OFAC Recommendation
All, In order to finalize the OFAC Recommendation, I attach a copy of the latest draft of the OFAC Recommendation with several proposed changes. I need to ascertain the level of support for including these changes. On our last call, we discussed these proposed changes, and also suggestions made on the list to include an instance involving the registrar Resello. Based on that call and discussion on the list, I believe that the group supports finalizing the document without the suggested changes. As discussed on the call, I am distributing this version of the OFAC Recommendation with the following statement: *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. * If you have not already done so, please respond and indicate whether or not you support the inclusion of these suggested changes or the Resello matter in the OFAC Recommendation. Thank you. Greg
Looks good to me. There is a record of the discussion, which appears to me as a fair thing. Best, 2017-10-02 8:01 GMT+02:00 Greg Shatan <gregshatanipc@gmail.com>:
All,
In order to finalize the OFAC Recommendation, I attach a copy of the latest draft of the OFAC Recommendation with several proposed changes. I need to ascertain the level of support for including these changes.
On our last call, we discussed these proposed changes, and also suggestions made on the list to include an instance involving the registrar Resello. Based on that call and discussion on the list, I believe that the group supports finalizing the document without the suggested changes.
As discussed on the call, I am distributing this version of the OFAC Recommendation with the following statement:
*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. *
If you have not already done so, please respond and indicate whether or not you support the inclusion of these suggested changes or the Resello matter in the OFAC Recommendation.
Thank you.
Greg
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Dear Greg, Thanks for the message, I do not wish to reiterate my concerns and reopen the discussion. However, as Steve Del Bianco stated in the chat and later on in a message to me ,there is a need to take a follow up action in drafting a Stress Test describing the situation in the overall activities of Jurisdiction Group without any référence to or inclusion in the OFAC Recommendation on OFAC. Steve stated that he 8 as the architect of all 40 Stress Tests in CCWG ,will assist to draft a text on the matter. In view of the above, YOU NEED TO AMEND THE INSTANCE AS FOLLOWS *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. To this effect a Stress Test is under preparation for subsequent submission to CCWG to address the matter, as appropriate Sub Group * Regards Kavouss On Mon, Oct 2, 2017 at 8:56 AM, Raphaël BEAUREGARD-LACROIX < raphael.beauregardlacroix@sciencespo.fr> wrote:
Looks good to me. There is a record of the discussion, which appears to me as a fair thing.
Best,
2017-10-02 8:01 GMT+02:00 Greg Shatan <gregshatanipc@gmail.com>:
All,
In order to finalize the OFAC Recommendation, I attach a copy of the latest draft of the OFAC Recommendation with several proposed changes. I need to ascertain the level of support for including these changes.
On our last call, we discussed these proposed changes, and also suggestions made on the list to include an instance involving the registrar Resello. Based on that call and discussion on the list, I believe that the group supports finalizing the document without the suggested changes.
As discussed on the call, I am distributing this version of the OFAC Recommendation with the following statement:
*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. *
If you have not already done so, please respond and indicate whether or not you support the inclusion of these suggested changes or the Resello matter in the OFAC Recommendation.
Thank you.
Greg
_______________________________________________ Ws2-jurisdiction mailing list Ws2-jurisdiction@icann.org https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
-- Raphaël Beauregard-Lacroix LinkedIn <https://www.linkedin.com/in/rapha%C3%ABl-beauregard-lacroix-88733786/> - @rbl0012 <https://twitter.com/rbl0112> - M: +33 7 86 39 18 15 <+33%207%2086%2039%2018%2015>
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Dear Greg and colleagues: I regret that I do not support the document as it presently stands. Since there is little prospect of an early agreement, I suggest that the matter be discussed in a face to face meeting in ICANN60. As far as I can see, the issue lies between Governments, and - as has indeed proved to be the case - lies beyond the competence of our subgroup. Also, if it is still the case that ICANN has not yet applied to ‘secure an OFAC license for all such applicants…’, that is a great shame. ICANN should not need the whole apparatus of the CCWG before undertaking that which is glaringly obviously required for it to execute its global mandate. Regards CW
On 2 Oct 2017, at 08:01, Greg Shatan <gregshatanipc@gmail.com <mailto:gregshatanipc@gmail.com>> wrote:
All,
In order to finalize the OFAC Recommendation, I attach a copy of the latest draft of the OFAC Recommendation with several proposed changes. I need to ascertain the level of support for including these changes.
On our last call, we discussed these proposed changes, and also suggestions made on the list to include an instance involving the registrar Resello. Based on that call and discussion on the list, I believe that the group supports finalizing the document without the suggested changes.
As discussed on the call, I am distributing this version of the OFAC Recommendation with the following statement:
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.
If you have not already done so, please respond and indicate whether or not you support the inclusion of these suggested changes or the Resello matter in the OFAC Recommendation.
Thank you.
Greg
<OFAC Recommendation with Proposed Changes.docx><OFAC Recommendation with Proposed Changes.pdf>_______________________________________________ Ws2-jurisdiction mailing list Ws2-jurisdiction@icann.org <mailto:Ws2-jurisdiction@icann.org> https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
Sent from my mobile Kindly excuse brevity and typos On Oct 2, 2017 2:22 PM, "Wilkinson" <mail@christopherwilkinson.eu> wrote: Also, if it is still the case that ICANN has not yet applied to ‘secure an OFAC license for all such applicants…’, that is a great shame. ICANN should not need the whole apparatus of the CCWG before undertaking that which is glaringly obviously required for it to execute its global mandate. SO: +1 to this. However if a community mandate further help ICANN org support their OFAC immunity request then that's fine. Regards Regards CW On 2 Oct 2017, at 08:01, Greg Shatan <gregshatanipc@gmail.com> wrote: All, In order to finalize the OFAC Recommendation, I attach a copy of the latest draft of the OFAC Recommendation with several proposed changes. I need to ascertain the level of support for including these changes. On our last call, we discussed these proposed changes, and also suggestions made on the list to include an instance involving the registrar Resello. Based on that call and discussion on the list, I believe that the group supports finalizing the document without the suggested changes. As discussed on the call, I am distributing this version of the OFAC Recommendation with the following statement: *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. * If you have not already done so, please respond and indicate whether or not you support the inclusion of these suggested changes or the Resello matter in the OFAC Recommendation. Thank you. Greg <OFAC Recommendation with Proposed Changes.docx><OFAC Recommendation with Proposed Changes.pdf>_______________________________________________ Ws2-jurisdiction mailing list Ws2-jurisdiction@icann.org https://mm.icann.org/mailman/listinfo/ws2-jurisdiction _______________________________________________ Ws2-jurisdiction mailing list Ws2-jurisdiction@icann.org https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
I concur in finalizing the OFAC recommendation without the proposed changes. I would also concur, however, in opening a separate issue stream to determine whether the issue raised warrants a further recommendation. Paul Paul Rosenzweig paul.rosenzweig@redbranchconsulting.com <mailto:paul.rosenzweig@redbranchconsulting.com> O: +1 (202) 547-0660 M: +1 (202) 329-9650 VOIP: +1 (202) 738-1739 www.redbranchconsulting.com <http://www.redbranchconsulting.com/> My PGP Key: https://keys.mailvelope.com/pks/lookup?op=get <https://keys.mailvelope.com/pks/lookup?op=get&search=0x9A830097CA066684> &search=0x9A830097CA066684 From: ws2-jurisdiction-bounces@icann.org [mailto:ws2-jurisdiction-bounces@icann.org] On Behalf Of Greg Shatan Sent: Monday, October 2, 2017 2:01 AM To: ws2-jurisdiction <ws2-jurisdiction@icann.org> Subject: [Ws2-jurisdiction] OFAC Recommendation All, In order to finalize the OFAC Recommendation, I attach a copy of the latest draft of the OFAC Recommendation with several proposed changes. I need to ascertain the level of support for including these changes. On our last call, we discussed these proposed changes, and also suggestions made on the list to include an instance involving the registrar Resello. Based on that call and discussion on the list, I believe that the group supports finalizing the document without the suggested changes. As discussed on the call, I am distributing this version of the OFAC Recommendation with the following statement: 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. If you have not already done so, please respond and indicate whether or not you support the inclusion of these suggested changes or the Resello matter in the OFAC Recommendation. Thank you. Greg
Dear Christopher Thank you for your message, I need not understand the reference to government here. May you kindly be more clear your problem with the text Are you opposing the amendment? Are you opposing the initial text without amendment? Regards Kavouss Sent from my iPhone
On 2 Oct 2017, at 18:31, Paul Rosenzweig <paul.rosenzweig@redbranchconsulting.com> wrote:
I concur in finalizing the OFAC recommendation without the proposed changes.
I would also concur, however, in opening a separate issue stream to determine whether the issue raised warrants a further recommendation.
Paul
Paul Rosenzweig paul.rosenzweig@redbranchconsulting.com O: +1 (202) 547-0660 M: +1 (202) 329-9650 VOIP: +1 (202) 738-1739 www.redbranchconsulting.com My PGP Key: https://keys.mailvelope.com/pks/lookup?op=get&search=0x9A830097CA066684
From: ws2-jurisdiction-bounces@icann.org [mailto:ws2-jurisdiction-bounces@icann.org] On Behalf Of Greg Shatan Sent: Monday, October 2, 2017 2:01 AM To: ws2-jurisdiction <ws2-jurisdiction@icann.org> Subject: [Ws2-jurisdiction] OFAC Recommendation
All,
In order to finalize the OFAC Recommendation, I attach a copy of the latest draft of the OFAC Recommendation with several proposed changes. I need to ascertain the level of support for including these changes.
On our last call, we discussed these proposed changes, and also suggestions made on the list to include an instance involving the registrar Resello. Based on that call and discussion on the list, I believe that the group supports finalizing the document without the suggested changes.
As discussed on the call, I am distributing this version of the OFAC Recommendation with the following statement:
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.
If you have not already done so, please respond and indicate whether or not you support the inclusion of these suggested changes or the Resello matter in the OFAC Recommendation.
Thank you.
Greg
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participants (7)
-
Arasteh -
Greg Shatan -
Kavouss Arasteh
-
Paul Rosenzweig -
Raphaël BEAUREGARD-LACROIX -
Seun Ojedeji -
Wilkinson