[Ws2-jurisdiction] OFAC Recommendation

[Kavouss Arasteh]

Dear Greg,
Thanks for the message, I do not wish to reiterate my concerns and reopen
the discussion.
However, as Steve Del Bianco stated in the chat and later on in a message
to me ,there is a need to take a follow up action in drafting a Stress
Test describing
the situation in the overall activities of Jurisdiction Group without any
référence to or inclusion in the OFAC Recommendation on OFAC.
Steve stated that he 8 as the architect of all 40 Stress Tests in CCWG
,will assist to draft a text on the matter.
In view of the above, YOU NEED TO AMEND THE INSTANCE AS FOLLOWS
*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. To this effect a Stress Test is under
preparation for subsequent submission to CCWG to address the matter, as
appropriate Sub Group *
Regards
Kavouss

On Mon, Oct 2, 2017 at 8:56 AM, Raphaël BEAUREGARD-LACROIX <
raphael.beauregardlacroix at sciencespo.fr> wrote:

> 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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>>
>>
>
>
> --
> Raphaël Beauregard-Lacroix
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