Let's Encrypt bans certificate usage in any US sanctioned territory [pdf]
https://letsencrypt.org/documents/LE-SA-v1.7-June-04-2026-diff.pdfThat 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.
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.
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.
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.
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.
> "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.
Or rather, when other countries say "sanctions", they are almost always talking about something completely different than the United States.
It’s a bit like the US arresting your mom at home in Texas because you ate a baggie of magic truffles in Amsterdam.
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.
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)
> 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.
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.
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.
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.
e.g. https://www.consilium.europa.eu/en/policies/sanctions-agains...
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.
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!
The terms of service update to clarify what we have always done, comply with relevant law, has not changed the situation for either country.
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.
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.
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)
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.
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.
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.
There’s no essential difference between the two from my perspective. Why are these my only choices?
An international body might work, or just move the issue one step back.
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...
I didn’t realize the slapped their face on the pavement right after being acquired.
In the Dutch hacker scene, Diginotar was a meme. Everyone knew it was a mess there.
Note that phones already try to prevent you from using a certificate that you provide yourself.
Maybe we should have solve the ISP snooping problem by making that illegal instead.
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).
If you want encryption without trust, just use self-signed certs.
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
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.
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
- "[the agreement] will remain in force during the entire period during which *any* of Your Certificates are valid" - plural
- "[by] requesting, accepting, or using *a* Let’s Encrypt Certificate" - pluralLet'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.
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?
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.
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.
The EU could easily bootstrap a Let's Encrypt competitor if it truly cared about removing dependencies on US based entities.
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).
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.
LWN has a good writeup on the audit situation as of 2014: https://lwn.net/Articles/590879/
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.
This is the main reason letsencrypt is so popular.
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.
I can't comment on the EU part though - not that relevant in my case.
That’s a pretty steep increase. I would almost be more interested in a monthly fee per cert.
is this standard MitM, or is it some crucially distinct variation?
> 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.
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.
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
No.
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.
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
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.
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.
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
> 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.
> [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.