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

[Raphaël BEAUREGARD-LACROIX]

I also agree with this recommendation.

Best,

2017-10-04 22:23 GMT+02:00 Wilkinson <mail at christopherwilkinson.eu>:

> Good evening: I abstain, formally.
> I consider that the mandate and composition of the working group is not
> susceptible to reach a conclusion that would be internationally acceptable
> at this time.
> I think that the issue should be put on hold for the time being, not
> excluding a face to face meeting in Abu Dhabi.
>
> Thankyou and regards
>
> CW
>
>
>
> On 4 Oct 2017, at 20:17, Paul Rosenzweig <paul.rosenzweig at redbranchcons
> ulting.com> wrote:
>
> I agree with this recommendation
> Paul
>
> Paul Rosenzweig
> paul.rosenzweig at redbranchconsulting.com
> O: +1 (202) 547-0660
> M: +1 (202) 329-9650
> VOIP: +1 (202) 738-1739
> www.redbranchconsulting.com
> My PGP Key: https://keys.mailvelope.com/pks/lookup?op=get&search=0x
> 9A830097CA066684
>
> *From:* ws2-jurisdiction-bounces at icann.org [mailto:ws2-jurisdiction-bounc
> es at icann.org <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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-- 
Raphaël Beauregard-Lacroix
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