Dear Greg

In reply to your invitation to raise question about OFAC ,these are my questions :

  1. When, how and who raised the applicability of OFAC TERMS  with respect to Gtld and CC TLD with ICANN

  2. Did ICANN react on that issue indicating the consequence of eventual application of OFAC terms to DNS, including ccTLDs

  3. What is the relation between gTLD , and  ccTLD, on the one hand and  and OFAC,on the other hand

  4. How OFAC terms and conditions could impact gTLD and ccTLD  

  5. Could OFAC terms prevents the Registry and / or Registrar directly or indirectly not  to enter into discussion or agreement with those countries under OFAC sanction  requesting gTLD

  6. Was the eventual applicability of a given OFAC terms to gTLD and ccTLD

    Included in the agreements with Registries and / or Registrar ,if yes based on what justification and which ICANN Resolutions

  7. In application of given terms of OFAC are there differences between Registries and

    Registrars from USA and Non USA ones

  8. I would appreciate very much to include these questions among those to be answered by Sam supported by an equivalent written document as I did mentioned

  9. Regards

  10. Kavouss

      

   

 









On Sun, Jul 30, 2017 at 10:15 PM, Nigel Roberts <nigel@channelisles.net> wrote:
Dear Greg

Here is my question for Sam    . . .


I don't know if I'll be able to make the call in person, so a written response would also be welcomed, if this is not too much much trouble.

(I am conscious that we not unecessarily incur legal costs.)


"Please provide an overview of the procedures adopted by IANA=PTI to ensure OFAC compliance in respect of ccTLD and gTLD transactions, and how they have changed since IANA was devolved to a separate incorporated body having its own legal personality?"




On 30/07/17 19:27, Greg Shatan wrote:
All,

Please respond to this email thread with any questions you have for
ICANN Legal regarding OFAC or other sanctions-related matters.  As you
know, Sam Eisner of ICANN Legal will be joining us in our call on
Tuesday, August 1 to discuss these topics.

It would be good to provide some of our questions to ICANN Legal in
advance, and for the Subgroup to have an idea of the questions
particular participants have.

I look forward to your responses to this email, which I will pass on to
ICANN Legal.

Best regards,

Greg


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