Kavouss,

Can you please guide me to the section of the RAA that would prevent such a business decision (i.e., a registrar deciding not to do business with citizens of a given country (whether it is Canada, Haiti, Iran or otherwise)?  

If there is such a provision, this would seem to be a compliance issue.  If there is not such a provision, I don't see how this particular issue comes within the scope of our group, since there is no indication that Resello's decision is triggered by OFAC (or by any non-US sanctions for that matter).

I have briefly reviewed the Resello Master Reseller Agreement and see no mention of OFAC or sanctions generally.  I note that Resello reserves the right to refuse any potential reseller.  The agreement can be found here: https://www.resello.com/agreement#TCgeneral

Please note that I am not supporting Resello's decision regarding Iranian citizens (though I have no idea why they made it), and I share your dismay with such a business policy.

Best regards,

Greg 

On Wed, Sep 20, 2017 at 2:36 AM, Kavouss Arasteh <kavouss.arasteh@gmail.com> wrote:
Dear Greg.
At the call on 13 Sept as well as on 18 Sept you asked to provide examples that NON US BASED Registrar should not replicate Rules established by OFAC in regard with request from registrant or reseller for domain name
Here is the example that you are looking for .
This is a real and actual case

An individual domain Name  Iranian National  reseller residing outside Iran sent a request  to <sales@resello.com>in  an online form, asking  to become reseller of Domain Name  in Iran (to sell domains to Iranian people)

He received the following reply

Quote

“On Tue, Sep 19, 2017 at 9:48 PM, Resello Sales <sales@resello.com> wrote:

Dear reseller ( XXX)

Unfortunately our policy restricts doing business with Iranian customers/resellers, even if they aren't living in Iran, but have an Iranian passport.

Kind regards,

Mark Assenberg
It is worth mentioning that Resello is a subsidiary company for following holding:

Yourholding
Ceintuurbaan 28
8024 AA Zwolle
+31 38 453 0752

The name is Yourholding and they are based in Netherlands. So they are not US-Based company.

They do not want to explain why they don't want to provide service to Iranian. They say, they is our internal policy decision.

It is important to make it clear that none of Registrars and service providers  which are not US Nationals or not based in USA cannot make internal policies to avoid giving services  to a given citizens. This is a global business not a personal decision of  a company or its managers.They must fully observe the expected behaviour and responses

It is important to emphasize that non-US based companies  should not to replicate the rules inside USA. 

Regards

Kavouss