[Ws2-jurisdiction] OFAC Recommendation

Raphaël BEAUREGARD-LACROIX raphael.beauregardlacroix at sciencespo.fr
Mon Oct 2 06:56:27 UTC 2017


Looks good to me. There is a record of the discussion, which appears to me
as a fair thing.

Best,

2017-10-02 8:01 GMT+02:00 Greg Shatan <gregshatanipc at gmail.com>:

> 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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>


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Raphaël Beauregard-Lacroix
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