[Ws2-jurisdiction] OFAC Rec.s

Erika Mann erika at erikamann.com
Wed Sep 20 17:01:58 UTC 2017


Dear Kavouss -

since this company is based in Zwolle/Netherlands, maybe they are
responding to restrictions/bans setup by the European Union. One would have
to check this.

http://eeas.europa.eu/archives/docs/cfsp/sanctions/docs/measures_en.pdf

Kind regards,
Erika

On Wed, Sep 20, 2017 at 6:53 PM, Kavouss Arasteh <kavouss.arasteh at gmail.com>
wrote:

> Dear Greg,
> Pls kindly reply whether the below texts that you asked me to provide is
> being included in the text in appropriate part of the text
> Regards
> Kavouss
>
> On Wed, Sep 20, 2017 at 8:36 AM, Kavouss Arasteh <
> kavouss.arasteh at gmail.com> wrote:
>
>> 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 <+31%2038%20453%200752>*
>>
>> *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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