Following is the amendments proposal of copilot:
If ICANN ever wanted to seriously tackle the “one domain is abusive, ten siblings are untouched” problem, the RAA would need a structural upgrade, not just a cosmetic tweak. What you’re proposing — mandatory associated‑domain checks once a domain is verified
abusive — is exactly the kind of systemic fix that would close the biggest operational blind spot in today’s DNS abuse framework.
Let me give you a clean, actionable blueprint for how such an amendment could be drafted so that it’s enforceable, proportionate, and technically realistic.
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🔧 How to Amend the RAA to Require Associated‑Domain Checks
Below is a structured proposal that fits the style and enforceability pattern of the 2023–2024 amendments.
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1️⃣ Add a New Defined Term: “Associated Domain Name”
This is essential. Without a definition, ICANN Compliance cannot enforce anything.
Proposed definition
> Associated Domain Name means a domain name under the Registrar’s sponsorship that shares one or more operational or registration attributes with a Verified Abusive Domain, including but not limited to:
> (a) identical or substantially similar registrant data;
> (b) identical or substantially similar nameservers;
> (c) identical hosting IP addresses;
> (d) identical DNS configuration patterns;
> (e) identical or substantially similar contact information provided via privacy/proxy services.
This definition is intentionally broad but bounded — similar to how “reasonable and appropriate action” was framed.
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2️⃣ Add a New Registrar Obligation: “Associated Domain Review Requirement”
Proposed RAA clause
> Upon verification that a domain name is engaged in DNS Abuse (“Verified Abusive Domain”), Registrar shall conduct an Associated Domain Review to identify any Associated Domain Names under its sponsorship that present a reasonable likelihood of facilitating
the same or related abusive activity.
This creates a triggered obligation — not continuous surveillance.
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3️⃣ Require Documented Review + Action on Associated Domains
Proposed clause
> Registrar shall document the results of the Associated Domain Review and, where evidence indicates that an Associated Domain Name is engaged in or facilitating DNS Abuse, Registrar shall take reasonable and appropriate action consistent with Section 3.18.
This ties the new requirement back to the existing enforcement mechanism.
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4️⃣ Add a Timeframe (ICANN loves timeframes)
Proposed clause
> The Associated Domain Review shall be completed within 72 hours of verification of DNS Abuse, unless exceptional circumstances justify a longer period.
This mirrors the “timely action” language in the amendments but makes it measurable.
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5️⃣ Add a Minimal‑Burden Safe Harbor
Registrars will fight this unless you give them a safety valve.
Proposed clause
> Registrar shall not be required to perform technical analysis beyond data reasonably available to it in the ordinary course of business. Nothing in this section obligates Registrar to perform active monitoring of domain names.
This keeps the requirement proportional and enforceable.
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6️⃣ Add ICANN Compliance Hooks
Proposed clause
> Registrar shall retain documentation of Associated Domain Reviews for no less than two years and shall provide such documentation to ICANN Compliance upon request.
This makes the obligation auditable.
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🧠 Why This Amendment Works
✔ It’s operationally realistic
Registrars already have access to the necessary data: WHOIS, RDAP, DNS config, hosting IPs.
✔ It targets abuse clusters, not single domains
This is where the real harm reduction happens.
✔ It avoids requiring proactive monitoring
ICANN has historically refused to mandate proactive surveillance; this stays within precedent.
✔ It is enforceable
Clear definitions + clear triggers + clear documentation = ICANN Compliance can act.
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🧩 Optional Add‑Ons (if you want to go further)
- Require registrars to suspend newly registered domains that match the abusive pattern until manual review.
- Require registrars to share associated‑domain findings with registries or trusted notifiers.
- Require registrars to publish transparency reports on associated-domain actions.
These would be more controversial but would dramatically reduce abuse at scale.
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(we should seriously take it into account)
ΜΕΓΓΟΥΔΗΣ Ναούμ
Αστυνόμος Α'
Διεύθυνση Δίωξης Κυβερνοεγκλήματος
Τμήμα Διαδικτυακής Προστασίας Ανηλίκων
MENGOUDIS Naoum
Police Major
Cyber Crime Directorate
Online Child Protection Department
T: (+30) 2106476475
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