[Ws2-jurisdiction] OFAC Recommendation

[Seun Ojedeji]

Sent from my mobile
Kindly excuse brevity and typos

On Oct 2, 2017 2:22 PM, "Wilkinson" <mail at christopherwilkinson.eu> wrote:


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.


SO: +1 to this. However if a community mandate further help ICANN org
support their OFAC immunity request then that's fine.

Regards


Regards

CW



On 2 Oct 2017, at 08:01, Greg Shatan <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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