US Registrars - OFAC Updates
The United States Department of the Treasury, Office of Foreign Asset Control (OFAC) has made a number of updates to the list of Specially Designated Nationals (SDN's) with whom engaging in trade or provisions of services is a federal felony. The SDN list is separate from the country sanction programs also administered by OFAC. Some time ago, OFAC began including specific domain names as SDN's. The first of these was kahane.net, but the list has grown much longer to include entities listed en masse as a single entity such as: WWW.CUBA-ECOTOURISM.COM (a.k.a. GO CUBA PLUS; a.k.a. T&M INTERNATIONAL LTD.; a.k.a. TOUR & MARKETING INTERNATIONAL LTD.; a.k.a. WWW.ABOUTCUBA.COM; a.k.a. WWW.BONJOURCUBA.COM; a.k.a. WWW.CIAOCUBA.COM; a.k.a. WWW.CIGARSSUPERSTORE.COM; a.k.a. WWW.CUBAADVICE.COM; a.k.a. WWW.CUBA-BARACOA.COM; a.k.a. WWW.CUBA- BAYAMO.COM; a.k.a. WWW.CUBA-CAMAGUEY.COM; a.k.a. WWW.CUBA- CAYOCOCO.COM; a.k.a. WWW.CUBA-CAYOGUILLERMO.COM; a.k.a. WWW.CUBA- CAYOLARGO.COM; a.k.a. WWW.CUBA-CAYOLEVISA.COM; a.k.a. WWW.CUBA- CAYOSABINAL.COM; a.k.a. WWW.CUBA-CAYOSAETIA.COM; a.k.a. WWW.CUBA- CAYOSANTAMARIA.COM; a.k.a. WWW.CUBA-CHE.COM; a.k.a. WWW.CUBA- CIEGODEAVILA.COM; a.k.a. WWW.CUBA-CIENFUEGOS.COM; a.k.a. WWW.CUBA- ELGUEA.COM; a.k.a. WWW.CUBAFIRST.COM; a.k.a. WWW.CUBAFUN.COM; a.k.a. WWW.CUBA-GIRON.COM; a.k.a. WWW.CUBA-GRANMA.COM; a.k.a. WWW.CUBA-GUAMA.COM; a.k.a. WWW.CUBA-GUARDALAVACA.COM; a.k.a. WWW.CUBA-HAVANACITY.COM; a.k.a. WWW.CUBA-HEMINGWAY.COM; a.k.a. WWW.CUBA-HOLGUIN.COM; a.k.a. WWW.CUBA-ISLADELAJUVENTUD.COM; a.k.a. WWW.CUBA-JARDINESDELEREY.COM; a.k.a. WWW.CUBA-LAHABANA.COM; a.k.a. WWW.CUBA-LASTUNAS.COM; a.k.a. WWW.CUBA-MATANZAS.COM; a.k.a. WWW.CUBANBASEBALLTRAVEL.COM; a.k.a. WWW.CUBANCULTURE.COM; a.k.a. WWW.CUBA-OLDHAVANA.COM; a.k.a. WWW.CUBAONE.COM; a.k.a. WWW.CUBA- PINARDELRIO.COM; a.k.a. WWW.CUBA-SANCTISPIRITUS.COM; a.k.a. WWW.CUBA-SANTALUCIA.COM; a.k.a. WWW.CUBA-SANTIAGODECUBA.COM; a.k.a. WWW.CUBA-SHOPPING.COM; a.k.a. WWW.CUBA-SOROA.COM; a.k.a. WWW.CUBASPORTS.COM; a.k.a. WWW.CUBA-TOPESDECOLLANTES.COM; a.k.a. WWW.CUBATRAVELDIRECTORY.COM; a.k.a. WWW.CUBA-TRINIDAD.COM; a.k.a. WWW.CUBA-VARADEROBEACH.COM; a.k.a. WWW.CUBA-VILLACLARA.COM; a.k.a. WWW.CUBAVIP.COM; a.k.a. WWW.CUBA-WEATHER.COM; a.k.a. WWW.GOCUBA.COM; a.k.a. WWW.GOCUBA.CU; a.k.a. WWW.GOCUBAPLUS.COM; a.k.a. WWW.IPIXCUBA.COM; a.k.a. WWW.NO.GOCUBAPLUS.COM; a.k.a. WWW.REALESTATECUBA.COM; a.k.a. WWW.TOURANDMARKETING.COM; a.k.a. WWW.VAMOSACUBA.COM), Ellen L. Skelton Building, 4th Floor, Fishers Estate, P.O. Box 3820, Road Town, Tortola, Virgin Islands, British; P.O. Box 24258, London, England SE9 1WS, United Kingdom; Hotel Acuario, Suite 3511, Marina Hemingway, Santa Fe, Playa, Havana, Cuba; Hotel Acuario, Suite 3541, Marina Hemingway, Santa Fe, Playa, Havana, Cuba; Hotel Acuario, Suite 3542, Marina Hemingway, Santa Fe, Playa, Havana, Cuba; Hotel Viejo y el Mar, Suite 6005, Marina Hemingway, Playa, Havana, Cuba; Calle 12 y Mar, Varadero Matanzas, Cuba; Calle Ramon Pino, No. 4, 38650, Los Cristianos, Arona, Tenerife, Spain [CUBA] The full list of SDN's is located here: http://www.treas.gov/offices/enforcement/ofac/sdn/sdnlist.txt John Berryhill, Ph.d., Esq. 4 West Front St. Media, PA 19063 (610) 565-5601 (267) 386-8115 fax
John, It seems unusual that the government would post a list of domains that were obviously registered at a US based registry, and state that it's a federal offense for US companies to provide services to them. Many of those domains are years old, and already listed on numerous search engine and websites too. If the situation was as serious as making it a federal felony, why wouldn't they just get the domains revoked and be done with it? ~Paul :DomainIt At 01:56 AM 10/3/2007, John Berryhill wrote:
The United States Department of the Treasury, Office of Foreign Asset Control (OFAC) has made a number of updates to the list of Specially Designated Nationals (SDN's) with whom engaging in trade or provisions of services is a federal felony. The SDN list is separate from the country sanction programs also administered by OFAC.
Some time ago, OFAC began including specific domain names as SDN's. The first of these was kahane.net, but the list has grown much longer to include entities listed en masse as a single entity such as:
WWW.CUBA-ECOTOURISM.COM (a.k.a. GO CUBA PLUS; a.k.a. T&M INTERNATIONAL LTD.; a.k.a. TOUR & MARKETING INTERNATIONAL LTD.; a.k.a. WWW.ABOUTCUBA.COM; a.k.a. WWW.BONJOURCUBA.COM; a.k.a. WWW.CIAOCUBA.COM; a.k.a. WWW.CIGARSSUPERSTORE.COM; a.k.a. WWW.CUBAADVICE.COM; a.k.a. WWW.CUBA-BARACOA.COM; a.k.a. WWW.CUBA- BAYAMO.COM; a.k.a. WWW.CUBA-CAMAGUEY.COM; a.k.a. WWW.CUBA- CAYOCOCO.COM; a.k.a. WWW.CUBA-CAYOGUILLERMO.COM; a.k.a. WWW.CUBA- CAYOLARGO.COM; a.k.a. WWW.CUBA-CAYOLEVISA.COM; a.k.a. WWW.CUBA- CAYOSABINAL.COM; a.k.a. WWW.CUBA-CAYOSAETIA.COM; a.k.a. WWW.CUBA- CAYOSANTAMARIA.COM; a.k.a. WWW.CUBA-CHE.COM; a.k.a. WWW.CUBA- CIEGODEAVILA.COM; a.k.a. WWW.CUBA-CIENFUEGOS.COM; a.k.a. WWW.CUBA- ELGUEA.COM; a.k.a. WWW.CUBAFIRST.COM; a.k.a. WWW.CUBAFUN.COM; a.k.a. WWW.CUBA-GIRON.COM; a.k.a. WWW.CUBA-GRANMA.COM; a.k.a. WWW.CUBA-GUAMA.COM; a.k.a. WWW.CUBA-GUARDALAVACA.COM; a.k.a. WWW.CUBA-HAVANACITY.COM; a.k.a. WWW.CUBA-HEMINGWAY.COM; a.k.a. WWW.CUBA-HOLGUIN.COM; a.k.a. WWW.CUBA-ISLADELAJUVENTUD.COM; a.k.a. WWW.CUBA-JARDINESDELEREY.COM; a.k.a. WWW.CUBA-LAHABANA.COM; a.k.a. WWW.CUBA-LASTUNAS.COM; a.k.a. WWW.CUBA-MATANZAS.COM; a.k.a. WWW.CUBANBASEBALLTRAVEL.COM; a.k.a. WWW.CUBANCULTURE.COM; a.k.a. WWW.CUBA-OLDHAVANA.COM; a.k.a. WWW.CUBAONE.COM; a.k.a. WWW.CUBA- PINARDELRIO.COM; a.k.a. WWW.CUBA-SANCTISPIRITUS.COM; a.k.a. WWW.CUBA-SANTALUCIA.COM; a.k.a. WWW.CUBA-SANTIAGODECUBA.COM; a.k.a. WWW.CUBA-SHOPPING.COM; a.k.a. WWW.CUBA-SOROA.COM; a.k.a. WWW.CUBASPORTS.COM; a.k.a. WWW.CUBA-TOPESDECOLLANTES.COM; a.k.a. WWW.CUBATRAVELDIRECTORY.COM; a.k.a. WWW.CUBA-TRINIDAD.COM; a.k.a. WWW.CUBA-VARADEROBEACH.COM; a.k.a. WWW.CUBA-VILLACLARA.COM; a.k.a. WWW.CUBAVIP.COM; a.k.a. WWW.CUBA-WEATHER.COM; a.k.a. WWW.GOCUBA.COM; a.k.a. WWW.GOCUBA.CU; a.k.a. WWW.GOCUBAPLUS.COM; a.k.a. WWW.IPIXCUBA.COM; a.k.a. WWW.NO.GOCUBAPLUS.COM; a.k.a. WWW.REALESTATECUBA.COM; a.k.a. WWW.TOURANDMARKETING.COM; a.k.a. WWW.VAMOSACUBA.COM), Ellen L. Skelton Building, 4th Floor, Fishers Estate, P.O. Box 3820, Road Town, Tortola, Virgin Islands, British; P.O. Box 24258, London, England SE9 1WS, United Kingdom; Hotel Acuario, Suite 3511, Marina Hemingway, Santa Fe, Playa, Havana, Cuba; Hotel Acuario, Suite 3541, Marina Hemingway, Santa Fe, Playa, Havana, Cuba; Hotel Acuario, Suite 3542, Marina Hemingway, Santa Fe, Playa, Havana, Cuba; Hotel Viejo y el Mar, Suite 6005, Marina Hemingway, Playa, Havana, Cuba; Calle 12 y Mar, Varadero Matanzas, Cuba; Calle Ramon Pino, No. 4, 38650, Los Cristianos, Arona, Tenerife, Spain [CUBA]
The full list of SDN's is located here:
http://www.treas.gov/offices/enforcement/ofac/sdn/sdnlist.txt
John Berryhill, Ph.d., Esq. 4 West Front St. Media, PA 19063 (610) 565-5601 (267) 386-8115 fax
Would "engaging in trade or provision of service" include being the registrar to such a domain? IE eNom is the registrar of: CUBA-ECOTOURISM.COM, ABOUTCUBA.COM, and others (but the Registrant appears to be in Tortola, not Cuba) For that matter, isn't Verisign ultimately providing service to these domains, so no matter the jurisdiction of the Registrar, the felony problem for any .com domains always involves Verisign? Richard -----Original Message----- From: owner-registrars@gnso.icann.org [mailto:owner-registrars@gnso.icann.org] On Behalf Of Paul Goldstone Sent: 03 October, 2007 7:57 AM To: john@johnberryhill.com Cc: 'Registrars Constituency' Subject: Re: [registrars] US Registrars - OFAC Updates John, It seems unusual that the government would post a list of domains that were obviously registered at a US based registry, and state that it's a federal offense for US companies to provide services to them. Many of those domains are years old, and already listed on numerous search engine and websites too. If the situation was as serious as making it a federal felony, why wouldn't they just get the domains revoked and be done with it? ~Paul :DomainIt At 01:56 AM 10/3/2007, John Berryhill wrote:
The United States Department of the Treasury, Office of Foreign Asset Control (OFAC) has made a number of updates to the list of Specially Designated Nationals (SDN's) with whom engaging in trade or provisions of services is a federal felony. The SDN list is separate from the country sanction programs also administered by OFAC.
Some time ago, OFAC began including specific domain names as SDN's. The first of these was kahane.net, but the list has grown much longer to include entities listed en masse as a single entity such as:
WWW.CUBA-ECOTOURISM.COM (a.k.a. GO CUBA PLUS; a.k.a. T&M INTERNATIONAL LTD.; a.k.a. TOUR & MARKETING INTERNATIONAL LTD.; a.k.a. WWW.ABOUTCUBA.COM; a.k.a. WWW.BONJOURCUBA.COM; a.k.a. WWW.CIAOCUBA.COM; a.k.a. WWW.CIGARSSUPERSTORE.COM; a.k.a. WWW.CUBAADVICE.COM; a.k.a. WWW.CUBA-BARACOA.COM; a.k.a. WWW.CUBA- BAYAMO.COM; a.k.a. WWW.CUBA-CAMAGUEY.COM; a.k.a. WWW.CUBA- CAYOCOCO.COM; a.k.a. WWW.CUBA-CAYOGUILLERMO.COM; a.k.a. WWW.CUBA- CAYOLARGO.COM; a.k.a. WWW.CUBA-CAYOLEVISA.COM; a.k.a. WWW.CUBA- CAYOSABINAL.COM; a.k.a. WWW.CUBA-CAYOSAETIA.COM; a.k.a. WWW.CUBA- CAYOSANTAMARIA.COM; a.k.a. WWW.CUBA-CHE.COM; a.k.a. WWW.CUBA- CIEGODEAVILA.COM; a.k.a. WWW.CUBA-CIENFUEGOS.COM; a.k.a. WWW.CUBA- ELGUEA.COM; a.k.a. WWW.CUBAFIRST.COM; a.k.a. WWW.CUBAFUN.COM; a.k.a. WWW.CUBA-GIRON.COM; a.k.a. WWW.CUBA-GRANMA.COM; a.k.a. WWW.CUBA-GUAMA.COM; a.k.a. WWW.CUBA-GUARDALAVACA.COM; a.k.a. WWW.CUBA-HAVANACITY.COM; a.k.a. WWW.CUBA-HEMINGWAY.COM; a.k.a. WWW.CUBA-HOLGUIN.COM; a.k.a. WWW.CUBA-ISLADELAJUVENTUD.COM; a.k.a. WWW.CUBA-JARDINESDELEREY.COM; a.k.a. WWW.CUBA-LAHABANA.COM; a.k.a. WWW.CUBA-LASTUNAS.COM; a.k.a. WWW.CUBA-MATANZAS.COM; a.k.a. WWW.CUBANBASEBALLTRAVEL.COM; a.k.a. WWW.CUBANCULTURE.COM; a.k.a. WWW.CUBA-OLDHAVANA.COM; a.k.a. WWW.CUBAONE.COM; a.k.a. WWW.CUBA- PINARDELRIO.COM; a.k.a. WWW.CUBA-SANCTISPIRITUS.COM; a.k.a. WWW.CUBA-SANTALUCIA.COM; a.k.a. WWW.CUBA-SANTIAGODECUBA.COM; a.k.a. WWW.CUBA-SHOPPING.COM; a.k.a. WWW.CUBA-SOROA.COM; a.k.a. WWW.CUBASPORTS.COM; a.k.a. WWW.CUBA-TOPESDECOLLANTES.COM; a.k.a. WWW.CUBATRAVELDIRECTORY.COM; a.k.a. WWW.CUBA-TRINIDAD.COM; a.k.a. WWW.CUBA-VARADEROBEACH.COM; a.k.a. WWW.CUBA-VILLACLARA.COM; a.k.a. WWW.CUBAVIP.COM; a.k.a. WWW.CUBA-WEATHER.COM; a.k.a. WWW.GOCUBA.COM; a.k.a. WWW.GOCUBA.CU; a.k.a. WWW.GOCUBAPLUS.COM; a.k.a. WWW.IPIXCUBA.COM; a.k.a. WWW.NO.GOCUBAPLUS.COM; a.k.a. WWW.REALESTATECUBA.COM; a.k.a. WWW.TOURANDMARKETING.COM; a.k.a. WWW.VAMOSACUBA.COM), Ellen L. Skelton Building, 4th Floor, Fishers Estate, P.O. Box 3820, Road Town, Tortola, Virgin Islands, British; P.O. Box 24258, London, England SE9 1WS, United Kingdom; Hotel Acuario, Suite 3511, Marina Hemingway, Santa Fe, Playa, Havana, Cuba; Hotel Acuario, Suite 3541, Marina Hemingway, Santa Fe, Playa, Havana, Cuba; Hotel Acuario, Suite 3542, Marina Hemingway, Santa Fe, Playa, Havana, Cuba; Hotel Viejo y el Mar, Suite 6005, Marina Hemingway, Playa, Havana, Cuba; Calle 12 y Mar, Varadero Matanzas, Cuba; Calle Ramon Pino, No. 4, 38650, Los Cristianos, Arona, Tenerife, Spain [CUBA]
The full list of SDN's is located here:
http://www.treas.gov/offices/enforcement/ofac/sdn/sdnlist.txt
John Berryhill, Ph.d., Esq. 4 West Front St. Media, PA 19063 (610) 565-5601 (267) 386-8115 fax
It seems unusual that the government would post a list of domains that were obviously registered at a US based registry, and state that it's a federal offense for US companies to provide services to them.
On the big list of "unusual things done by the US government", this may rank somewhere down in the triple digits. I suspect the OFAC might possibly make an observation similar to yours in the future, which is why I believed the list might be useful to US registrars before such time. The domain for the "Islamic Army In Iraq" at iasite.net had entered expiration recently, and it appears that the domain name was subject to some interesting maneuvers after that. What is fascinating is that the name servers were restored, so the site continues to operate from its host - in Flushing, New York. One might compare that to, say, the Al-Aqsa Martyrs Brigade, whose registrar apparently allowed renewal of their domain kataebaqsa1.com, but has suspended their nameservers. The continued operation of such sites may reflect a decision to monitor, rather than to stop, such activities. If a US registrar does not have specific reason to believe that its dealings with SDN's are authorized, then it may be worth a run through the list. The relevant regulations and executive orders pretty much authorize the US government to haul away your entire operation with zero notice.
participants (3)
-
John Berryhill -
Paul Goldstone -
Richard Lau