It sounds like the recommendation is indeed an increase in compliance demands, but no funding 
for an automated monitoring tool, and that sounds silly to some. However, often organizations, whether commercial or non, lag behind in developing such tools. 

BUT, this is helpful to our purposes of interacting related to budget, and my draft letter, which I hope to finalize and share with others tomorrow. 
Sorry for delay. 
But, thanks, Ron, for your efforts to keep this a focus...









From: randruff@rnapartners.com
To: zahid@dndrc.com; bc-gnso@icann.org
Subject: RE: [bc-gnso] FW: [council] Response from ICANN Compliance re. RAP recommendations
Date: Thu, 24 Feb 2011 15:32:03 -0500

It’s starting to feel like Alice in Wonderland…  A Working Group spends countless hours debating VI, followed by the Board making its own decision “based on experts” rather than the community.  We are informed that a Code of Conduct will resolve the issues and, not to worry, all the resources necessary for a fully-funded Compliance Department will be made available.  Then the positions for the Head of Compliance plus two other officers remain unfilled for the better part of a year…

 

Now Pam Little’s response to GNSO Council questions is scary (emphasis added):

 

With regard to part “b)” of Recommendation 2, the RAA requires that registrars provide an interactive web page and a port 43 WHOIS access.  As mentioned above, the Compliance department uses an automated tool to monitor registrar port 43 access obligations.   However, the monitoring tool does not monitor web-based WHOIS obligations. Monitoring registrar compliance with web based WHOIS access requires a manual check of each the 970+ registrars’ websites, as the Compliance department currently does not have an automated monitoring tool. 

 

I wonder which compliance officer(s) spends their life on this task?  In reality, not enough.  So, as I now understand it, we will have a set of laws in the new ‘Code of Conduct’ (pdp or staff generated?) that the vertically integrated entities will honorably abide by, left unchecked due to lack of staff and clearly structural issues vis-à-vis how ICANN monitors compliance.

 

My head is spinning…   Is it just me?

 

RA

 

Ronald N. Andruff

RNA Partners, Inc.

 

 


From: owner-bc-gnso@icann.org [mailto:owner-bc-gnso@icann.org] On Behalf Of Zahid Jamil
Sent: Thursday, February 24, 2011 11:44 AM
To: 'Bc GNSO list '
Subject: [bc-gnso] FW: [council] Response from ICANN Compliance re. RAP recommendations

 

 

 

Sincerely,

 

 

Zahid Jamil

Barrister-at-law

Jamil & Jamil

Barristers-at-law

219-221 Central Hotel Annexe

Merewether Road, Karachi. Pakistan

Cell: +923008238230

Tel: +92 21 35680760 / 35685276 / 35655025

Fax: +92 21 35655026

www.jamilandjamil.com

 

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From: owner-council@gnso.icann.org [mailto:owner-council@gnso.icann.org] On Behalf Of Marika Konings
Sent: 23 February 2011 13:48
To: council@gnso.icann.org
Subject: [council] Response from ICANN Compliance re. RAP recommendations

 

Dear All,

 

Please find attached the response from ICANN's Compliance Department in relation to resolved #1 of the recently adopted motion on the Registration Abuse Policies Working Group Final Report (RESOLVED #1, the GNSO Council instructs ICANN Policy Staff to forward the two issues identified by the RAP IDT as having low resource requirements, WHOIS Access recommendation #2 and Fake Renewal Notices recommendation #1, to ICANN Compliance Staff for resolution. ICANN Compliance Staff is requested to provide the GNSO Council with its feedback on the two recommendations and proposed implementation in a timely manner).

 

Pam Little, Interim Head of Contractual Compliance, is not available to participate in the Council meeting coming Thursday, but she is happy to take further comments / questions by email. In addition, she has indicated that she is available to discuss the response and any further questions in person with the Council during the weekend session at the ICANN meeting in San Francisco, if required.

 

With best regards,

 

Marika