[CCWG-ACCT] Jurisdiction Subgroup Draft Report for CCWG-Accountability Plenary Review

Greg Shatan gregshatanipc at gmail.com
Wed Oct 11 23:53:57 UTC 2017


I am pleased to submit the Draft Report from the Jurisdiction Subgroup for
consideration by the CCWG-Accountability Plenary.

It is my understanding that a minority viewpoint is expected to be
submitted.  In the interests of time, this will be submitted to the Plenary
separately from the Draft Report.

*During the preparation of the OFAC 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 "stress tests" based on these scenarios.*

I look forward to the Plenary's reading of the Draft Report.

Best regards,

Greg Shatan
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