[Ws2-jurisdiction] Current Draft of OFAC Recommendation

[Mueller, Milton L]

Greg
This is a very good start for a final report dealing with the OFAC issues.
I have a few comments and recommendations which I summarize below. We can discuss on the call, too.

You wrote “ICANN should commit to applying for OFAC license for all such applicants,”
For clarity’s sake you should modify  “all such applicants” to “All applicants who are not SDNs.”

I do not agree that it is “premature” to recommend that ICANN seek a general license. Our recommendations are not binding anyway as far as I know and ICANN will do its own feasibility study.

We should recommend that ICANN request that the domain name exception be removed from the general license for export of certain services and software incident to Internet-based communications. Seems very simple.

From: ws2-jurisdiction-bounces at icann.org [mailto:ws2-jurisdiction-bounces at icann.org] On Behalf Of Greg Shatan
Sent: Wednesday, September 6, 2017 2:29 PM
To: ws2-jurisdiction <ws2-jurisdiction at icann.org>
Cc: acct-staff at icann.org
Subject: [Ws2-jurisdiction] Current Draft of OFAC Recommendation

All,

I've just downloaded the draft of the OFAC Recommendation as it currently stands.  It is attached in Word and PDF versions.

The Master List will follow.

Greg
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