FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation
All, Here is the FINAL Draft of the OFAC Recommendations, reflecting our call today. There are a few changes based on a question asked in the call about what "residents" was intended to mean. In the course of cleaning that up, I noticed that the language cited to the RAA in fact came from the Terms and Conditions for a Registrar Accreditation Application. I've cleaned that up. (The language did not change at all, just the citation.) Finally, given the complexity of OFAC, I've added a "caveat" as footnote 1 so that the reader will understand the initial section is just a high-level overview of OFAC (provided for context), and not legal advice, etc. Please review and let me know if you see any issues in the attached. *Please respond no later than 23:00 UTC . *This will be submitted before 23:59 UTC today for consideration by the Plenary. As a reminder, this will be submitted to the Plenary with an email including the following paragraph: *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.* Thank you! Greg
I agree with this 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: Wednesday, October 4, 2017 2:03 PM To: ws2-jurisdiction <ws2-jurisdiction@icann.org> Subject: [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation All, Here is the FINAL Draft of the OFAC Recommendations, reflecting our call today. There are a few changes based on a question asked in the call about what "residents" was intended to mean. In the course of cleaning that up, I noticed that the language cited to the RAA in fact came from the Terms and Conditions for a Registrar Accreditation Application. I've cleaned that up. (The language did not change at all, just the citation.) Finally, given the complexity of OFAC, I've added a "caveat" as footnote 1 so that the reader will understand the initial section is just a high-level overview of OFAC (provided for context), and not legal advice, etc. Please review and let me know if you see any issues in the attached. Please respond no later than 23:00 UTC . This will be submitted before 23:59 UTC today for consideration by the Plenary. As a reminder, this will be submitted to the Plenary with an email including the following paragraph: 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. Thank you! Greg
Good evening: I abstain, formally. I consider that the mandate and composition of the working group is not susceptible to reach a conclusion that would be internationally acceptable at this time. I think that the issue should be put on hold for the time being, not excluding a face to face meeting in Abu Dhabi. Thankyou and regards CW
On 4 Oct 2017, at 20:17, Paul Rosenzweig <paul.rosenzweig@redbranchconsulting.com> wrote:
I agree with this 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&search=0x9A830097CA066684 <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: Wednesday, October 4, 2017 2:03 PM To: ws2-jurisdiction <ws2-jurisdiction@icann.org> Subject: [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation
All,
Here is the FINAL Draft of the OFAC Recommendations, reflecting our call today. There are a few changes based on a question asked in the call about what "residents" was intended to mean. In the course of cleaning that up, I noticed that the language cited to the RAA in fact came from the Terms and Conditions for a Registrar Accreditation Application. I've cleaned that up. (The language did not change at all, just the citation.) Finally, given the complexity of OFAC, I've added a "caveat" as footnote 1 so that the reader will understand the initial section is just a high-level overview of OFAC (provided for context), and not legal advice, etc.
Please review and let me know if you see any issues in the attached. Please respond no later than 23:00 UTC . This will be submitted before 23:59 UTC today for consideration by the Plenary.
As a reminder, this will be submitted to the Plenary with an email including the following paragraph:
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.
Thank you!
Greg
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I also agree with this recommendation. Best, 2017-10-04 22:23 GMT+02:00 Wilkinson <mail@christopherwilkinson.eu>:
Good evening: I abstain, formally. I consider that the mandate and composition of the working group is not susceptible to reach a conclusion that would be internationally acceptable at this time. I think that the issue should be put on hold for the time being, not excluding a face to face meeting in Abu Dhabi.
Thankyou and regards
CW
On 4 Oct 2017, at 20:17, Paul Rosenzweig <paul.rosenzweig@redbranchcons ulting.com> wrote:
I agree with this 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=0x 9A830097CA066684
*From:* ws2-jurisdiction-bounces@icann.org [mailto:ws2-jurisdiction-bounc es@icann.org <ws2-jurisdiction-bounces@icann.org>] *On Behalf Of *Greg Shatan *Sent:* Wednesday, October 4, 2017 2:03 PM *To:* ws2-jurisdiction <ws2-jurisdiction@icann.org> *Subject:* [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation
All,
Here is the FINAL Draft of the OFAC Recommendations, reflecting our call today. There are a few changes based on a question asked in the call about what "residents" was intended to mean. In the course of cleaning that up, I noticed that the language cited to the RAA in fact came from the Terms and Conditions for a Registrar Accreditation Application. I've cleaned that up. (The language did not change at all, just the citation.) Finally, given the complexity of OFAC, I've added a "caveat" as footnote 1 so that the reader will understand the initial section is just a high-level overview of OFAC (provided for context), and not legal advice, etc.
Please review and let me know if you see any issues in the attached. *Please respond no later than 23:00 UTC . *This will be submitted before 23:59 UTC today for consideration by the Plenary.
As a reminder, this will be submitted to the Plenary with an email including the following paragraph:
*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.*
Thank you!
Greg
_______________________________________________ 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
-- 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
+1 With the recommendations. On Wed, Oct 4, 2017 at 11:02 PM, Raphaël BEAUREGARD-LACROIX < raphael.beauregardlacroix@sciencespo.fr> wrote:
I also agree with this recommendation.
Best,
2017-10-04 22:23 GMT+02:00 Wilkinson <mail@christopherwilkinson.eu>:
Good evening: I abstain, formally. I consider that the mandate and composition of the working group is not susceptible to reach a conclusion that would be internationally acceptable at this time. I think that the issue should be put on hold for the time being, not excluding a face to face meeting in Abu Dhabi.
Thankyou and regards
CW
On 4 Oct 2017, at 20:17, Paul Rosenzweig <paul.rosenzweig@redbranchcons ulting.com> wrote:
I agree with this 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=0x 9A830097CA066684
*From:* ws2-jurisdiction-bounces@icann.org [mailto:ws2-jurisdiction-bounc es@icann.org <ws2-jurisdiction-bounces@icann.org>] *On Behalf Of *Greg Shatan *Sent:* Wednesday, October 4, 2017 2:03 PM *To:* ws2-jurisdiction <ws2-jurisdiction@icann.org> *Subject:* [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation
All,
Here is the FINAL Draft of the OFAC Recommendations, reflecting our call today. There are a few changes based on a question asked in the call about what "residents" was intended to mean. In the course of cleaning that up, I noticed that the language cited to the RAA in fact came from the Terms and Conditions for a Registrar Accreditation Application. I've cleaned that up. (The language did not change at all, just the citation.) Finally, given the complexity of OFAC, I've added a "caveat" as footnote 1 so that the reader will understand the initial section is just a high-level overview of OFAC (provided for context), and not legal advice, etc.
Please review and let me know if you see any issues in the attached. *Please respond no later than 23:00 UTC . *This will be submitted before 23:59 UTC today for consideration by the Plenary.
As a reminder, this will be submitted to the Plenary with an email including the following paragraph:
*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.*
Thank you!
Greg
_______________________________________________ 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
-- 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
_______________________________________________ Ws2-jurisdiction mailing list Ws2-jurisdiction@icann.org https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
I support this recommendation. Dr. Milton Mueller Professor, School of Public Policy Georgia Institute of Technology [IGP_logo_gold block_email sig]<http://www.internetgovernance.org/> From: ws2-jurisdiction-bounces@icann.org [mailto:ws2-jurisdiction-bounces@icann.org] On Behalf Of Paul Rosenzweig Sent: Wednesday, October 4, 2017 2:18 PM To: 'Greg Shatan' <gregshatanipc@gmail.com>; 'ws2-jurisdiction' <ws2-jurisdiction@icann.org> Subject: Re: [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation I agree with this 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&search=0x9A830097CA066684 From: ws2-jurisdiction-bounces@icann.org<mailto:ws2-jurisdiction-bounces@icann.org> [mailto:ws2-jurisdiction-bounces@icann.org] On Behalf Of Greg Shatan Sent: Wednesday, October 4, 2017 2:03 PM To: ws2-jurisdiction <ws2-jurisdiction@icann.org<mailto:ws2-jurisdiction@icann.org>> Subject: [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation All, Here is the FINAL Draft of the OFAC Recommendations, reflecting our call today. There are a few changes based on a question asked in the call about what "residents" was intended to mean. In the course of cleaning that up, I noticed that the language cited to the RAA in fact came from the Terms and Conditions for a Registrar Accreditation Application. I've cleaned that up. (The language did not change at all, just the citation.) Finally, given the complexity of OFAC, I've added a "caveat" as footnote 1 so that the reader will understand the initial section is just a high-level overview of OFAC (provided for context), and not legal advice, etc. Please review and let me know if you see any issues in the attached. Please respond no later than 23:00 UTC . This will be submitted before 23:59 UTC today for consideration by the Plenary. As a reminder, this will be submitted to the Plenary with an email including the following paragraph: 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. Thank you! Greg
I also support this. Thanks, Mike Mike Rodenbaugh RODENBAUGH LAW tel/fax: +1.415.738.8087 http://rodenbaugh.com On Thu, Oct 5, 2017 at 1:34 PM, Mueller, Milton L <milton@gatech.edu> wrote:
I support this recommendation.
Dr. Milton Mueller
Professor, School of Public Policy
Georgia Institute of Technology
[image: IGP_logo_gold block_email sig] <http://www.internetgovernance.org/>
*From:* ws2-jurisdiction-bounces@icann.org [mailto:ws2-jurisdiction- bounces@icann.org] *On Behalf Of *Paul Rosenzweig *Sent:* Wednesday, October 4, 2017 2:18 PM *To:* 'Greg Shatan' <gregshatanipc@gmail.com>; 'ws2-jurisdiction' < ws2-jurisdiction@icann.org> *Subject:* Re: [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation
I agree with this recommendation
Paul
Paul Rosenzweig
paul.rosenzweig@redbranchconsulting.com
O: +1 (202) 547-0660 <(202)%20547-0660>
M: +1 (202) 329-9650 <(202)%20329-9650>
VOIP: +1 (202) 738-1739 <(202)%20738-1739>
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 <ws2-jurisdiction-bounces@icann.org>] *On Behalf Of *Greg Shatan *Sent:* Wednesday, October 4, 2017 2:03 PM *To:* ws2-jurisdiction <ws2-jurisdiction@icann.org> *Subject:* [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation
All,
Here is the FINAL Draft of the OFAC Recommendations, reflecting our call today. There are a few changes based on a question asked in the call about what "residents" was intended to mean. In the course of cleaning that up, I noticed that the language cited to the RAA in fact came from the Terms and Conditions for a Registrar Accreditation Application. I've cleaned that up. (The language did not change at all, just the citation.) Finally, given the complexity of OFAC, I've added a "caveat" as footnote 1 so that the reader will understand the initial section is just a high-level overview of OFAC (provided for context), and not legal advice, etc.
Please review and let me know if you see any issues in the attached. *Please respond no later than 23:00 UTC . *This will be submitted before 23:59 UTC today for consideration by the Plenary.
As a reminder, this will be submitted to the Plenary with an email including the following paragraph:
*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.*
Thank you!
Greg
_______________________________________________ Ws2-jurisdiction mailing list Ws2-jurisdiction@icann.org https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
I agree, too! (Certainly in personal capacity that is). Thomas
Am 04.10.2017 um 20:03 schrieb Greg Shatan <gregshatanipc@gmail.com>:
All,
Here is the FINAL Draft of the OFAC Recommendations, reflecting our call today. There are a few changes based on a question asked in the call about what "residents" was intended to mean. In the course of cleaning that up, I noticed that the language cited to the RAA in fact came from the Terms and Conditions for a Registrar Accreditation Application. I've cleaned that up. (The language did not change at all, just the citation.) Finally, given the complexity of OFAC, I've added a "caveat" as footnote 1 so that the reader will understand the initial section is just a high-level overview of OFAC (provided for context), and not legal advice, etc.
Please review and let me know if you see any issues in the attached. Please respond no later than 23:00 UTC . This will be submitted before 23:59 UTC today for consideration by the Plenary.
As a reminder, this will be submitted to the Plenary with an email including the following paragraph:
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.
Thank you!
Greg
<Final Proposed Final OFAC Recommendation for Plenary.docx><Final Proposed Final OFAC Recommendation for Plenary.pdf>_______________________________________________ Ws2-jurisdiction mailing list Ws2-jurisdiction@icann.org https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
participants (8)
-
Adebunmi AKINBO -
Greg Shatan -
Mike Rodenbaugh -
Mueller, Milton L -
Paul Rosenzweig -
Raphaël BEAUREGARD-LACROIX -
Thomas Rickert -
Wilkinson