[Ws2-jurisdiction] OFAC Recommendation

[Greg Shatan]

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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