[Ws2-jurisdiction] OFAC Recommendation

[Wilkinson]

Dear Greg and colleagues:

I regret that I do not support the document as it presently stands. Since there is little prospect of an early agreement, I suggest that the matter be discussed in a face to face meeting in ICANN60.
As far as I can see, the issue lies between Governments, and  - as has indeed proved to be the case - lies beyond the competence of our subgroup.

Also, if it is still the case that ICANN has not yet applied to ‘secure an OFAC license for all such applicants…’, that is a great  shame.
ICANN should not need the whole apparatus of the CCWG before undertaking that which is glaringly obviously required for it to execute its global mandate.

Regards

CW



> On 2 Oct 2017, at 08:01, Greg Shatan <gregshatanipc at gmail.com <mailto:gregshatanipc at gmail.com>> wrote:
> 
> 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
> 
> 
> <OFAC Recommendation with Proposed Changes.docx><OFAC Recommendation with Proposed Changes.pdf>_______________________________________________
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