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

[Paul Rosenzweig]

I agree with this recommendation

Paul

 

Paul Rosenzweig

paul.rosenzweig at redbranchconsulting.com <mailto:paul.rosenzweig at redbranchconsulting.com> 

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www.redbranchconsulting.com <http://www.redbranchconsulting.com/> 

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From: ws2-jurisdiction-bounces at icann.org [mailto:ws2-jurisdiction-bounces at icann.org] On Behalf Of Greg Shatan
Sent: Wednesday, October 4, 2017 2:03 PM
To: ws2-jurisdiction <ws2-jurisdiction at icann.org>
Subject: [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of OFAC Recommendation

 

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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