Dear Greg Dear All, Thank you very much amending the Note as submitted I have already requested Steve to kindly prepare a draft "Stress Test" to address the subject matter . Regards Kavouss On Wed, Oct 4, 2017 at 8:33 AM, Greg Shatan <gregshatanipc@gmail.com> wrote:
All:
Here are the agenda and documents for our upcoming call at 1300-1430 UTC today.
1. Agenda 2. Proposed Final OFAC Recommendation (Second Reading) 3. OFAC Recommendation with Proposed Changes 4. Choice of Law and Venue Recommendation
Based on discussions on last week's call and on the list, it seems clear that the proposed changes in document 3 did not get sufficient traction to be included in the Final OFAC Recommendation, which remains unchanged from last week, including the two small additions to the final paragraph that were discussed on that call.
If approved by the Subgroup, the OFAC Recommendation would be delivered to the Plenary, with the following note in the email:
*During the preparation of this 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 a "stress tests" based on these scenarios.*
I look forward to our call.
Greg
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