[Ws2-jurisdiction] [EXTERNAL] Re: [Ext] RES: OFAC Recommendation -- Further Suggested Revisions
Burr, Becky
Becky.Burr at team.neustar
Fri Sep 22 18:04:10 UTC 2017
I feel less equivocal than the rest of the US lawyers on this list, apparently. The OFAC rules apply to “US Persons” and the Treasury Department rules say:
All U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, all U.S incorporated entities and their foreign branches. In the cases of certain programs, such as those regarding Cuba and North Korea, all foreign subsidiaries owned or controlled by U.S. companies also must comply. Certain programs also require foreign persons in possession of U.S. origin goods to comply.
This definition simply does not support application of the OFAC rules to a contracted party solely due to their contracts with ICANN IMHO.
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From: <ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org>> on behalf of Tijani BEN JEMAA <tijani.benjemaa at topnet.tn<mailto:tijani.benjemaa at topnet.tn>>
Date: Friday, September 22, 2017 at 2:43 PM
To: Paul Rosenzweig <paul.rosenzweig at redbranchconsulting.com<mailto:paul.rosenzweig at redbranchconsulting.com>>
Cc: ws2-jurisdiction <ws2-jurisdiction at icann.org<mailto:ws2-jurisdiction at icann.org>>
Subject: [EXTERNAL] Re: [Ws2-jurisdiction] [Ext] RES: OFAC Recommendation -- Further Suggested Revisions
Thank you Paul,
So, since no firm answer can be given, it is not sure that OFAC doesn’t apply to any of ICANN's contracted parties solely due to their contracts with ICANN, which is a concern in my opinion.
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Tijani BEN JEMAA
Executive Director
Mediterranean Federation of Internet Associations (FMAI)
Phone: +216 98 330 114
+216 52 385 114
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Le 22 sept. 2017 à 13:13, Paul Rosenzweig <paul.rosenzweig at redbranchconsulting.com<mailto:paul.rosenzweig at redbranchconsulting.com>> a écrit :
Hi Tijani
Let me try. You ask “According to the California or US jurisdictions” I assume you mean EITHER the executive branches of those areas or their courts.
As to California – OFAC is a Federal law, so the California state government would have no authority to construe the law or enforce it. As a result, no action to enforce OFAC requirements has ever been brought by California or adjudicated by California courts. Since the law is outside of their scope of reference this is not surprising.
As to the Federal government, its rules regarding the scope of OFAC are set forth in regulations that are discussed in detail in the draft report the group put together. Those regulations do not directly address ICANN (or any other specific business entity) but describe widely the categories and types of people and institutions to which it applies. The US government through the Department of Treasury has never been asked about ICANN’s contracted parties directly and if asked they probably would refuse to answer a hypothetical. So we are left only with the regulations – and as to those, I agree with Sam that the best reading of them is that they apply to ICANN but not the contracted parties (unless the contracted parties are themselves US companies independently subject to OFAC).
Since no enforcement action has ever been brought against ICANN or a contracted party in a US court, no US court has ever answered the question you ask
Hope that helps
Paul
Paul Rosenzweig
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From: ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org> [mailto:ws2-jurisdiction-bounces at icann.org] On Behalf Of Tijani BEN JEMAA
Sent: Thursday, September 21, 2017 4:22 PM
To: Samantha Eisner <Samantha.Eisner at icann.org<mailto:Samantha.Eisner at icann.org>>
Cc: ws2-jurisdiction <ws2-jurisdiction at icann.org<mailto:ws2-jurisdiction at icann.org>>
Subject: Re: [Ws2-jurisdiction] [Ext] RES: OFAC Recommendation -- Further Suggested Revisions
Thank you Sam,
You didn’t answer my question which was:
According to the California and US jurisdictions, does OFAC apply to any of ICANN's contracted parties solely due to their contracts with ICANN?
I will very much appreciate a clear and to the point answer.
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Tijani BEN JEMAA
Executive Director
Mediterranean Federation of Internet Associations (FMAI)
Phone: +216 98 330 114
+216 52 385 114
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Le 21 sept. 2017 à 20:45, Samantha Eisner <Samantha.Eisner at icann.org<mailto:Samantha.Eisner at icann.org>> a écrit :
ICANN cannot and does not obligate its contracted parties to follow OFAC regulations. ICANN requires them to follow applicable laws.
—
Samantha Eisner
Deputy General Counsel, ICANN
12025 Waterfront Drive, Suite 300
Los Angeles, California 90094
USA
Direct Dial: +1 310 578 8631
From: Tijani BEN JEMAA <tijani.benjemaa at topnet.tn<mailto:tijani.benjemaa at topnet.tn>>
Date: Wednesday, September 20, 2017 at 3:20 PM
To: Seun Ojedeji <seun.ojedeji at gmail.com<mailto:seun.ojedeji at gmail.com>>
Cc: Samantha Eisner <samantha.eisner at icann.org<mailto:samantha.eisner at icann.org>>, ws2-jurisdiction <ws2-jurisdiction at icann.org<mailto:ws2-jurisdiction at icann.org>>
Subject: [Ext] Re: [Ws2-jurisdiction] RES: OFAC Recommendation -- Further Suggested Revisions
Thank you Samantha,
You said « ICANN agrees that OFAC does not apply to any of ICANN's contracted parties solely due to a contract with ICANN. ». Does that mean that according to the California and US jurisdictions, OFAC does not apply to any of ICANN's contracted parties solely due to a contract with ICANN?
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Tijani BEN JEMAA
Executive Director
Mediterranean Federation of Internet Associations (FMAI)
Phone: +216 98 330 114
+216 52 385 114
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Le 20 sept. 2017 à 21:44, Seun Ojedeji <seun.ojedeji at gmail.com<mailto:seun.ojedeji at gmail.com>> a écrit :
Thanks a lot for that helpful response Samantha!
Regards
Sent from my mobile
Kindly excuse brevity and typos
On Sep 20, 2017 9:37 PM, "Samantha Eisner" <Samantha.Eisner at icann.org<mailto:Samantha.Eisner at icann.org>> wrote:
Hi Seun -
To your question below, and as noted in my presentation to the Jurisdiction group below, ICANN agrees that OFAC does not apply to any of ICANN's contracted parties solely due to a contract with ICANN. However, ICANN cannot provide any advice to a contracted party as to which laws and regulations are (or are not) applicable, and each contracted party is responsible for understanding that as part of their business operations.
Sam
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Samantha Eisner
Deputy General Counsel, ICANN
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From:ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org> <ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org>> on behalf of Seun Ojedeji <seun.ojedeji at gmail.com<mailto:seun.ojedeji at gmail.com>>
Sent: Wednesday, September 20, 2017 1:17 PM
To: Mueller, Milton L
Cc: ws2-jurisdiction
Subject: Re: [Ws2-jurisdiction] RES: OFAC Recommendation -- Further Suggested Revisions
Sent from my mobile
Kindly excuse brevity and typos
On Sep 20, 2017 4:03 PM, "Mueller, Milton L" <milton at gatech.edu<mailto:milton at gatech.edu>> wrote:
We do ask ICANN to clarify that registrars do not need to follow OFAC sanctions simply due to their contracts with ICANN, and that is important.
SO: Can we get ICANN legal to respond to the above as I think it will help someone like myself move from sitting on the fence on this particular topic.
Regards
From:ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org> [mailto:ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org>] On Behalf Of Kavouss Arasteh
Sent: Wednesday, September 20, 2017 10:48 AM
To: Thiago Braz Jardim Oliveira <thiago.jardim at itamaraty.gov.br<mailto:thiago.jardim at itamaraty.gov.br>>; Thomas Rickert <rickert at anwaelte.de<mailto:rickert at anwaelte.de>>; León Felipe Sánchez Ambía <leonfelipe at sanchez.mx<mailto:leonfelipe at sanchez.mx>>; Jordan Carter <jordan at internetnz.net.nz<mailto:jordan at internetnz.net.nz>>
Cc: ws2-jurisdiction at icann.org<mailto:ws2-jurisdiction at icann.org>
Subject: Re: [Ws2-jurisdiction] RES: OFAC Recommendation -- Further Suggested Revisions
Deaar Thiago, Dear Jorge,
Thanks to your positive r3sponse .I am waiting for Greg to resolve the issue.
I strongly oppose to the unilateral removal of the last paragraph as result of off line exchange of views between two or three individual.
We should be transparent
We should listen to each other.We should consider problems of others
Tks
Regards
Kavouss
On Wed, Sep 20, 2017 at 3:46 PM, Thiago Braz Jardim Oliveira <thiago.jardim at itamaraty.gov.br<mailto:thiago.jardim at itamaraty.gov.br>> wrote:
Dear Greg,
I add my voice to Jorge's suggestion and look forward to an agreeable solution.
Best,
Thiago
-----Mensagem original-----
De: ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org> [mailto:ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org>] Em nome de Jorge.Cancio at bakom.admin.ch<mailto:Jorge.Cancio at bakom.admin.ch>
Enviada em: quarta-feira, 20 de setembro de 2017 05:10
Para: gregshatanipc at gmail.com<mailto:gregshatanipc at gmail.com>
Cc: ws2-jurisdiction at icann.org<mailto:ws2-jurisdiction at icann.org>
Assunto: Re: [Ws2-jurisdiction] OFAC Recommendation -- Further Suggested Revisions
Dear Greg,
would it be possible that Kavouss' concerns are addressed by you also bilaterally as he seems not to be satisfied with these explanations, This could help avoiding any misunderstanding?
I feel we are very close to consensus and such an effort would most probably be helpful in order to allow all to be on board.
kind regards
Jorge
________________________________
Von: Greg Shatan <gregshatanipc at gmail.com<mailto:gregshatanipc at gmail.com>>
Datum: 20. September 2017 um 07:25:56 MESZ
An: Arasteh <kavouss.arasteh at gmail.com<mailto:kavouss.arasteh at gmail.com>>
Cc: ws2-jurisdiction <ws2-jurisdiction at icann.org<mailto:ws2-jurisdiction at icann.org>>
Betreff: Re: [Ws2-jurisdiction] OFAC Recommendation -- Further Suggested Revisions
All,
I wanted to reflect in this email thread how the various topics in the paragraph submitted by Kavouss for potential inclusion in the "General License" recommendation have been dealt with in the document. Here are the different sections of the text, followed by my notes in italics.
Generally, ICANN must pursue the application for general license at earliest time and should advertise and communicate with registries and registrars to revise their registrant agreements and not to copy and paste the general agreements found in US-based registrars. The role of ICANN, to make awareness about such situation is critical and should not be undermined.
This is now covered in the section on General Licenses, so this is not needed here.
There are several reports in the media that US-Based and Non-US registrars have asked registrants to transfer out their domains immediately because they might get affected by US sanctions.
This is not related to General Licenses, so it should not be included in that recommendation. Regarding non-US registrars: This issue is generally discussed in the section "Application of OFAC Limitations by Non-US Registrars." If the Subgroup receives media reports of non-US registrars taking such actions and it appears there may be no legal basis for these actions, we could cite them in this section. Since the Subgroup has not seen the reports mentioned here, we do not have any basis to include this sentence, and so it is not included.
Regarding US registrars, who have OFAC compliance obligations, there does not appear to be an issue that falls within the purview of the Subgroup. It may well be that these registrars are complying with their legal obligations (or seeking to become compliant with their legal obligations).
Samples of that are related to Godaddy and Online Nic, which made pressure against registrants having Iranian citizenship.
These are both US-based registrars, who are required to comply with OFAC sanctions. As noted above, it may well be that these registrars are complying with their legal obligations (or seeking to become compliant with their legal obligations). This does not fit with the issue discussed in this report, which relates to mistaken application of OFAC sanctions by non-US registrars, so it is not included.
To determine the nature of registrant, registrars usually refer to Admin contact details recorded in whois database. If admin address and phone number is related to sanctioned countries, it is assumed that domain owner is a hidden risk for the registrar, therefore registrars try to examine zero risk policy in regard of penalties imposed by OFAC.
This is not related to the General License either. This seems to be directed toward registrars' business practices and business judgment. Without commenting on the validity of the issue, this would not appear to be an issue for this Subgroup or the CCWG. Furthermore, if these are registrars with OFAC compliance obligations, then it may well be that these registrars are complying with their legal obligations. If these are non-US registrars without OFAC compliance obligations, then this issue is covered generally under "Application of OFAC Limitations by Non-US Registrars." As such the paragraph is not included.
Best regards,
Greg
On Tue, Sep 19, 2017 at 1:30 AM, Arasteh <kavouss.arasteh at gmail.com<mailto:kavouss.arasteh at gmail.com><mailto:kavouss.arasteh at gmail.com<mailto:kavouss.arasteh at gmail.com>>> wrote:
Dear Paul
Thank you very much for your comments
I am open to soften the text as you suggested e.g. to replace " prove " by " determine" and the term"must" be a less stronger term such as" need" which is between must/ shall/ and may However, due to the fact that we are severely affected by the process, may I humbly request you to kindly agree to retain the idea with slightly modified text to also be agreeable to you.
I am jerky awaiting to receive your fair suggestion as soon possible Regards Kavouss
Sent from my iPhone
On 19 Sep 2017, at 02:16, Paul Rosenzweig <paul.rosenzweig at redbranchconsulting.com<mailto:paul.rosenzweig at redbranchconsulting.com><mailto:paul.rosenzweig at redbranchconsulting.com<mailto:paul.rosenzweig at redbranchconsulting.com>>> wrote:
All
Given the lateness with which we received Kavouss's suggested paragraph and revisions and the fact that I, regretfully, could not make the call, let me note my disagreement with two aspects of it:
First, on page 5, it is suggested that a survey be undertaken to "prove" that non-US registrars are imposing OFAC requirements. Since the point of the survey is to determine what is true, it is premature to assume that it will "prove" the facts assumed by the proposer. The word "prove" is therefore in error and should be replaced by "determent whether"
Second, I oppose the proposed new paragraph at the end simply because, as written, I have absolutely no idea what is meant. But use of terms like "must" as an imperative are always inappropriate in recommendations. Insofar as I can discern the intent (that there is some action being taken by registries against registrants) that issue is a new one that needs to be fully discussed and it is, of course, quite different from the OFAC general license idea for ICANN that we have been discussing (which would only relate to ICANN's on RAA agreements).
Paul
Paul Rosenzweig
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From: ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org><mailto:ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org>> [mailto:ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdiction-bounces at icann.org>] On Behalf Of Greg Shatan
Sent: Monday, September 18, 2017 2:13 PM
To: ws2-jurisdiction <ws2-jurisdiction at icann.org<mailto:ws2-jurisdiction at icann.org><mailto:ws2-jurisdiction at icann.org<mailto:ws2-jurisdiction at icann.org>>>
Subject: Re: [Ws2-jurisdiction] OFAC Recommendation -- Further Suggested Revisions
CORRECTED VERSION ATTACHED. A paragraph suggested by Kavouss, which is in the Google Doc, did not show up in the Word document (nor in the PDF, which is based on the Word doc). Corrected versions are attached. Thank you to Kavouss for catching this. Please see the last paragraph in the document so that you can review this suggested text.
Also, some crossed-out text at the very end that was supposed to be deleted (as noted on last week's call) has now been deleted from the attached (and the Google Doc).
Greg
On Mon, Sep 18, 2017 at 1:42 PM, Greg Shatan <gregshatanipc at gmail.com<mailto:gregshatanipc at gmail.com><mailto:gregshatanipc at gmail.com<mailto:gregshatanipc at gmail.com>>> wrote:
All,
I have attached a further revised OFAC Recommendation, reflecting changes suggested by Kavouss Arasteh and Seun Ojedeji. Word and PDF versions are attached, and the Google Doc reflects these suggested changes as well.
I look forward to our call.
Best regards,
Greg
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