Tel: 314-889-1100
Fax: 314-889-1101
www.bdo.com

101 S Hanley Rd, #800
St. Louis, MO 63105

REPORT OF THE INDEPENDENT ACCOUNTANT
To the management of Amazon Trust Services, LLC (“ATS”):
We have examined ATS management’s assertion that for its Certification Authority (“CA”)
operations in various locations in the United States of America, throughout the period January
16, 2019 to January 15, 2020 for its CAs enumerated in Attachment B, ATS has:•disclosed its business, key lifecycle management, certificate lifecycle management, andCA environment control practices in the applicable versions of its Certification PracticeStatement and Certificate Policy enumerated in Attachment A•

maintained effective controls to provide reasonable assurance that:o ATS’ Certification Practice Statement is consistent with its Certificate Policy; ando ATS provides its services in accordance with its Certificate Policy and Certification
Practice Statement•

maintained effective controls to provide reasonable assurance that:o the integrity of keys and certificates it manages is established and protected
throughout their lifecycles;o the integrity of subscriber keys and certificates it manages is established andprotected throughout their lifecycles;
o subscriber information is properly authenticated; ando subordinate CA certificate requests are accurate, authenticated, and approved•maintained effective controls to provide reasonable assurance that:o logical and physical access to CA systems and data is restricted to authorizedindividuals;o the continuity of key and certificate management operations is maintained; ando CA systems development, maintenance, and operations are properly authorized
and performed to maintain CA systems integrity

based on the WebTrust Principles and Criteria for Certification Authorities v2.1. ATS managementis responsible for its assertion. Our responsibility is to express an opinion on management’s
assertion, based on our examination.
The relative effectiveness and significance of specific controls at ATS and their effect on
assessments of control risk for subscribers and relying parties are dependent on their interaction
with the controls, and other factors present at individual subscriber and relying party locations.
Our examination did not extend to controls at individual subscriber and relying party locations
and we have not evaluated the effectiveness of such controls.
ATS does not escrow CA keys, does not provide certificate suspension services, and does notprovide the subscriber key lifecycle management services. Accordingly, our examination did notextend to controls that would address those criteria.

BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of theinternational BDO network of independent member firms.
BDO is the brand name for the BDO network and for each of the BDO Member Firms.

Our examination was conducted in accordance with attestation standards established by theAmerican Institute of Certified Public Accountants. Those standards require that we plan andperform the examination to obtain reasonable assurance about whether management’s assertionis fairly stated, in all material respects. An examination involves performing procedures to obtainevidence about management’s assertion. The nature, timing, and extent of the procedures
selected depend on our judgment, including an assessment of the risks of material misstatementof management’s assertion, whether due to fraud or error. We believe that the evidence weobtained is sufficient and appropriate to provide a reasonable basis for our opinion.
Because of the nature and inherent limitations of controls, ATS’ ability to meet theaforementioned criteria may be affected. For example, controls may not prevent, or detect andcorrect, error, fraud, unauthorized access to systems and information, or failure to comply withinternal and external policies or requirements. Also, the projection of any conclusions based on
our findings to future periods is subject to the risk that changes may alter the validity of suchconclusions.
In our opinion management’s assertion, as referred to above, is fairly stated, in all material
respects.
Without modifying our opinion, we noted the following other matter during our procedures:

1

Matter Topic

Matter Description

Certificate Content

ATS disclosed in Mozilla Bug 1574594 three (3) test
revoked certificates were issued without populating theSubject Alternative Name.

This report does not include any representation as to the quality of ATS’ services other than its
CA operations in various locations in the United States of America, nor the suitability of any ofATS’ services for any customer's intended purpose.
The World Health Organization classified the COVID-19 outbreak as a pandemic in March 2020.
Based on the rapid increase in exposure globally, the gravity or length of the impact of theCOVID-19 outbreak cannot be determined at this time.
ATS’ use of the WebTrust for Certification Authorities Seal constitutes a symbolic representationof the contents of this report and it is not intended, nor should it be construed, to update thisreport or provide any additional assurance.

April 8, 2020

2

ATTACHMENT A – CERTIFICATION PRACTICE STATEMENT AND CERTIFICATEPOLICY VERSIONS IN-SCOPE
Policy Name
Amazon Trust Services Certification Practice Statement

Version
1.0.8

Effective Date
December 17, 2019

Amazon Trust Services Certification Practice Statement

1.0.7

April 13, 2018

Amazon Trust Services Certificate Policy

1.0.7

December 18, 2019

Amazon Trust Services Certificate Policy

1.0.6

April 13, 20183ATTACHMENT B – IN-SCOPE CAs
Root CA Subject DN

SHA2 Thumbprint

SPKI SHA256

Valid To

8ECDE6884F3D87B1125BA31AC3FCB13D7016DE7F57CC904FE1CB97C6AE98196E

FBE3018031F9586BCBF417
27E417B7D1C45C2F47F93B
E372A17B96B50757D5A25/25/2015

1/16/2038

CN = Amazon Root CA 2
O = AmazonC = US

1BA5B2AA8C65401A82960118F80BEC4F62304D83CEC4713A19C39C011EA46DB47F4296FC5B6A4E3B35D3C369623E364AB1AF381D8FA7121533C9D6C633EA2461

5/25/2015

5/25/2040

CN = Amazon Root CA 3
O = Amazon
C = US

18CE6CFE7BF14E60B2E347B8DFE868CB31D02EBB3ADA271569F50343B46DB3A436ABC32656ACFC645C61B71613C4BF21C787F5CABBEE
48348D58597803D7ABC95/25/2015

5/25/2040

CN = Amazon Root CA 4
O = Amazon
C = US

E35D28419ED02025CFA69038CD623962458DA5C695FBDEA3C22B0BFB25897092

F7ECDED5C66047D28ED64
66B543C40E0743ABE81D109254DCF845D4C2C7853C55/25/2015

5/25/2040

CN = Starfield Services
Root Certificate
Authority - G2 1
O = Starfield
Technologies, Inc.
L = Scottsdale
S = Arizona
C = US

568D6905A2C88708A4B3025190EDCFEDB1974A606A13C6E5290FCB2AE63EDAB5

2B071C59A0A0AE76B0EAD
B2BAD23BAD4580B69C360
1B630C2EAF0613AFA83F92

8/31/200912/31/2037

Cross-Signed Root CA
Subject DN

CN = Amazon Root CA 1
O = Amazon
C = USSHA2 Thumbprint

SPKI SHA256

87DCD4DC74640A322CD205552506D1BE64F12596258096544986B4850BC72706

FBE3018031F9586BCBF417
27E417B7D1C45C2F47F93B
E372A17B96B50757D5A2391220705B75BCF3ED3CD4B3631213F569D2CF8226101E170799A5354AB12861

CN = Amazon Root CA 2
O = Amazon
C = US

1

Valid From

CN = Amazon Root CA 1
O = Amazon
C = US

8B358466D66126312120645A5875A6A57E3C81D98476A967604244254EAC00F0

7F4296FC5B6A4E3B35D3C369623E364AB1AF381D8FA7121533C9D6C633EA2461

Valid From

Valid To

5/25/201512/31/2037

10/21/2015

12/31/20375/25/2015

12/31/2037

ATS assumed operation of this Root CA on June 10, 2015. Starfield Technologies operated this CA prior to June 10, 2015 and was responsible for its key generation.

4Cross-Signed Root CA
Subject DN

SHA2 Thumbprint

SPKI SHA256

CN = Amazon Root CA 3
O = Amazon
C = US

40C826FDB22BA32A2F9DB4F94770F72B8B1DA9C8FFDA7B11E6F27AF245C89B5E

36ABC32656ACFC645C61B71613C4BF21C787F5CABBEE
48348D58597803D7ABC9

5/25/201512/31/2037

CN = Amazon Root CA 4
O = Amazon
C = US

543D9B7FC2A6471CD84FCA52C2CF6159DF83EBFCD88D8B08B5AF3F88737F52E6F7ECDED5C66047D28ED6466B543C40E0743ABE81D109254DCF845D4C2C7853C55/25/2015

12/31/2037

SHA2 Thumbprint

SPKI SHA256

DFCC775C644DB4A33AD71293433F463C8E31057CE22CB267F9D31A0353F4FC2F

B58539ECAA13921CCDB80
D38D34875FDE6471C5A159
D9BEEF2FA6F99983BD611

10/21/2015

10/18/2025

39C763A9CF19D923F977D23626AB890449A444AB8B795C815EF1EF81FEBC1E3864BB5BD80311FA3F53BD99404CAB8762AD6E048447D0A97F219FCECA1661F37C

10/21/2015

10/18/202572130E3B28900349214617F4D6F3FB85D08475EE78BF095C59458A14D1828866

1BDA5AFFF83781380BF708
198F9F7D2DB1E067F14BB9
EA7BAE70AAC0B0305E7B

10/21/2015

10/18/2025

205154B777EDC55A5146585A5E54E054A70BE4AAD3B85D02318DA27BF807ADF17C53B5DF79135D9AF6195E
F6BB73AB98C2C89950B892
B192DFFD784DB925A41C

10/21/2015

10/18/2025

7BED29276ACBED9F176F38BBA3A67CE5815B5CBF1522C7BB59ECD86B09E16ED2

17708DFF2B7FAEC9CB1B52
15EBB2421D97B0543C936F
AC9D6E02B92F20E5C707

10/21/2015

10/18/2025

Intermediate CA
Subject DN

CN = Amazon
OU = Server CA 0A
O = Amazon
C = US
CN = Amazon
OU = Server CA 1A
O = Amazon
C = US
CN = Amazon
OU = Server CA 2A
O = Amazon
C = US
CN = Amazon
OU = Server CA 3A
O = Amazon
C = US
CN = Amazon
OU = Server CA 4A
O = Amazon
C = US

5

Valid From

Valid From

Valid To

Valid To

AMAZON TRUST SERVICES, LLC MANAGEMENT’S ASSERTION
Amazon Trust Services, LLC (“ATS”) operates the Certification Authority (“CA”) services for theCAs enumerated in Attachment B, and provides the following CA services:••••••••

Subscriber registration
Certificate renewal
Certificate rekey
Certificate issuance
Certificate distribution
Certificate revocation
Certificate validation
Subordinate CA certification

The management of ATS is responsible for establishing and maintaining effective controls over its
CA operations, including its CA business practices disclosure on its repository, CA businesspractices management, CA environmental controls, CA key lifecycle management controls,
certificate lifecycle management controls, and subordinate CA certificate lifecycle management
controls. These controls contain monitoring mechanisms, and actions are taken to correct
deficiencies identified.
There are inherent limitations in any controls, including the possibility of human error, and thecircumvention or overriding of controls. Accordingly, even effective controls can only provide
reasonable assurance with respect to ATS’ Certification Authority operations. Furthermore,because of changes in conditions, the effectiveness of controls may vary over time.
ATS management has assessed its disclosures of its certificate practices and controls over its CA
services. Based on that assessment, in ATS management’s opinion, in providing its CA services inthe United States of America, throughout the period January 16, 2019 to January 15, 2020, ATS
has:•disclosed its business, key lifecycle management, certificate lifecycle management, andCA environment control practices in the applicable versions of its Certification PracticeStatement and Certificate Policy enumerated in Attachment A•

maintained effective controls to provide reasonable assurance that:o ATS’ Certification Practice Statement is consistent with its Certificate Policy; ando ATS provides its services in accordance with its Certificate Policy and Certification
Practice Statement•maintained effective controls to provide reasonable assurance that:o the integrity of keys and certificates it manages is established and protected
throughout their lifecycles;o the integrity of subscriber keys and certificates it manages is established andprotected throughout their lifecycles;
o subscriber information is properly authenticated; ando subordinate CA certificate requests are accurate, authenticated, and approved•maintained effective controls to provide reasonable assurance that:o logical and physical access to CA systems and data is restricted to authorizedindividuals;o the continuity of key and certificate management operations is maintained; ando CA systems development, maintenance, and operations are properly authorized
and performed to maintain CA systems integrity

based on the WebTrust Principles and Criteria for Certification Authorities v2.1, including thefollowing:
CA Business Practices Disclosure••

Certification Practice Statement (CPS)
Certificate Policy (CP)CA Business Practices Management•••

Certification Practice Statement (CPS) Management
Certificate Policy (CP) Management
CP and CPS Consistency

CA Environmental Controls••••••••••

Security Management
Asset Classification and Management
Personnel Security
Physical and Environmental SecurityOperations Management
System Access Management
System Development, Maintenance, and Change Management
Disaster Recovery, Backups, and Business Continuity Management
Monitoring and Compliance
Audit Logging

CA Key Lifecycle Management Controls
•
•••
•••
•
••

CA Key Generation
CA Key Storage, Backup, and Recovery
CA Public Key Distribution
CA Key Usage
CA Key Archival
CA Key Destruction
CA Key Compromise
CA Cryptographic Hardware Life Cycle Management
CA Key Transportation
CA Key Migration

Certificate Lifecycle Management Controls•••••••

Subscriber Registration
Certificate Renewal
Certificate Rekey
Certificate Issuance
Certificate Distribution
Certificate RevocationCertificate Validation

Subordinate CA and Cross Certificate Lifecycle Management Controls•Subordinate CA Certificate and Cross Certificate Lifecycle Management

ATS does not escrow CA keys, does not provide certificate suspension services, and does notprovide subscriber key lifecycle management services. Accordingly, our assertion does not extend
to controls that would address those criteria.
ATS did not delegate subscriber information authentication to any third parties. ATS maintainedcontrols over subscriber information authentication for all certificates issued.

Jonathan Kozolchyk_____________________________________________________
Jonathan Kozolchyk
Vice President
Amazon Trust Services LLC
April 8, 2020

ATTACHMENT A – CERTIFICATION PRACTICE STATEMENT AND CERTIFICATEPOLICY VERSIONS IN-SCOPE
Policy Name
Amazon Trust Services Certification Practice Statement

Version
1.0.8

Effective Date
December 17, 2019

Amazon Trust Services Certification Practice Statement

1.0.7

April 13, 2018

Amazon Trust Services Certificate Policy

1.0.7

December 18, 2019

Amazon Trust Services Certificate Policy

1.0.6

April 13, 2018

ATTACHMENT B – IN-SCOPE CAsRoot CA Subject DN

SHA2 Thumbprint

SPKI SHA256

Valid To

8ECDE6884F3D87B1125BA31AC3FCB13D7016DE7F57CC904FE1CB97C6AE98196E

FBE3018031F9586BCBF417
27E417B7D1C45C2F47F93B
E372A17B96B50757D5A2

5/25/2015

1/16/2038

CN = Amazon Root CA 2
O = Amazon
C = US

1BA5B2AA8C65401A82960118F80BEC4F62304D83CEC4713A19C39C011EA46DB4

7F4296FC5B6A4E3B35D3C369623E364AB1AF381D8FA7121533C9D6C633EA2461

5/25/2015

5/25/2040

CN = Amazon Root CA 3
O = Amazon
C = US

18CE6CFE7BF14E60B2E347B8DFE868CB31D02EBB3ADA271569F50343B46DB3A436ABC32656ACFC645C61B7
1613C4BF21C787F5CABBEE
48348D58597803D7ABC95/25/2015

5/25/2040

CN = Amazon Root CA 4
O = Amazon
C = US

E35D28419ED02025CFA69038CD623962458DA5C695FBDEA3C22B0BFB25897092

F7ECDED5C66047D28ED6466B543C40E0743ABE81D109254DCF845D4C2C7853C55/25/2015

5/25/2040

CN = Starfield Services
Root Certificate
Authority - G2 1
O = Starfield
Technologies, Inc.
L = Scottsdale
S = Arizona
C = US

568D6905A2C88708A4B3025190EDCFEDB1974A606A13C6E5290FCB2AE63EDAB5

2B071C59A0A0AE76B0EAD
B2BAD23BAD4580B69C360
1B630C2EAF0613AFA83F92

8/31/200912/31/2037

SHA2 Thumbprint

SPKI SHA256

Cross-Signed Root CA
Subject DN

CN = Amazon Root CA 1
O = Amazon
C = US

87DCD4DC74640A322CD205552506D1BE64F12596258096544986B4850BC72706

FBE3018031F9586BCBF417
27E417B7D1C45C2F47F93B
E372A17B96B50757D5A2391220705B75BCF3ED3CD4B3631213F569D2CF8226101E170799A5354AB12861

1

Valid From

CN = Amazon Root CA 1
O = Amazon
C = US

Valid FromValid To

5/25/201512/31/2037

10/21/2015

12/31/2037

CN = Amazon Root CA 2
O = Amazon
C = US

8B358466D66126312120645A5875A6A57E3C81D98476A967604244254EAC00F07F4296FC5B6A4E3B35D3C369623E364AB1AF381D8FA7121533C9D6C633EA2461

5/25/201512/31/2037

CN = Amazon Root CA 3
O = Amazon
C = US

40C826FDB22BA32A2F9DB4F94770F72B8B1DA9C8FFDA7B11E6F27AF245C89B5E

36ABC32656ACFC645C61B71613C4BF21C787F5CABBEE
48348D58597803D7ABC95/25/2015

12/31/2037

ATS assumed operation of this Root CA on June 10, 2015. Starfield Technologies operated this CA prior to June 10, 2015 and was responsible for its key generation.

Cross-Signed Root CA
Subject DN

CN = Amazon Root CA 4
O = Amazon
C = USIntermediate CA
Subject DN

CN = Amazon
OU = Server CA 0A
O = Amazon
C = US
CN = Amazon
OU = Server CA 1A
O = Amazon
C = US
CN = Amazon
OU = Server CA 2A
O = Amazon
C = US
CN = Amazon
OU = Server CA 3A
O = Amazon
C = US
CN = Amazon
OU = Server CA 4A
O = Amazon
C = USSHA2 Thumbprint

SPKI SHA256

Valid From

543D9B7FC2A6471CD84FCA52C2CF6159DF83EBFCD88D8B08B5AF3F88737F52E6F7ECDED5C66047D28ED6466B543C40E0743ABE81D109254DCF845D4C2C7853C5SHA2 Thumbprint

SPKI SHA256

DFCC775C644DB4A33AD71293433F463C8E31057CE22CB267F9D31A0353F4FC2F

B58539ECAA13921CCDB80
D38D34875FDE6471C5A159
D9BEEF2FA6F99983BD611

10/21/2015

10/18/2025

39C763A9CF19D923F977D23626AB890449A444AB8B795C815EF1EF81FEBC1E3864BB5BD80311FA3F53BD99404CAB8762AD6E048447D0A97F219FCECA1661F37C

10/21/2015

10/18/2025

72130E3B28900349214617F4D6F3FB85D08475EE78BF095C59458A14D1828866

1BDA5AFFF83781380BF708
198F9F7D2DB1E067F14BB9
EA7BAE70AAC0B0305E7B

10/21/2015

10/18/2025

205154B777EDC55A5146585A5E54E054A70BE4AAD3B85D02318DA27BF807ADF17C53B5DF79135D9AF6195E
F6BB73AB98C2C89950B892
B192DFFD784DB925A41C

10/21/2015

10/18/2025

7BED29276ACBED9F176F38BBA3A67CE5815B5CBF1522C7BB59ECD86B09E16ED217708DFF2B7FAEC9CB1B52
15EBB2421D97B0543C936F
AC9D6E02B92F20E5C707

10/21/2015

10/18/2025

5/25/2015

Valid From

Valid To
12/31/2037

Valid To