[Ws2-jurisdiction] OFAC Rec.s

Erika Mann erika at erikamann.com
Wed Sep 20 19:04:12 UTC 2017


Dear Kavouss -

I will look into this, I will send a request to the European Commission,
goes faster than anything else.

Kind regards,
Erika

On Wed, Sep 20, 2017 at 7:56 PM, Kavouss Arasteh <kavouss.arasteh at gmail.com>
wrote:

> Dear Erika,
> I do not understand the European ban or sanctuion.
> There is no basis for such ban or sanction
> I request that this issue be included in the introductory part of the
> report 7 OFAC Rec. and be reflected, where possible, in the recommand part.
> I hope people now recognized that we are real victim on this issue.
> Pls kindly look at the matter and also ask Louisewees ( Board Mmember ) to
> check
> Regards
> Kavouss
>
> On Wed, Sep 20, 2017 at 7:01 PM, Erika Mann <erika at erikamann.com> wrote:
>
>> 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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>>>
>>
>
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