[CCWG-ACCT] Jurisdiction Subgroup: OFAC Recommendation

[Greg Shatan]

Plenary:

I submit for your consideration the Subgroup's recommendation on matters
relating to OFAC.  The rest of our Report will follow next week.

*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.*

Greg Shatan
*Rapporteur*
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