[Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation

[Greg Shatan]

All,

Here is the FINAL Draft of the OFAC Recommendations, reflecting our call
today. There are a few changes based on a question asked in the call about
what "residents" was intended to mean.  In the course of cleaning that up,
I noticed that the language cited to the RAA in fact came from the Terms
and Conditions for a Registrar Accreditation Application.  I've cleaned
that up.  (The language did not change at all, just the citation.)
Finally, given the complexity of OFAC, I've added a "caveat" as footnote 1
so that the reader will understand the initial section is just a high-level
overview of OFAC (provided for context), and not legal advice, etc.

Please review and let me know if you see any issues in the attached.  *Please
respond no later than 23:00 UTC . *This will be submitted before 23:59 UTC
today for consideration by the Plenary.

As a reminder, this will be submitted to the Plenary with an email
including the following paragraph:

*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.  The Subgroup will consider creating a "stress
tests" based on these scenarios.*

Thank you!

Greg
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