Dear Erika,

I do not understand the European ban or sanctuion.

There is no basis for such ban or sanction

I request that this issue be included in the introductory part of the report 7 OFAC Rec. and be reflected, where possible, in the recommand part.

I hope people now recognized that we are real victim on this issue.

Pls kindly look at the matter and also ask Louisewees ( Board Mmember ) to check

Regards

Kavouss

On Wed, Sep 20, 2017 at 7:01 PM, Erika Mann <erika@erikamann.com> wrote:

Dear Kavouss - 

since this company is based in Zwolle/Netherlands, maybe they are responding to restrictions/bans setup by the European Union. One would have to check this. 

http://eeas.europa.eu/archives/docs/cfsp/sanctions/docs/measures_en.pdf

Kind regards, 

Erika 

On Wed, Sep 20, 2017 at 6:53 PM, Kavouss Arasteh <kavouss.arasteh@gmail.com> wrote:

Dear Greg,

Pls kindly reply whether the below texts that you asked me to provide is being included in the text in appropriate part of the text

Regards

Kavouss

On Wed, Sep 20, 2017 at 8:36 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

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