[registrars] US Registrars - OFAC Updates

[Richard Lau]

Would "engaging in trade or provision of service" include being the
registrar to such a domain?

IE eNom is the registrar of: CUBA-ECOTOURISM.COM, ABOUTCUBA.COM, and others
(but the Registrant appears to be in Tortola, not Cuba)

For that matter, isn't Verisign ultimately providing service to these
domains, so no matter the jurisdiction of the Registrar, the felony problem
for any .com domains always involves Verisign?



Richard  



-----Original Message-----
From: owner-registrars at gnso.icann.org
[mailto:owner-registrars at gnso.icann.org] On Behalf Of Paul Goldstone
Sent: 03 October, 2007 7:57 AM
To: john at johnberryhill.com
Cc: 'Registrars Constituency'
Subject: Re: [registrars] US Registrars - OFAC Updates


John,

It seems unusual that the government would post a list of domains that 
were obviously registered at a US based registry, and state that it's 
a federal offense for US companies to provide services to them.  Many 
of those domains are years old, and already listed on numerous search 
engine and websites too.  If the situation was as serious as making it 
a federal felony, why wouldn't they just get the domains revoked and 
be done with it?

~Paul
:DomainIt


At 01:56 AM 10/3/2007, John Berryhill wrote:


>The United States Department of the Treasury, Office of Foreign Asset
>Control (OFAC) has made a number of updates to the list of Specially
>Designated Nationals (SDN's) with whom engaging in trade or provisions of
>services is a federal felony.  The SDN list is separate from the country
>sanction programs also administered by OFAC.
>
>Some time ago, OFAC began including specific domain names as SDN's.  The
>first of these was kahane.net, but the list has grown much longer to
include
>entities listed en masse as a single entity such as:
>
>WWW.CUBA-ECOTOURISM.COM (a.k.a. GO CUBA PLUS; a.k.a. T&M
>INTERNATIONAL LTD.; a.k.a. TOUR & MARKETING INTERNATIONAL LTD.;
>a.k.a. WWW.ABOUTCUBA.COM; a.k.a. WWW.BONJOURCUBA.COM; a.k.a.
>WWW.CIAOCUBA.COM; a.k.a. WWW.CIGARSSUPERSTORE.COM; a.k.a.
>WWW.CUBAADVICE.COM; a.k.a. WWW.CUBA-BARACOA.COM; a.k.a. WWW.CUBA-
>BAYAMO.COM; a.k.a. WWW.CUBA-CAMAGUEY.COM; a.k.a. WWW.CUBA-
>CAYOCOCO.COM; a.k.a. WWW.CUBA-CAYOGUILLERMO.COM; a.k.a. WWW.CUBA-
>CAYOLARGO.COM; a.k.a. WWW.CUBA-CAYOLEVISA.COM; a.k.a. WWW.CUBA-
>CAYOSABINAL.COM; a.k.a. WWW.CUBA-CAYOSAETIA.COM; a.k.a. WWW.CUBA-
>CAYOSANTAMARIA.COM; a.k.a. WWW.CUBA-CHE.COM; a.k.a. WWW.CUBA-
>CIEGODEAVILA.COM; a.k.a. WWW.CUBA-CIENFUEGOS.COM; a.k.a. WWW.CUBA-
>ELGUEA.COM; a.k.a. WWW.CUBAFIRST.COM; a.k.a. WWW.CUBAFUN.COM;
>a.k.a. WWW.CUBA-GIRON.COM; a.k.a. WWW.CUBA-GRANMA.COM; a.k.a.
>WWW.CUBA-GUAMA.COM; a.k.a. WWW.CUBA-GUARDALAVACA.COM; a.k.a.
>WWW.CUBA-HAVANACITY.COM; a.k.a. WWW.CUBA-HEMINGWAY.COM; a.k.a.
>WWW.CUBA-HOLGUIN.COM; a.k.a. WWW.CUBA-ISLADELAJUVENTUD.COM; a.k.a.
>WWW.CUBA-JARDINESDELEREY.COM; a.k.a. WWW.CUBA-LAHABANA.COM; a.k.a.
>WWW.CUBA-LASTUNAS.COM; a.k.a. WWW.CUBA-MATANZAS.COM; a.k.a.
>WWW.CUBANBASEBALLTRAVEL.COM; a.k.a. WWW.CUBANCULTURE.COM; a.k.a.
>WWW.CUBA-OLDHAVANA.COM; a.k.a. WWW.CUBAONE.COM; a.k.a. WWW.CUBA-
>PINARDELRIO.COM; a.k.a. WWW.CUBA-SANCTISPIRITUS.COM; a.k.a.
>WWW.CUBA-SANTALUCIA.COM; a.k.a. WWW.CUBA-SANTIAGODECUBA.COM; a.k.a.
>WWW.CUBA-SHOPPING.COM; a.k.a. WWW.CUBA-SOROA.COM; a.k.a.
>WWW.CUBASPORTS.COM; a.k.a. WWW.CUBA-TOPESDECOLLANTES.COM; a.k.a.
>WWW.CUBATRAVELDIRECTORY.COM; a.k.a. WWW.CUBA-TRINIDAD.COM; a.k.a.
>WWW.CUBA-VARADEROBEACH.COM; a.k.a. WWW.CUBA-VILLACLARA.COM; a.k.a.
>WWW.CUBAVIP.COM; a.k.a. WWW.CUBA-WEATHER.COM; a.k.a.
>WWW.GOCUBA.COM; a.k.a. WWW.GOCUBA.CU; a.k.a. WWW.GOCUBAPLUS.COM;
>a.k.a. WWW.IPIXCUBA.COM; a.k.a. WWW.NO.GOCUBAPLUS.COM; a.k.a.
>WWW.REALESTATECUBA.COM; a.k.a. WWW.TOURANDMARKETING.COM; a.k.a.
>WWW.VAMOSACUBA.COM), Ellen L. Skelton Building, 4th Floor, Fishers
>Estate, P.O. Box 3820, Road Town, Tortola, Virgin Islands, British;
>P.O. Box 24258, London, England SE9 1WS, United Kingdom; Hotel
>Acuario, Suite 3511, Marina Hemingway, Santa Fe, Playa, Havana,
>Cuba; Hotel Acuario, Suite 3541, Marina Hemingway, Santa Fe, Playa,
>Havana, Cuba; Hotel Acuario, Suite 3542, Marina Hemingway, Santa
>Fe, Playa, Havana, Cuba; Hotel Viejo y el Mar, Suite 6005, Marina
>Hemingway, Playa, Havana, Cuba; Calle 12 y Mar, Varadero Matanzas,
>Cuba; Calle Ramon Pino, No. 4, 38650, Los Cristianos, Arona,
>Tenerife, Spain [CUBA]
>
>The full list of SDN's is located here:
>
>http://www.treas.gov/offices/enforcement/ofac/sdn/sdnlist.txt
>
>
>
>John Berryhill, Ph.d., Esq.
>4 West Front St. 
>Media, PA  19063
>(610) 565-5601
>(267) 386-8115 fax