Let's Encrypt bans certificate usage in any US sanctioned territory [pdf]
Posted by piskov 1 day ago
Comments
Comment by CobrastanJorji 11 hours ago
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.
Comment by jaas 6 hours ago
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.
Comment by notamario 6 hours ago
Comment by jaas 5 hours ago
Comment by marcus_holmes 4 hours ago
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...
Comment by BLKNSLVR 1 hour ago
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...
Comment by bawolff 3 hours ago
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.
Comment by marcus_holmes 1 hour ago
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.
Comment by JuniperMesos 3 hours ago
Comment by fc417fc802 2 hours ago
Comment by FireBeyond 2 hours ago
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.
Comment by loloquwowndueo 7 hours ago
Comment by rzerowan 10 hours ago
Comment by thayne 1 hour ago
Comment by PalmPilotProMax 1 hour ago
Comment by xxpor 9 hours ago
Comment by mschuster91 7 hours ago
Comment by xxpor 4 hours ago
Comment by dsl 8 hours ago
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.
Comment by greyface- 7 hours ago
Comment by 10000truths 6 hours ago
Comment by greyface- 6 hours ago
Comment by thayne 1 hour ago
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.
Comment by amluto 46 minutes ago
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.
Comment by tbrownaw 5 hours ago
Comment by bigiain 5 hours ago
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...)
Comment by tolciho 3 hours ago
OpenBSD being based in Canada ships strong crypto, but has had a sometimes troubled relationship with certain regimes.
Comment by dd8601fn 31 minutes ago
Comment by greyface- 5 hours ago
Comment by golem14 6 minutes ago
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?
Comment by wodenokoto 5 hours ago
If complying with the law gets in the way of the mission I’m not sure that counts as a change to the mission.
Comment by Supermancho 3 hours ago
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.
Comment by wodenokoto 2 hours ago
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.
Comment by __s 4 hours ago
tattoo yourself with crypto code to become munitions
Comment by bhhaskin 8 hours ago
Comment by lxgr 7 hours ago
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.
Comment by firefax 7 hours ago
Comment by jcranmer 6 hours ago
Comment by gopher_space 4 hours ago
Let me introduce you to the phrase "I don't see a mechanism."
Comment by firefax 4 hours ago
I'm not familiar with this phrase, but I think I did a good job citing a comparable example in my original post.
Comment by throwaway85825 9 hours ago
Comment by Izmaki 8 hours ago
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.
Comment by firefax 7 hours ago
Comment by idoubtit 22 hours ago
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.
Comment by cassianoleal 21 hours ago
Comment by cromka 21 hours ago
Comment by mikeyouse 12 hours ago
> "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.
Comment by pclmulqdq 8 hours ago
Comment by Tangurena2 7 hours ago
Comment by naturalmovement 12 hours ago
Comment by rafram 12 hours ago
Comment by marcosdumay 7 hours ago
Or rather, when other countries say "sanctions", they are almost always talking about something completely different than the United States.
Comment by cassianoleal 10 hours ago
It’s a bit like the US arresting your mom at home in Texas because you ate a baggie of magic truffles in Amsterdam.
Comment by rafram 10 hours ago
Comment by cassianoleal 8 hours ago
Comment by cromka 9 hours ago
Comment by drstewart 6 hours ago
Comment by kube-system 9 hours ago
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.
Comment by cassianoleal 8 hours ago
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.
Comment by kube-system 8 hours ago
Comment by lmm 6 hours ago
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)
Comment by kube-system 6 hours ago
> 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.
Comment by lmm 6 hours ago
Comment by kube-system 6 hours ago
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.
Comment by lmm 4 hours ago
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.
Comment by kube-system 4 hours ago
Comment by lmm 1 hour ago
Comment by cassianoleal 7 hours ago
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.
Comment by kube-system 6 hours ago
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.
Comment by trumpdong 4 hours ago
Comment by trumpdong 4 hours ago
Comment by mfuzzey 10 hours ago
Comment by kube-system 9 hours ago
e.g. https://www.consilium.europa.eu/en/policies/sanctions-agains...
Comment by nozzlegear 1 hour ago
Comment by drstewart 6 hours ago
Comment by throw-the-towel 7 hours ago
Comment by hparadiz 7 hours ago
Comment by eqvinox 5 hours ago
Comment by hparadiz 5 hours ago
Comment by eqvinox 1 hour ago
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.
Comment by vova_hn2 5 hours ago
Comment by hparadiz 5 hours ago
Comment by vova_hn2 5 hours ago
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
Comment by nozzlegear 1 hour ago
Comment by throw-the-towel 6 hours ago
Comment by belorn 8 hours ago
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.
Comment by PunchyHamster 10 hours ago
Comment by Insimwytim 12 hours ago
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!
Comment by jaas 10 hours ago
The terms of service update to clarify what we have always done, comply with relevant law, has not changed the situation for either country.
Comment by joshuaissac 10 hours ago
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]
Comment by jaas 9 hours ago
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.
Comment by thayne 1 hour ago
Seems to be pretty clear that it would include non-government entities in sanctioned countries.
Comment by lioeters 9 hours ago
Comment by Hundredth0006 9 hours ago
Comment by jaas 3 hours ago
Comment by john_strinlai 9 hours ago
"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.
Comment by joemi 9 hours ago
Still needs updating if it's supposed to only apply to governments, though.
Comment by saeedesmaili 7 hours ago
Comment by gnerd00 11 hours ago
Comment by Dibby053 2 minutes ago
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.
Comment by axiologist 18 hours ago
Comment by belorn 10 hours ago
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.
Comment by hulitu 35 minutes ago
Wasn't Let's encrypt a Mozilla child ?
The real control lies at who defines what is trusted.
Comment by MarleTangible 18 hours ago
Comment by lesostep 9 hours ago
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.
Comment by happosai 10 hours ago
Comment by owl57 3 hours ago
Comment by Parodper 14 hours ago
Comment by theamk 14 hours ago
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)
Comment by toast0 7 hours ago
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.
Comment by trumpdong 4 hours ago
Comment by toast0 1 hour ago
Comment by Parodper 12 hours ago
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.
Comment by theamk 9 hours ago
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.
Comment by trumpdong 4 hours ago
Comment by gopher_space 9 hours ago
There’s no essential difference between the two from my perspective. Why are these my only choices?
Comment by r-w 8 hours ago
Comment by coldtea 7 hours ago
Or so they say. How's that been working out in practice?
Comment by trumpdong 4 hours ago
Comment by Parodper 6 hours ago
Comment by coldtea 6 hours ago
I guess one doing well enough can be oblivious to all this...
Comment by Parodper 6 hours ago
An international body might work, or just move the issue one step back.
Comment by xorcist 6 hours ago
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.
Comment by toast0 1 hour ago
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.
Comment by account42 13 hours ago
Comment by theamk 13 hours ago
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...
Comment by JumpCrisscross 11 hours ago
I didn’t realize the slapped their face on the pavement right after being acquired.
Comment by Fnoord 9 hours ago
In the Dutch hacker scene, Diginotar was a meme. Everyone knew it was a mess there.
Comment by thaumasiotes 12 hours ago
Note that phones already try to prevent you from using a certificate that you provide yourself.
Comment by fluoridation 6 hours ago
Comment by trumpdong 4 hours ago
Comment by account42 13 hours ago
Maybe we should have solve the ISP snooping problem by making that illegal instead.
Comment by theamk 13 hours ago
Comment by cyanydeez 12 hours ago
Comment by lxgr 7 hours ago
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).
Comment by kube-system 9 hours ago
If you want encryption without trust, just use self-signed certs.
Comment by lxgr 7 hours ago
Comment by 13415 8 hours ago
Comment by kube-system 8 hours ago
Comment by 13415 7 hours ago
Comment by kube-system 7 hours ago
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
Comment by palmotea 14 hours ago
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.
Comment by account42 13 hours ago
Comment by franga2000 13 hours ago
Comment by trumpdong 4 hours ago
Comment by Igrom 21 hours ago
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" - pluralComment by trumpdong 4 hours ago
Comment by VortexLain 10 hours ago
Comment by rerdavies 8 hours ago
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.
Comment by fluoridation 6 hours ago
Comment by lmm 6 hours ago
Comment by m2f2 23 hours ago
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?
Comment by tialaramex 10 hours ago
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.
Comment by basilikum 9 hours ago
Looking at LavaBit^1 I really would not be so comfortable. The world and especially the US has not gotten more free since then.
Comment by tialaramex 8 hours ago
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.
Comment by basilikum 8 hours ago
Comment by toast0 7 hours ago
I would like to think at least all the high profile destinations have someone watching.
Comment by tialaramex 8 hours ago
Comment by basilikum 8 hours ago
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
Comment by tialaramex 5 hours ago
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.
Comment by 8organicbits 5 hours ago
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.
Comment by nickf 8 hours ago
Comment by toast0 7 hours ago
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.
Comment by tialaramex 4 hours ago
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.
Comment by rafram 12 hours ago
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https://www.france24.com/en/americas/20250820-us-hits-icc-wi...
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Comment by ygjb 10 hours ago
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).
Comment by daneel_w 10 hours ago
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.
Comment by pratyahava 10 hours ago
Comment by trumpdong 4 hours ago
Comment by mrweasel 10 hours ago
The EU could easily bootstrap a Let's Encrypt competitor if it truly cared about removing dependencies on US based entities.
Comment by zajio1am 9 hours ago
Comment by toast0 7 hours ago
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.
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Comment by em-bee 16 hours ago
LWN has a good writeup on the audit situation as of 2014: https://lwn.net/Articles/590879/
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Comment by pavon 11 hours ago
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.
Comment by ezbie 14 hours ago
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.
Comment by kube-system 8 hours ago
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Comment by xorcist 6 hours ago
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.
Comment by rwmj 7 hours ago
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Comment by bigfishrunning 10 hours ago
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.
Comment by Galanwe 10 hours ago
Maybe because the US dropped most of its anti trust regulations, leading to ridiculously monopolistic practices such as "acquire everything that may be threatening".
Comment by bigfishrunning 10 hours ago
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.
Comment by trumpdong 4 hours ago
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Comment by jldugger 6 hours ago
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.
Comment by guhcampos 5 hours ago
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".
Comment by RyeCombinator 23 hours ago
Comment by gapan 23 hours ago
This is the main reason letsencrypt is so popular.
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Comment by 47282847 23 hours ago
Comment by ZeroSSL 14 hours ago
- 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.
Comment by kruffalon 12 hours ago
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
Comment by hoistbypetard 11 hours ago
There's no reason to believe they're any less subject to US jurisdiction than LetsEncrypt.
Comment by idoubtit 10 hours ago
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.
Comment by redrblackr 11 hours ago
Comment by orochimaaru 11 hours ago
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.
Comment by slau 23 hours ago
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.
Comment by nomadwastaken 21 hours ago
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.
Comment by 47282847 16 hours ago
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Comment by matharmin 11 hours ago
I can't comment on the EU part though - not that relevant in my case.
Comment by linsomniac 12 hours ago
Comment by slau 23 hours ago
That’s a pretty steep increase. I would almost be more interested in a monthly fee per cert.
Comment by nomadwastaken 21 hours ago
> 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.
Comment by matharmin 11 hours ago
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Comment by trumpdong 4 hours ago
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.
Comment by niemandhier 10 hours ago
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.
Comment by trumpdong 4 hours ago
Comment by DoctorOetker 23 hours ago
is this standard MitM, or is it some crucially distinct variation?
Comment by thephyber 22 hours ago
> 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.
Comment by walletdrainer 22 hours ago
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Comment by mmahd7456 11 hours ago
Only to people who have a need to be offended.
Comment by walletdrainer 9 hours ago
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Comment by ComputerGuru 11 hours ago
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.
Comment by Panzerschrek 23 hours ago
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Comment by joemi 9 hours ago
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.
Comment by hinata08 9 hours ago
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
Comment by Fnoord 9 hours ago
No.
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Comment by trumpdong 4 hours ago
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.
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Comment by greatgib 11 hours ago
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
Comment by markhahn 7 hours ago
Comment by diimdeep 18 hours ago
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.
Comment by phoe-krk 18 hours ago
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Comment by jalospinoso 12 hours ago
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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Comment by hinata08 12 hours ago
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
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Comment by hinata08 11 hours ago
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
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Comment by Towaway69 23 hours ago
> 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.
Comment by thephyber 22 hours ago
> [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.
Comment by gossamer 10 hours ago