[Ws2-jurisdiction] OFAC Rec.s

[Kavouss Arasteh]

Dear Greg.
At the call on 13 Sept as well as on 18 Sept you asked to provide examples
that NON US BASED Registrar should not replicate Rules established by OFAC
in regard with request from registrant or reseller for domain name
Here is the example that you are looking for .
This is a real and actual case

*An individual domain Name  Iranian National  reseller residing outside
Iran sent a request  to <sales at resello.com <sales at resello.com>>in  an
online form, asking  to become reseller of Domain Name  in Iran (to sell
domains to Iranian people) *

*He received the following reply*

*Quote*

*“On Tue, Sep 19, 2017 at 9:48 PM, Resello Sales <sales at resello.com
<sales at resello.com>> wrote:*

*Dear reseller ( XXX) *

*Unfortunately our policy restricts doing business with Iranian
customers/resellers, even if they aren't living in Iran, but have an
Iranian passport.*




*Kind regards, Mark Assenberg It is worth mentioning that Resello is a
subsidiary company for following holding:*




*Yourholding Ceintuurbaan 28
<https://maps.google.com/?q=Ceintuurbaan+28+8024+AA+Zwolle&entry=gmail&source=g>
8024 AA Zwolle
<https://maps.google.com/?q=Ceintuurbaan+28+8024+AA+Zwolle&entry=gmail&source=g>
+31 38 453 0752*

*The name is Yourholding and they are based in Netherlands. So they are not
US-Based company.*

*They do not want to explain why they don't want to provide service to
Iranian. They say, they is our internal policy decision.*

*It is important to make it clear that none of Registrars and service
providers  which are not US Nationals or not based in USA cannot make
internal policies to avoid giving services  to a given citizens. This is a
global business not a personal decision of  a company or its managers.They
must fully observe the expected behaviour and responses *

*It is important to emphasize that non-US based companies  should not to
replicate the rules inside USA. *

*Regards*

*Kavouss *
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