Hello Greg, all

I like to quote 2 sections from our current draft:

"These sanctions have been imposed on certain countries, as well as individuals and entities that appear on OFAC's List of Specially Designated Nationals and Blocked Persons (the "SDN List"). ICANN is prohibited from providing most goods or services to residents of sanctioned countries or their governmental entities or to SDNs without an applicable U.S. government authorization or exemption."

Our recommendation:

"ICANN should commit to applying for and using best efforts to secure an OFAC license for all such applicants if the applicant is otherwise qualified (and is not on the SDN list)"

Please pay attention to the phrases in bracket of both paragraphs. Am i right if I understand this to mean we are actually not asking ICANN to seek exemption for those on the SDN list? (If the response if a Yes then kindly read further below)

If I may, how does our recommendation serve as improvement from the status quo? I mean what category of applicants will start to feel the positive impact of our recommendation?

Regards

Sent from my mobile
Kindly excuse brevity and typos

On Oct 13, 2017 3:29 AM, "Greg Shatan" <gregshatanipc@gmail.com> wrote:

All,

One of the Subgroup members pointed out a minor editing error in the document. On pages 13-14, there were several mentions of the RAA, when in fact the language quoted and discussed was from the ICANN Terms and Conditions for Registrar Accreditation Application. (The reference was correct in the Executive Summary.) This has now been fixed in the attached.

Greg

On Thu, Oct 12, 2017 at 10:10 PM, Greg Shatan <gregshatanipc@gmail.com> wrote:
All,

Some minor formatting errors crept into the Report when it was converted from Word to PDF. A new PDF of the report is attached. I've checked each page to confirm that the formatting errors were resolved.

Thank you to Jorge Cancio for catching this problem!

Greg

On Wed, Oct 11, 2017 at 7:53 PM, Greg Shatan <gregshatanipc@gmail.com> wrote:
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

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