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

[Adebunmi AKINBO]

+1 With the recommendations.

On Wed, Oct 4, 2017 at 11:02 PM, Raphaël BEAUREGARD-LACROIX <
raphael.beauregardlacroix at sciencespo.fr> wrote:

> 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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>>
>>
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>>
>
>
> --
> Raphaël Beauregard-Lacroix
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