All,

I am pleased to submit the Draft Report from the Jurisdiction Subgroup for consideration by the CCWG-Accountability Plenary.

It is my understanding that a minority viewpoint is expected to be submitted.  In the interests of time, this will be submitted to the Plenary separately from the Draft Report.

During the preparation of the OFAC Recommendation, the Subgroup considered an email where a registrar declined to do business with a potential reseller, based on the registrar’s policy of not doing business with people with Iranian passports.  The Subgroup also learned that this registrar, which had been registering domains for a number of Iranian nationals, refused to continue to do business with them.  The Subgroup has concluded that, to the extent these instances are related to OFAC, the concerns raised by these instances are adequately covered in the Recommendation already without any additional changes.  This is not in any way a comment on the validity of these particular concerns.  The Subgroup will consider creating "stress tests" based on these scenarios.

I look forward to the Plenary's reading of the Draft Report.

Best regards,

Greg Shatan

Rapporteur