not supported by any major browser ?
the wikipedia page has links to projects that removed CAcert where reasons are stated. the main one being that CAcert didn't complete a security audit or because they were not yet accepted by mozilla (because of the lack of an audit, but also because CAcert actually withdrew the request to be included). one group removed it because CAcert has a strict root redistribtion license that they can't follow.
LWN has a good writeup on the audit situation as of 2014: https://lwn.net/Articles/590879/
Took me a minute to parse the headline -- Sanctioned as as in "imposed penalty" (ie "sanctions"), not as in dictionary definition #2 "official permission or approval".
Perhaps because "US territories" are a thing, perhaps because it's way more newsworthy if LE bans the US, or perhaps im just a dummie.
Has anyone got any experience with Zero SSL? https://zerossl.com/ It seems like a good EU alternative.
EU? There’s almost zero information on the company, no privacy policy? The only place I found any mention is the footer, “HID Global Corporation, part of ASSA ABLOY”. Assa Abloy seems Swedish but HID Global is a US company as far as a quick search goes. But without a proper company info page and privacy policy I wouldn’t consider it anywhere near a “good alternative” regardless.
Jumping in here since we’ve been seeing more mentions of ZeroSSL lately, likely related to the recent CA/B Forum discussions around 1‑year certificates and ACME automation.
- We’re based in Austria (ZeroSSL GmbH). The company was acquired by HID in 2024, which is part of Assa Abloy (Sweden).
- We’re not positioning ourselves as a purely EU-based CA substitute, and we generally don’t market it that way.
- For DV certs specifically, we act as a distributor. Under the hood these are Sectigo-issued certificates, similar to how other providers (for example Namecheap) operate.
Happy to clarify further if useful.
> - We’re not positioning ourselves as a purely EU-based CA substitute, and we generally don’t market it that way.
OK, but in the context of this topic thr interesting part isn't your marketing but your jurisdiction.
Could you clarify which jurisdiction you operate under and a link on the ZeroSSL website that collaborates that?
Thank you <3
[dead]
Sectigo used to be Comodo's CA business. If memory serves, that business was purchased by a US PE firm and renamed "Sectigo". Sectigo Inc.'s corporate headquarters is now in Scottsdale, AZ.
There's no reason to believe they're any less subject to US jurisdiction than LetsEncrypt.
There were reason to believe they were less subject to US juridiction: their Subscriber Agreement is for "Sectigo Limited, a limited company formed under the laws of England and Wales". See https://www.sectigo.com/uploads/backgrounds/Certificate-Subs...
Sadly, their United Terms and Conditions in section 8.2 are even more restrictive than LE's. They reject any entity "located in, incorporated under the laws of, or owned (meaning 50% or greater ownership interest) or otherwise, directly or indirectly, controlled by, or acting on behalf of, a person located in, residing in, or organized under the laws of any country sanctioned under the laws of the U.S. or E.U." See https://www.sectigo.com/uploads/backgrounds/United-Terms-and...
From a layman point of view, it could even mean that the ICC and the UN are prohibited from using Sectigo. The Customer must have no "affiliates, officers, directors, or employees" that are on sanction lists, and the US have sanctioned some high-profile members of the UN and the ICC that spoke about the genocide in Gaza.
Any plans on becoming an independent CA? Would certificates issued in your name also risk being affected by US sanctions trough sentigo?
If so, we still need to follow guidelines from our parent Assa Abloy, a public company from Sweden, which has itself a list of restricted countries they are doing business in.
https://help.zerossl.com/hc/en-us/articles/360060119833-Rest...
If they do business in the US they will be expected to comply with US law - this includes their stock being traded on US stock exchanges.
If they don’t have any business in the US and any financial ties to the US they won’t be subject to the sanctions. But I believe it will create issues if they want to enter the US market.
HID was originally American and Scottish, but became fully American in 1994.
HID was acquired by Assa Abloy in 2000. No idea whether that means we now consider it Swedish.
ZeroSSL used to be Austrian until their acquisition in 2024.
I used to work for a company that got acquired by HID. It looks like HID has retained their original offices in some form.
The privacy policy is under legal in the footer, exactly where I'd expect it to be honest. It also gives the company registration: > 1.1. We, ZeroSSL GmbH, FN 443956b (the “Company“) and below that the company address (registered in Austria).
Don't get me wrong, I agree that there is some lack of "who actually runs/controls this", especially on the about page where I expect such things to be.
At the very least it's not as transparent as I'd wish from a CA. E.g their Certificate Agreement is from Sectigo, so are they involved? No mention anywhere else from what I can see.
I don’t see “legal” in the footer on mobile. Or any other link. Or a link to an About page in the main nav. There’s nothing.
Very interesting! Yea I was on desktop, that's a really bad oversight to hide all of that on mobile...
3 90-day ACME certs for free. 180€/year for unlimited 90-day certs and 5 yearly ones.
That’s a pretty steep increase. I would almost be more interested in a monthly fee per cert.
From their docs[0] this doesn't seem to apply if using ACME, but they don't exactly make that clear...
> By using ZeroSSL's ACME feature, you will be able to generate an unlimited amount of 90-day SSL certificates at no charge, also supporting multi-domain certificates and wildcards. Each certificate you create will be stored in your ZeroSSL account.
[0]: https://zerossl.com/documentation/acme/
Yeah, they don't make it that clear, but you get basically the same functionality as with LetsEncrypt for free, including wildcard certs. You basically only need to pay for manually issued certs, or some of their other additional features.
I use them in some cases to avoid the rate limits on LetsEncrypt, and they have better support for some older platforms (like ancient Android versions), and I'm pretty happy so far. I have a paid account to support them, but it's not a requirement for ACME certs. It works without issue with Kubernetes Certbot, and seamless to switch between ZeroSSL and LetsEncrypt.
I can't comment on the EU part though - not that relevant in my case.
There was some subtle issue with ZeroSSL's implementation of ACME that I ran into with, IIRC, lego and domain certs and there was a ~5 year old lego open issue about it. That was a couple years ago, might be fixed, but my understanding at the time was that it was an issue with Zero's ACME implementation, so there may be dragons.
ZeroSSL aren't an EU-based alternative, unfortunately.
It's Sectigo under the hood.
Hello! The US is the enemy of democracy. If someone should be banned, then them.
> active eavesdropping (e.g., monster-in-the-middle attacks)
is this standard MitM, or is it some crucially distinct variation?
Man in the Middle Wiki:
> Also known as a monster-in-the-middle,[1][2] machine-in-the-middle,[3] meddler-in-the-middle,[4] manipulator-in-the-middle,[5][6] person-in-the-middle[7] (PITM), or adversary-in-the-middle[8] (AITM) attack.
Those sources feel more than slightly contrived.
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"concepts like "man" and "woman" are deeply sexist and offensive in their culture".
Only to people who have a need to be offended.
Being offended is a core part of the American identity.
I kinda like this framing. It effectively classifies companies such as Zscaler and CloudFlare as monsters.
It's particularly funny because "monster-in-the-middle" appears to be a deliberately quirky marketing term invented by cloudflare.
Fun fact: some older articles were originally written using the term man-in-the-middle, but at some point were updated... except that the diagrams still use man-in-the-middle because search-and-replace doesn't work on images.
For all the people commenting, the ITAR rules still apply for TLS, if you want to use TLS in an app for iOS/Android, one of the requirements is to get an ITAR exemption as part of the app review [1].
The US sanctions are imposed on entire nations (eg Iran), so LetsEncrypt have no option but to state in their conditions that their service is not available. They don't have a choice as a US organization operating under US law.
Whether they choose to enforce that through technical means (eg blocking IPs etc) is up to them.
[1] https://developer.apple.com/documentation/security/complying...
Does it mean that russian/iranian web-sites using letsencrypt stop working and need to change their certificate provider?
Depends on whether LE is compelled to terminate service to BGP AS numbers hosted in U.S.-sanctioned countries, and whether LE continues operating out of the U.S..
It works like this. The US gov sends LE a nastygram saying they must terminate service to sanctioned entities. LE either does that or several people go to jail. The USgov doesn't care how it happens, as long as they can't find any evidence that any sanctioned entities are LE customers.
Depending on how you are supposed to read "You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations." it could mean that you are not even allowed to use LE certificate to provide services to sanctioned entities as a random non-US company/person.
I hope not. We don't have any alternatives yet.
https://www.actalis.com/activate-free-plan maybe?
This page is blocked for me from server's end. I'll try later using VPN, but looks like it won't work :-)
They already revoced certificates for some russian sites
any details on that? links to people reporting it?
max.ru — Russian messenger
https://community.letsencrypt.org/t/why-issue-certificate-fo...
I had been meaning to post somewhere that they issued a certificate to kza.org.kp a few months ago but didn't really seem worthy of its own thread.
I am no lawyer, but while there do appear to be some exemptions for communication related services, it's not clear that this qualifies as LE isn't actually providing telecommunications, just a certificate file. And it's not even an issue of the encryption itself, North Korea is under a general embargo so any exports or trade whatsoever is restricted by default.
As an aside, many of North Korea's web servers appear to be old enough to have Heartbleed based on their banner versions, but most don't actually have HTTPS in the first place.
To be put in perspective with their push for very short live certificates, like 7 days, with the argument that anyone can easily get certificate from at any time.
But in fact, little by little you have all the stacks needed to be able to isolate some entities from internet at the us request in a very short time
Why when connecting to a TLS website service that does not have a CA signed certificate, I am welcomed with "Secure connection failed, browser not trusting the ceritifate. Do you want to continue?", without showing me the actual certificate fingerprint?
On desktops browser displaying the fingerprint/hash requires clicks, on mobile is not implemented and on native apps practically not existing.
The keys should be shown, so they could be verified manually in person or via other channel. Just like the SSH do. Someone say people would just click "accept" without a thought, but the button is already here, just no information what actually is accepted.
The title was a bit misleading.
When I read it, I interpreted it as "let's encrypt bans certificate usage in - any territories endorsed by the US". Took me reading a couple comments to understand it actually meant "territories under US sanctions".
It their right to do that.
But can we still trust them?
I am not well versed in how their systemwide certificate issuance works: If they have to add this to their terms to comply with their government, could the same government use pressure to leverage let’s encrypt to do harm.
Yes, of course it could and it will. I don't think the US government has ever missed an opportunity to be corrupt and break shit for stupid reasons.
This is bullshit on par with the Chinese firewall, meant to effectively prevent the (entire!) western world from information by parties deemed persona non-grata. SSL certificates are supposed to be about security, not geopolitics.
I'm pretty sure a LE server hitting an Iranian or North Korean endpoint and validating a crypto challenge does not break any OFAC or EAR rules, and no money changes hands. And if a non-US entity wants to do it, the US would just sanction them. Microsoft and Mozilla are certainly not going to include a North Korean or Russian state CA in the root trusted certs (and if they did, the US government could just threaten them with sanctions, too).
Hard not to say "we warned you" about making self-signed certs completely unusable in favor of a very centralized approach.
It was a great hack, but it was always just that: a hack. We all always knew that the "certificate authority"-hierarchy is broken and can easily be abused by the ones in power. I appreciate everything that the let's encrypt peeps have done for the world, but the cert authority system really needs an overhaul.
Is Let's Encrypt the only provider of SSL certificates?
Genuine question! Because I assumed there were other places you could get a SSL certificate, but people in this thread seem to be implying that without Let's Encrypt, there's no way for people in those sanctioned territories to get a cert.
If it was a genuine question, the genuine answer is it's the provider that democratised streamlined ACME certificate verification and made it for free
No account, no payment, a single bash command or a certbot that runs regularly and you have your own globally recognised certificate
Historically, providers used to make the most frictions so that they could justify absolutely crazy fees for signing any certificates. It doesn't goes down well in DevOps, it doesn't work with indies who don't have 3 to 4 digits figures to blow in httpS, everyone including organisations ended up making certificates authorities of their own to sign stuff... and let's encrypt was successful at making certificates easy, free and actually secure
> Is Let's Encrypt the only provider of SSL certificates?
No.
There are some options. actalis.com is European alternative but free tier is a bit less than Let's Encrypt.
If nothing has changed it's still the only one that's free and instant. Back in the day you'd had to pay $10/y and install manually
https://zerossl.com/
We all knew something like this was coming when we decided to centralise the web around Let's Encrypt.
In reality of course you can probably just ignore this as long as you request the certificate from a proxy in a nonsanctioned country and you don't stick out to the government.
Time for a non-US equivalent of Let's Encrypt?
How will you get Mozilla and Google to trust it?
Especially since sanctions are transitive. Mozilla and Google, being US companies, are actually not allowed to trust any entity whose purpose is to work around sanctions. Their members could go to jail for that.
Yeah, let everybody build and use their own services, and then the US will end up having less control and visibility. Great tactics!
Dictators love it when their citizens can't use encryption. It makes them much easier to control and monitor.
What other CAs implement ACME? Are there any free alternatives outside the US?
Weird. The copy I read says they have just deleted that section of their user agreement.
How are they going to enforce this?
I would imagine, as a CA that issues only DV certs, they'd disallow issuance to various ccTLDs, and perhaps stop newAccount registrations with email addresses at those ccTLDs. That's about as much as they could do - IP-blocking by region is ineffective and crude at best.
The question is, will that be enough? If OFAC can demonstrate that even with such restrictions, sanctioned entities are frequently obtaining certificates, they may be forced to require account creation or something else as a means of limiting that.
They also likely would have to implement some kind of domain name screening, just like banks have to block transfers that mention "Havana" or "Tehran".
They are currently not doing anything, even ccTLD blocks. They have issued certificates for .kp domains this month and in August of last year.
A lot of the pushback browser vendors got for locking APIs behind so-called "secure contexts" was because everyone (including them) knew this would happen. If there is a centralized system, some politician will manage to find a way to fuck with it.
Iran and other tyrannical governments can easily set up their own CAs and force their citizens to use them. Iran likely already has this infra in place. This ban does nothing but highlights LE as the liability it is. The decades-old certificate authority scheme is no longer fit for purpose and needs to go.
If you're a web developer, consider offering your site through public key-addressable networks. Reticulum and Tor are good options that work today.
PLEASE DON'T DO THIS )":
the reach is by rough estimates ~2.5–6 million websites globally, 2–5 million of those in Russia and 0.3-1 million in Iran
Whatever USofA, it's not hard to have their own cosmodrome and certificates.
Tangential, in 2026 website certificates feel like nothing, disposable automation artifact, toxic max-security[1], vehicle for those who rent seek, fingerprint.
[1] https://tom7.org/httpv/httpv.pdf
All they can do is disable support for certain ccTLDs, but other than that, it's unenforceable.
That's why many tech companies echo these laws overtly and with a lot of fanfare... They know they have no real control over who uses their services, so this is a way to signal their good faith and best effort in advance, in case they end up caught up in some foreign cyberbullshit.
this is big blow to the Internet society very disappointing to read this..
huh? the linked document shows that bullet item as deleted.
And now imagine that one of the Trump tantrums contains an announcement of sanctions against the European Union.
He already announced sanctions against Spain. And took them back when Germany announced that sanctions against one EU country meant sanctions against them all.
The uninteresting version of this is “US entity follows US law.”
The interesting version is that Web PKI is not just cryptographic infrastructure. It is also a policy distribution system. A browser trust store, a CA, a subscriber agreement, revocation rules, export controls, and sanctions law all end up in the request path of "can this site speak HTTPS to normal users?"
That does not make Let’s Encrypt uniquely bad. Any CA has some jurisdiction, owners, contracts, root-program obligations, abuse process, and legal exposure. Moving the CA changes the governance surface; it does not remove governance.
But it does mean "just use Let’s Encrypt" is not a neutral answer when protocols, browsers, APIs, app stores, or regulators effectively require TLS. The operational dependency is not only ACME uptime and certificate issuance. It is also jurisdictional continuity.
The hard product question is what failure mode we want:
1. Web PKI: power concentrates in CAs, browsers, and root programs. 2. DANE/DNSSEC: power shifts toward DNS operators, registries, registrars, and governments. 3. Self-signed / TOFU / pinning: power shifts toward application-specific trust and worse UX. 4. Multiple CAs: better resilience, but still bounded by browser trust stores and legal chokepoints.
There is no apolitical trust system here. There are only different control planes with different failure modes.
The practical ask from Let’s Encrypt should be clarity: issuance vs renewal vs revocation, existing certs vs future certs, domain location vs subscriber location, hosting location vs user location, and how they interpret “use” of a certificate. Without that, operators are left guessing whether this is a narrow compliance clause or a broad infrastructure-risk event.
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What in the actual fuck?
I had the parent organization of LetsEncrypt (Internet Security Research Group) in my Will, but after reading this, I will remove it immediately. US sanctions harm too many innocent people.
Sanctioned has a double meaning here[1]:
> 2. officially or formally ratified or confirmed.
> 3. penalized, especially by way of discipline or to force compliance with legal obligations.
So who can use lets encrypt? Those that are penalised or those that are confirmed.
[1] https://www.dictionary.com/browse/sanctioned
If you click the link…
> [You certify to LetsEncrypt that] …
> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions; (b) a prohibited or restricted party under U.S. or other applicable sanctions and export control laws and regulations; or (c) owned or controlled by or acting on behalf of anyone described in (a) or (b). You agree to use Let’s Encrypt Certificates and any services provided by or on behalf of ISRG in compliance with applicable U.S. export control and sanctions laws and regulations.
It took me a minute to understand the original post because the verb sanction means both itself and basically the opposite of itself. It would be better to say "any territory that the US has levied sanctions against". I thought LetsEncrypt had banned its usage in the US! The word for words like sanction is contronym.
This actually makes sense. No freedom for the enemies of freedom.
the list of ppl under US sanctions is staggering
Europe starts to shield itself from the risk since Nicolas Guillou, the French ICC judge who issued a warrant against bibi got sanctioned (France officially protested about this case)
China is being successful at blocking US firms out of their supply chains (they already use Linux on Loongarch processors with some homemade architecture and pioneer RISC V), since a bunch of their companies also got sanctions for supplying the governement
US stands so much for freedom that it's the first country to refuse immigration to FIFA world cup teams and athletes, with Iranians not allowed to stay between games and Somali goalkeeper being turned away at the border. Germany itself didn't do for the 1936 Olympics.
So at best, they're only shooting themselves in the foot by showing any US component in a supply chain is a risk, while using US clouds were already a risk of loss of revenue from FISA requests to undercut your bid and rot your company and using US dollars for trade was already a liability
In the meantime, US companies can do anything, break any financial law and abuse every human right, they'll just sign DPAs to avoid prosecution
love thought-terminating cliches. really helps keep from actually thinking ever.
Your comment reads like a thought-terminating cliché. If Russia occupied your city, killed your family and friends and left you homeless, you might reconsider giving freedom to those who take it away from others. Unfortunately, sanctions are often very easy to evade.
This is a reasonable point, if "enemies of freedom" and "enemies of America" are synonymous...
Now imagine the USA did that to the city you live in...
it can't happen, they only attack civilians in countries that have weapons of mass destruction or have a evil economic system of socialized healthcare and labor market
They also don't like states that threaten business by turning workers into a commodity that you have to compensate each month ; Spain sunk the Maine ; and they had manifest destiny given from God to get rid of natives
Ah right, that's why there's US sanctions on Israel?
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But what if you're the baddies?
Then try not to be completely dependent on the products of a company that is under the control of your enemy.
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