Hello, Andy Steingruebl here.
On October the National Telecommunications
and Information Administration (NTIA) published a Notice on Inquiry in the Federal Register related to DNSSEC and Root Zone Signing.
PayPal has responded with comments, which are posted below and should show up soon at the NTIA DNSSEC site.
Our submission is below.
**************************************************************
TO: DNSSEC@ntia.doc.gov
FROM: Michael Barrett, Chief Information Security Officer, PayPal
RE:
Notice of Inquiry on Enhancing the Security and Stability
of the Internet’s Domain Names and Addressing System — 73 Fed. Reg.
59608 (Oct. 9, 2008) and
http://www.ntia.doc.gov/frnotices/2008/FR_DNSSEC_081009.pdf
DATE: November 21, 2008
Thank
you for this opportunity to comment on implementation of DNSSEC (Domain
Name and Addressing System Security Extensions) at the root zone level,
on behalf of PayPal. Since 1998, PayPal has been the global leader in
online payment solutions. While PayPal has only been in business a
decade, it has about 165 million users globally, operates in 190
markets, and settles in 19 major currencies; in 2007 we processed over
$47 billion in payments.
As a major online financial services
institution, the safe and secure operation of the Internet is of vital
importance to PayPal’s business. This safety and security, and indeed
the ongoing viability of electronic commerce, depend on the trust of
consumers. They must know that they are interacting with the real
PayPal and not a phishing site. PayPal has been a leader in the
deployment of technologies that enable this trust. PayPal was one of
the first deployers of EV (Extended Validation) SSL (Secure Sockets
Layer) digital certificates. It applies digital signatures to all
email it sends to consumers. These techniques enable consumers, ISPs,
and software clients to make trust decisions about what content is
legitimately from PayPal. However, there are limits to what any single
company can do to make the Internet experience of our customers safe
and secure. The current weakest link in the trust chain on the
Internet is the DNS (Domain Name System).
In this context, the
rapid adoption of DNSSEC (DNS Security Extensions) and signing of the
root zone is an urgent requirement. We applaud NTIA for initiating
this inquiry, and urge it to move with all possible speed to implement
DNSSEC. Inaction or further delay would be detrimental to the
interests of consumers and other Internet users, and to the healthy
growth of electronic commerce.
Background
We believe
that there are three major threats to the internet user that are
related to authentication or identifying who users are communicating
with:
- Spoofed websites
- Spoofed Email
- Spoofed DNS
The first two threats are being managed. SSL, along with EV
certificates, largely solves the general problem of spoofed websites
from a technology standpoint - at least for those sites that can put
all of their traffic across SSL. Email signing via DKIM (Domain Keys
Identified Mail) along with other technologies such as ADSP (Author
Domain Signing Practices), and reputation services, mostly solve the
problem of spoofed email. This leaves DNS spoofing as the main
unaddressed vulnerability in this sphere. DNSSEC is the best available
tool for addressing this threat.
DNS spoofing currently falls
into two categories, both of which we believe are threats to PayPal, to
our customers, and to consumers and Internet users in general. The
first type of spoofing is done by an attacker. These attacks can occur
on public networks such as a public wireless access point, or they can
be targeted against DNS infrastructure at the ISP. With the
vulnerabilities inherent in the DNS protocol’s UDP delivery mechanism
and lack of strong encryption for transport, DNSSEC represents the only
way for a consumer and an ISP to identify a legitimate DNS response.
The
second threat of DNS spoofing comes from DNS infrastructure operators
themselves. Many DNS providers, registries, and ISPs are performing
DNS spoofing as a way to monetize user errors, such as when a user
attempts to access a domain name that does not exist. In the case of
DNS spoofing of non-existent domains we believe this is an internet
governance problem between ICANN and the registry for a given TLD.
A
more insidious type of DNS spoofing has taken hold lately that we
believe is also a threat. This is the spoofing of DNS responses for
non-existent sub-domains of legitimate domains within DNS. Many ISPs
in the US and elsewhere are spoofing DNS replies for DNS requests that
generate an NXDOMAIN record type from the SOA (Start of Authority) for
that domain. For example, when a user mistypes ww.paypal.com
(intending to type www.paypal.com), the ISP will serve that user a
spoofed DNS reply that points the user at an ad server run by the ISP.
This ISP ad server will receive cookies intended for the domain in
question, can set cookies for the domain in question, and is now within
the security perimeter of the domain owner without the owner’s
permission. As a result, security features within the intended site
may no longer work properly, and the consumer’s security is
jeopardized. In the worst-case scenario, bad actors could use this
technique to generate a spoofed reply pointing to a fake site intended
to mimic the actual PayPal site. Consumers using an ordinary internet
connection have no mechanism for determining that this response was
spoofed. DNSSEC is currently the only security technology that would
reveal to the typical consumer that the response was spoofed, and allow
the consumer to make an informed choice about this illegitimate
behavior by the ISP.
The Value of DNSSEC
DNSSEC
and root zone signing solve several critical security problems and
provide the basis for new developments in the secure delivery of
information, such as signed security policies, secure SPF policy
delivery, and the secure delivery of information such as that contained
in DNS SRV records. No other alternative for providing the secure
delivery of this information is on the horizon. Kaminsky’s work on
exposing new exploits against previously known structural weaknesses in
the DNS protocols has increased the pressure and need for DNS
authentication. While theoretically, there might be better technical
solutions than DNSSEC, we do not believe that there is enough time to
contemplate development of an alternative protocol to DNSSEC, which
currently represents the only viable option for the secure delivery of
this type of information.
The main hurdles to overcome are
those related to responsibility and authority for management of the
root zone signing keys and the signing itself. In this matter we
believe there are short term and long term considerations.
In
the short term we believe that getting the root zone signed, even under
the auspices of a single root signing authority, is preferable to
waiting for consensus to emerge about per-country or M-of-N signature
proposals. While we recognize that single authority systems may not be
as robust in the face of certain types of attacks, and could be
vulnerable to political pressure, we believe that these issues should
be decoupled from the implementation timeframe for initial signing of
the root zone. A single authority should sign the root zone as soon as
possible. We believe that there is now limited time before usable
brute force attacks are available to criminals, and therefore rapid
deployment of DNSSEC is the only viable solution.
Based on
currently submitted proposals we believe that IANA or ICANN should be
given the authority and responsibility for implementing the initial
root zone signing. Of the choices presented in the Notice of Inquiry,
Proposed Process Flow #4 would accomplish this, though there are other
options for achieving this result. Given the current role of ICANN in
governance, and of IANA (as administered by ICANN) in root zone
maintenance, this would be the natural choice for the authority and
responsibility for root zone signing. However, we do have operational
concerns related to security practices of whoever is chosen. On this
issue, we urge NTIA to seek expert guidance from organizations (such as
root Certification Authorities) that have experience in handling the
type of sensitive materials involved in these operations.
Longer
term, we believe that some form of M-of-N or simple multiple signing
authorities approaches should be explored. Vesting control of root
zone signing in one entity is too tempting an attack target and too
subject to political pressure from a single government or entity.
Ultimately end-user and DNS infrastructure software will be the main
consumers of DNSSEC data. Just like the current situation in web
browsers, where a list of Root CA Certificates is deployed, we expect a
similar model will be necessary for DNSSEC. Given the already existing
software infrastructure and ecosystem for allowing multiple Root CA
certificates in end-user software, we believe M-of-N, or at the very
least multiple signatures on the root zone or other TLDs, is in
practice workable. We recommend that this option be further developed,
but we do not think it would be prudent to wait until it is fully
developed before signing the root using DNSSEC.
Finally, I
would like to publicly recognize the significant contribution of Andy
Steingruebl, Principal Information Security Engineer in the PayPal
Information Security team, in helping form our opinion. He facilitated
my team in coming to a consensus on this difficult issue, and performed
extensive analysis of the various options presented in the Notice of
Inquiry.
PayPal appreciates the opportunity to provide comments.
We would be glad to provide further information on this topic and look
forward to working with NTIA in closing the existing vulnerabilities of
the DNS through prompt adoption of DNSSEC.
Respectfully submitted,
Michael Barrett
Chief Information Security Officer, PayPal