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

[Mike Rodenbaugh]

I also support this.

Thanks,
Mike

Mike Rodenbaugh
RODENBAUGH LAW
tel/fax:  +1.415.738.8087
http://rodenbaugh.com

On Thu, Oct 5, 2017 at 1:34 PM, Mueller, Milton L <milton at gatech.edu> wrote:

> I support this recommendation.
>
>
>
> Dr. Milton Mueller
>
> Professor, School of Public Policy
>
> Georgia Institute of Technology
>
>
>
> [image: IGP_logo_gold block_email sig]
> <http://www.internetgovernance.org/>
>
>
>
>
>
>
>
> *From:* ws2-jurisdiction-bounces at icann.org [mailto:ws2-jurisdiction-
> bounces at icann.org] *On Behalf Of *Paul Rosenzweig
> *Sent:* Wednesday, October 4, 2017 2:18 PM
> *To:* 'Greg Shatan' <gregshatanipc at gmail.com>; 'ws2-jurisdiction' <
> ws2-jurisdiction at icann.org>
> *Subject:* Re: [Ws2-jurisdiction] FOR YOUR FINAL REVIEW: FINAL Draft of
> OFAC Recommendation
>
>
>
> I agree with this recommendation
>
> Paul
>
>
>
> Paul Rosenzweig
>
> paul.rosenzweig at redbranchconsulting.com
>
> O: +1 (202) 547-0660 <(202)%20547-0660>
>
> M: +1 (202) 329-9650 <(202)%20329-9650>
>
> VOIP: +1 (202) 738-1739 <(202)%20738-1739>
>
> www.redbranchconsulting.com
>
> My PGP Key: https://keys.mailvelope.com/pks/lookup?op=get&search=
> 0x9A830097CA066684
>
>
>
> *From:* ws2-jurisdiction-bounces at icann.org [mailto:ws2-jurisdiction-
> bounces 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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