[Ssr2-review] ICANN Organization Blog on DNS Abuse

Wed May 6 16:17:34 UTC 2020

Dear Denise,

Thank you for the questions. Sorry for my slow response, I had a few busy days, and somehow, I marked this whole thread as read in my Outlook folder without seeing your message.

Jennifer, thank you for sending these questions through the standard process; this is the best way to proceed.

The blog is about what ICANN Org is doing, and in my opinion, that is significant, and it is very good that we talk more about that.

To me, it seems that the discussion is circling back to the question of voluntarily contract negotiations vs. policy development process, that we discussed in some detail. I am looking forward to recommendations from this team for PDP(s), addressed to the GNSO council. I don't see a way forward in bypassing the BUMP, as that would contradict the bylaws. Generally speaking of the DNS abuse, I think its less of a question of what is DNS abuse (how to write the definitions), it is much more what is in the ICANN (rather limited) remit.

Speaking of Covid registrations, I see that many actors in the ecosystem are trigger-happy and that we have a lot of false positives. For example, I had to intervene for covid19.rs to be unblocked at Domaintools and Quad9, and I heard of a similar case for the official Belgian domain/site. Such an approach significantly impacts the ability of people and organizations on the Internet to publish useful content. So, as always, it's complicated and needs balancing and multistakeholderism. 

Best, Danko Jevtović

From: Denise Michel <denisemichel at fb.com> 
Sent: Wednesday, April 29, 2020 10:35 PM
To: danko.jevtovic at board.icann.org; 'ICANN SSR2' <ssr2-review at icann.org>
Subject: Re: [Ssr2-review] ICANN Organization Blog on DNS Abuse

Thanks for sharing, the ICANN blog <https://www.icann.org/news/blog/icann-org-s-multifaceted-response-to-dns-abuse> , Danko.  It’s highly relevant to SSR2 work, as well as to what several SSR2 members are doing in our day jobs to stop domain abuse.

On the whole, the blog is an expression of intent to act. While welcomed, there are no specifics nor a time table for when the internal and community actions will occur. This raises several questions related to SSR2 work for ICANN Staff to answer (and a couple for the Board), which are listed below.

Would SSR2 be able to get expedited answers to these? It would be useful for all concerned if we could factor this into our SSR2 work.

Thanks

Denise

1) The blog says: " the domain names and the data collected by the system will be shared with parties who are in a position to take action, such as registrars and registries, and in some cases with national and international law enforcement organizations."

*	What specific actions is ICANN expecting registries and registrars to take?  
*	For example, is ICANN encouraging suspension of name resolution or of the registration, or the registrant account?
*	Will ICANN ask registrars and registries to report on the efficacy of these actions? If so, when and on what cadence?
*	ICANN should publicly report per registrar & registry action: 

*	  How many names has it identified as suspicious/malicious?
*	  What’s the number of domain names that each registry/registrar has taken action against? And what action was taken?

*	When can we expect ICANN public reporting and on what cadence? 

2) What distinguishes ICANN's participation in the face of the pandemic from how they've participated in the past? 

*	The blog says: “ICANN Compliance uses data collected in audits (described in more detail below) to assess whether registries and registrars are adhering to their DNS security threat obligations.” 
*	What will Compliance do that it has not done until now?
*	Is Compliance making audit data associated with US-based registrars available to States Attorney Generals and the US Attorney General?

3) The blog states (the obvious) that ICANN isn’t a regulator of Internet content, but it doesn’t address ICANN’s public interest remit. Multiple entities have asked ICANN to better govern the manner in which domain names are registered, and now especially, everyone is asking ICANN to hold contracted parties to greater accountability to prevent domains from being registered by malicious actors, especially for pandemic-related fraud and abuse. This requires greater scrutiny during the registration process. 

*	What actions are ICANN taking that address this?
*	In addition to high volumes of fraudulent domain names containing pandemic-related strings with which criminals try to fool Internet users, random looking or otherwise auto-generated names that are easy to register in volume and are being used by the hundreds to perpetuate pandemic-related phishing attacks. What actions are ICANN taking that addresses this?
*	Recommended actions contained in SSR2’s draft report could help mitigate pandemic-related domain name abuse. Is the ICANN Board and staff reconsidering any of these actions?
*	Recommendations from others over the last few years also would help mitigate pandemic-related domain name abuse – especially the substantially increased phishing attacks that harm users. Is the ICANN Board and staff reconsidering any of these actions? Including:

- will ICANN move to ensure domain name registrant data is validated? Or at least implement cross-field validation?

- will ICANN put in place an Acceptable Use Policy that applies specifically to parties that register large numbers of domains, that requires registrants to apply for (and be validated for) bulk registration services? Further, will ICANN put in place an obligation to distinguish domain names registered by legal entities from those registered by

natural persons, classify parties that use bulk registration services as legal entities, and require unredacted access to the registration data of legal entities?

- will ICANN maintain and publish a current list of validated bulk registrants (who are from above defined as not natural persons)?

- will ICANN disallow registration transactions that involve large numbers of random-looking algorithmic domain names? 

-  will ICANN disallow, for a period of one year, the re-registration of any bulk-registered domain name that has been used in a criminal cyberattack?

From: Ssr2-review <ssr2-review-bounces at icann.org <mailto:ssr2-review-bounces at icann.org> > on behalf of "danko.jevtovic at board.icann.org <mailto:danko.jevtovic at board.icann.org> " <danko.jevtovic at board.icann.org <mailto:danko.jevtovic at board.icann.org> >
Organization: ICANN Board
Date: Tuesday, April 21, 2020 at 8:44 AM
To: SSR2 <ssr2-review at icann.org <mailto:ssr2-review at icann.org> >
Subject: [Ssr2-review] ICANN Organization Blog on DNS Abuse

ICANN Organization Blog on DNS Abuse

https://www.icann.org/news/blog/icann-org-s-multifaceted-response-to-dns-abuse

Danko

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