[Ws2-jurisdiction] [EXTERNAL] Re: [Ext] RES: OFAC Recommendation -- Further Suggested Revisions

Seun Ojedeji seun.ojedeji at gmail.com
Tue Sep 26 15:15:09 UTC 2017 

Wew! Now am lost on all the Res*  :-)

Anyway my general view on OFAC is that I am strongly for an OFAC immune
ICANN but don't care much about OFAC immune Registry[1]

Regards
1. Except the root maintainer.
Sent from my mobile
Kindly excuse brevity and typos

On Sep 26, 2017 4:06 PM, "Greg Shatan" <gregshatanipc at gmail.com> wrote:

> Resello is not Reseller Club.
>
> On Tue, Sep 26, 2017 at 10:48 AM, Seun Ojedeji <seun.ojedeji at gmail.com>
> wrote:
>
>> Hello Greg,
>>
>> Sent from my mobile
>> Kindly excuse brevity and typos
>>
>> On Sep 26, 2017 3:27 PM, "Greg Shatan" <gregshatanipc at gmail.com> wrote:
>>
>> Seun,
>>
>> It seemed clear to me, from both Kavouss's and Farzaneh's emails, that
>> Resello is a Dutch entity.  Can you point to the language you are relying
>> on?
>>
>>
>> SO: Here is the text I was relying on:
>>
>> "...But Resello history is interesting to know. Reseller Club was a
>> *US-India entity*. Many businesses and other registrants in Iran had
>> registered their domain name with them. 4 years ago Reseller club decided
>> *to move completely to the US*...."
>>
>>
>> In any event, if it were a US-based entity, I believe your position is
>> consistent with the Subgroup's view.
>>
>>
>> SO: If indeed it were US based then Yes. My rationale is that ICANN is
>> globally unique hence should be OFAC immune. Resello isn't unique as there
>> are other options, so if US decides to limit business of her tax payers as
>> such so be it. Registrants can "easily" look for a non-US entity to do
>> business with and indirectly pay tax to such entity's country of
>> incoporation.
>>
>> Regards
>>
>>
>> Greg
>>
>> On Tue, Sep 26, 2017 at 10:06 AM, Seun Ojedeji <seun.ojedeji at gmail.com>
>> wrote:
>>
>>> Dear all,
>>>
>>> Based on the background recently provided, it seem resello is a US based
>>> entity so one would expect OFAC to apply just like it does for ICANN.
>>>
>>> Should ICANN then be the one to ask for a waiver for resello? I don't
>>> think so.
>>>
>>> Regards
>>> Sent from my mobile
>>> Kindly excuse brevity and typos
>>>
>>> On Sep 26, 2017 2:13 PM, "Paul Rosenzweig" <
>>> paul.rosenzweig at redbranchconsulting.com> wrote:
>>>
>>>> As I read it they said “our policy” not “our national policy” – and in
>>>> any event “our national policy” might very well mean “the policy we follow
>>>> nation-wide” and not “the policy our national government imposes.”
>>>>
>>>>
>>>>
>>>> P
>>>>
>>>>
>>>>
>>>> Paul Rosenzweig
>>>>
>>>> paul.rosenzweig at redbranchconsulting.com
>>>>
>>>> O: +1 (202) 547-0660 <+1%20202-547-0660>
>>>>
>>>> M: +1 (202) 329-9650 <+1%20202-329-9650>
>>>>
>>>> VOIP: +1 (202) 738-1739 <+1%20202-738-1739>
>>>>
>>>> www.redbranchconsulting.com
>>>>
>>>> My PGP Key: https://keys.mailvelope.com/pk
>>>> s/lookup?op=get&search=0x9A830097CA066684
>>>>
>>>>
>>>>
>>>> *From:* ws2-jurisdiction-bounces at icann.org [mailto:
>>>> ws2-jurisdiction-bounces at icann.org] *On Behalf Of *Kavouss Arasteh
>>>> *Sent:* Tuesday, September 26, 2017 8:51 AM
>>>> *To:* Burr, Becky <Becky.Burr at team.neustar>; ws2-jurisdiction <
>>>> ws2-jurisdiction at icann.org>
>>>> *Subject:* Re: [Ws2-jurisdiction] [EXTERNAL] Re: [Ext] RES: OFAC
>>>> Recommendation -- Further Suggested Revisions
>>>>
>>>>
>>>>
>>>> Dear Beckie
>>>>
>>>> Yes pls read the text as he said " *based on our national Policy *
>>>> ......"
>>>>
>>>> Kavouss
>>>>
>>>>
>>>>
>>>> On Tue, Sep 26, 2017 at 2:04 PM, Burr, Becky <Becky.Burr at team.neustar>
>>>> wrote:
>>>>
>>>> Could someone clarify one point for me?  Did the Registrar
>>>> affirmatively state that it was unwilling to work with Iranian reseller
>>>> because of OFAC?  Or  it that an assumption only?
>>>>
>>>> Becky Burr
>>>>
>>>> Sent from my iPhone
>>>>
>>>>
>>>> On Sep 26, 2017, at 18:26, Kavouss Arasteh <kavouss.arasteh at gmail.com>
>>>> wrote:
>>>>
>>>> Dear Greg
>>>>
>>>> Thanks
>>>>
>>>> The issue is that the Registrar refusal to get involved in the business
>>>> apparently and perhaps  actually  resulted from misinterpretation of OFAC
>>>> Regulations as that Registrar was over prudent to totally exclude any
>>>> likelihood of application of OFAC by US to the case .
>>>>
>>>> If in the view of the group , see the compilation of views by all of
>>>> you as conveyed to you as a cut and paste text  , there is no link between
>>>> the request and OFAC then it should be explained  that such irrelevance of
>>>> the refusal to OFAC as the refusal seemed to have been based on the
>>>>  misinterpretation of the Registrar  that there might have been a relation
>>>> thereto
>>>>
>>>> Then, the group  while confirming  that  inapplicability of OFAC to the
>>>> case needs to (to be mentioned in the document  to clarify the matter for
>>>> the case and for any future misinterpretation.
>>>>
>>>> Moreover, the group needs to mention that the need to verify whether
>>>> there is a clear provision in the RAA to obligate the Registrar to enter
>>>> into business with registrant or there is no provision to authorise it to
>>>> refuse ,i.e. silent situation in RAA . In that case the Group while
>>>> excluding the applicability or relation between the request and OFAC
>>>> recommend ICANN to examine the matter and take necessary action, as
>>>> appropriate
>>>>
>>>> Regards
>>>>
>>>> Kavouss
>>>>
>>>>
>>>>
>>>> On Tue, Sep 26, 2017 at 9:02 AM, Greg Shatan <gregshatanipc at gmail.com>
>>>> wrote:
>>>>
>>>> Kavouss,
>>>>
>>>>
>>>>
>>>> It might help Paul and others to understand your point if you could
>>>> explain your three points, specifically:
>>>>
>>>> a) Why it is necessary to include this case/anecdote in the OFAC
>>>> Recommendation
>>>>
>>>> b) Why it is relevant to the OFAC Recommendation that Resello's
>>>> decision could *not* be attributed to OFAC applicability
>>>>
>>>> c) Why it is relevant to the OFAC Recommendation that the RAA has no
>>>> obligation for the Registrar to enter into the requested Reseller agreement
>>>>
>>>>
>>>>
>>>> Best regards,
>>>>
>>>>
>>>>
>>>> Greg
>>>>
>>>>
>>>>
>>>> On Tue, Sep 26, 2017 at 1:04 AM, Arasteh <kavouss.arasteh at gmail.com>
>>>> wrote:
>>>>
>>>> Paul
>>>>
>>>> You have never ever Been at loss
>>>>
>>>> This addition is necessary to address the case as contained in my
>>>> suggestion as further elaborated in the sense a) to include the case as
>>>> reported , b) to mention that the refusal of Resello could not be
>>>> attributed to the likelihood of OFAC applicability and c) to Mention that
>>>> RAA is silent in obligation of Registrar to enter into business with
>>>> requérant of domain name purchase as well as its refusal
>>>>
>>>> I hope it is clear
>>>>
>>>> Tks
>>>>
>>>> Kavouss
>>>>
>>>>
>>>> Sent from my iPhone
>>>>
>>>>
>>>> On 26 Sep 2017, at 00:57, Paul Rosenzweig <
>>>> paul.rosenzweig at redbranchconsulting.com> wrote:
>>>>
>>>> We already have .. at some length.  I confess in this instance I really
>>>> am at a loss as to what more is desired.
>>>>
>>>>
>>>>
>>>> Paul
>>>>
>>>>
>>>>
>>>> Paul Rosenzweig
>>>>
>>>> paul.rosenzweig at redbranchconsulting.com
>>>>
>>>> O: +1 (202) 547-0660 <(202)%20547-0660>
>>>>
>>>> M: +1 (202) 329-9650 <(202)%20329-9650>
>>>>
>>>> VOIP: +1 (202) 738-1739 <(202)%20738-1739>
>>>>
>>>> www.redbranchconsulting.com
>>>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.redbranchconsulting.com_&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=grvWAwyNT097vY4v9uiI5SpAWPQ9RL3qJnEKLDZJJ4o&e=>
>>>>
>>>> My PGP Key: https://keys.mailvelope.com/pk
>>>> s/lookup?op=get&search=0x9A830097CA066684
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__keys.mailvelope.com_pks_lookup-3Fop-3Dget-26search-3D0x9A830097CA066684&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=QZg6_N_7tZaDa5yi_94NMsyDiQhAX1f-AGdeWkzBOJY&e=>
>>>>
>>>>
>>>>
>>>> *From:* Jorge.Cancio at bakom.admin.ch [mailto:Jorge.Cancio at bakom.admin.ch
>>>> <Jorge.Cancio at bakom.admin.ch>]
>>>> *Sent:* Monday, September 25, 2017 10:25 AM
>>>> *To:* paul.rosenzweig at redbranchconsulting.com; olgacavalli at gmail.com;
>>>> Samantha.Eisner at icann.org
>>>> *Cc:* ws2-jurisdiction at icann.org
>>>> *Subject:* AW: [Ws2-jurisdiction] [Ext] RES: OFAC Recommendation --
>>>> Further Suggested Revisions
>>>>
>>>>
>>>>
>>>> Dear all, dear Paul,
>>>>
>>>>
>>>>
>>>> I guess what is being highlighted is a potential „chilling effect“ that
>>>> could be addressed through improved awareness and communication – something
>>>> we may well mention in this recommendation…
>>>>
>>>>
>>>>
>>>> Kind regards
>>>>
>>>>
>>>>
>>>> Jorge
>>>>
>>>>
>>>>
>>>> *Von:* ws2-jurisdiction-bounces at icann.org [
>>>> mailto:ws2-jurisdiction-bounces at icann.org
>>>> <ws2-jurisdiction-bounces at icann.org>] *Im Auftrag von *Paul Rosenzweig
>>>> *Gesendet:* Montag, 25. September 2017 16:12
>>>> *An:* 'Olga Cavalli' <olgacavalli at gmail.com>; 'Samantha Eisner' <
>>>> Samantha.Eisner at icann.org>
>>>> *Cc:* 'ws2-jurisdiction' <ws2-jurisdiction at icann.org>
>>>> *Betreff:* Re: [Ws2-jurisdiction] [Ext] RES: OFAC Recommendation --
>>>> Further Suggested Revisions
>>>>
>>>>
>>>>
>>>> In the end, the problem is that the question of RAA implementation is a
>>>> completely differerent issue from OFAC.   The real reason this is
>>>> problematic is that an unreleated issue is being shoehorned into an
>>>> existing, otherwise complete, recommendation.
>>>>
>>>>
>>>>
>>>> We should move consideration of the RAA issue raised to a new issue
>>>> subhead in the Subgroup.
>>>>
>>>>
>>>>
>>>> Paul
>>>>
>>>>
>>>>
>>>> Paul Rosenzweig
>>>>
>>>> paul.rosenzweig at redbranchconsulting.com
>>>>
>>>> O: +1 (202) 547-0660 <(202)%20547-0660>
>>>>
>>>> M: +1 (202) 329-9650 <(202)%20329-9650>
>>>>
>>>> VOIP: +1 (202) 738-1739 <(202)%20738-1739>
>>>>
>>>> www.redbranchconsulting.com
>>>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.redbranchconsulting.com_&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=grvWAwyNT097vY4v9uiI5SpAWPQ9RL3qJnEKLDZJJ4o&e=>
>>>>
>>>> My PGP Key: https://keys.mailvelope.com/pk
>>>> s/lookup?op=get&search=0x9A830097CA066684
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__keys.mailvelope.com_pks_lookup-3Fop-3Dget-26search-3D0x9A830097CA066684&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=QZg6_N_7tZaDa5yi_94NMsyDiQhAX1f-AGdeWkzBOJY&e=>
>>>>
>>>>
>>>>
>>>> *From:* ws2-jurisdiction-bounces at icann.org [
>>>> mailto:ws2-jurisdiction-bounces at icann.org
>>>> <ws2-jurisdiction-bounces at icann.org>] *On Behalf Of *Olga Cavalli
>>>> *Sent:* Saturday, September 23, 2017 4:42 PM
>>>> *To:* Samantha Eisner <Samantha.Eisner at icann.org>
>>>> *Cc:* ws2-jurisdiction <ws2-jurisdiction at icann.org>
>>>> *Subject:* Re: [Ws2-jurisdiction] [Ext] RES: OFAC Recommendation --
>>>> Further Suggested Revisions
>>>>
>>>>
>>>>
>>>> Dear all,
>>>>
>>>>
>>>>
>>>> could it be possible to address Mr Araste's concerns?
>>>>
>>>>
>>>>
>>>> perhaps producing a new document with references to comments by himself
>>>> and others?
>>>>
>>>>
>>>>
>>>> This could be very useful for us following the discussion as the thread
>>>> of emails sometimes becomes confusing.
>>>>
>>>>
>>>>
>>>> best regards
>>>>
>>>>
>>>>
>>>> Olga
>>>>
>>>>
>>>>
>>>> 2017-09-22 14:52 GMT-07:00 Samantha Eisner <Samantha.Eisner at icann.org>:
>>>>
>>>> Sorry for the delay in responding - I'm traveling internationally and
>>>> have not been able to stay fully on top of the email traffic.  Greg and
>>>> Paul, thank you for your responses on the issue and for also recognizing
>>>> that the question does reach into providing legal advice that ICANN is not
>>>> in a position to give.  I agree with your analyses.
>>>>
>>>>
>>>>
>>>> As noted, I've previously stated that ICANN agrees that OFAC does not
>>>> apply to any of ICANN's contracted parties solely due to a contract with
>>>> ICANN.
>>>>
>>>>
>>>>
>>>> Contracted parties each need to assess for themselves whether they must
>>>> comply with the OFAC regulations based on whatever business factors they
>>>> choose to take into account.
>>>>
>>>>
>>>>
>>>> ____
>>>>
>>>> Samantha Eisner
>>>>
>>>> Deputy General Counsel, ICANN
>>>>
>>>> 12025 Waterfront Drive, Suite 300
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__maps.google.com_-3Fq-3D12025-2BWaterfront-2BDrive-2C-2BSuite-2B300-5F-5F-5F-5F-2BLos-2BAngeles-2C-2BCalifornia-2B90094-5F-5F-5F-5F-2BUSA-26entry-3Dgmail-26source-3Dg&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=l0zMXq81yFPIhPWH9iYzDLnDtfycIlng1sD9-RJ8UNM&e=>
>>>>
>>>> Los Angeles, California 90094
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__maps.google.com_-3Fq-3D12025-2BWaterfront-2BDrive-2C-2BSuite-2B300-5F-5F-5F-5F-2BLos-2BAngeles-2C-2BCalifornia-2B90094-5F-5F-5F-5F-2BUSA-26entry-3Dgmail-26source-3Dg&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=l0zMXq81yFPIhPWH9iYzDLnDtfycIlng1sD9-RJ8UNM&e=>
>>>>
>>>> USA
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__maps.google.com_-3Fq-3D12025-2BWaterfront-2BDrive-2C-2BSuite-2B300-5F-5F-5F-5F-2BLos-2BAngeles-2C-2BCalifornia-2B90094-5F-5F-5F-5F-2BUSA-26entry-3Dgmail-26source-3Dg&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=l0zMXq81yFPIhPWH9iYzDLnDtfycIlng1sD9-RJ8UNM&e=>
>>>>
>>>> Direct Dial: +1 310 578 8631 <(310)%20578-8631>
>>>> ------------------------------
>>>>
>>>> *From:* ws2-jurisdiction-bounces at icann.org <
>>>> ws2-jurisdiction-bounces at icann.org> on behalf of Greg Shatan <
>>>> gregshatanipc at gmail.com>
>>>> *Sent:* Friday, September 22, 2017 11:09 AM
>>>> *To:* Tijani BEN JEMAA
>>>> *Cc:* ws2-jurisdiction
>>>> *Subject:* Re: [Ws2-jurisdiction] [Ext] RES: OFAC Recommendation --
>>>> Further Suggested Revisions
>>>>
>>>>
>>>>
>>>> Tijani,
>>>>
>>>>
>>>>
>>>> Paul is being a bit lawyerly and careful and emphasizing that there is
>>>> no positive statement in the law or regulations that one can point to and
>>>> say, "this says OFAC doesn’t apply to any of ICANN's contracted parties
>>>> solely due to their contracts with ICANN."  He has also explained that
>>>> there would not be, because that's not how laws work (or regulations,
>>>> except if there were a general license -- but a general license would only
>>>> be needed if the sanctions would otherwise apply).
>>>>
>>>>
>>>>
>>>> Sam is also being careful (and has to be, because ICANN cannot give
>>>> legal advice on OFAC compliance to contracted parties), when she confirms
>>>> that "ICANN cannot and does not obligate its contracted parties to follow
>>>> OFAC regulations."  But consider that Sam also said that "*ICANN
>>>> agrees that OFAC does not apply to any of ICANN's contracted parties solely
>>>> due to a contract with ICANN*."  Considering how careful ICANN has to
>>>> be in not giving legal advice on OFAC compliance, this should be highly
>>>> persuasive.
>>>>
>>>>
>>>>
>>>> Consider also that all contracting parties would be in breach of their
>>>> ICANN contracts if US law required them all to comply with OFAC because
>>>> they have an ICANN contract and they did not do so.  Do you think ICANN or
>>>> the US government would tolerate such widespread violation of law and
>>>> breach of contract?
>>>>
>>>>
>>>>
>>>> Like Becky I'll be a little less lawyerly, and say that I can find
>>>> absolutely no basis for concern that OFAC applies to any of ICANN's
>>>> contracted parties solely because they have entered into a contract with
>>>> ICANN.
>>>>
>>>>
>>>>
>>>> Greg
>>>>
>>>>
>>>>
>>>> On Fri, Sep 22, 2017 at 1:43 PM, Tijani BEN JEMAA <
>>>> tijani.benjemaa at topnet.tn> wrote:
>>>>
>>>> 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.
>>>>
>>>>
>>>>
>>>> ------------------------------------------------------------
>>>> -----------------
>>>>
>>>> *Tijani BEN JEMAA*
>>>>
>>>> Executive Director
>>>>
>>>> Mediterranean Federation of Internet Associations (*FMAI*)
>>>>
>>>> Phone: +216 98 330 114 <+216%2098%20330%20114>
>>>>
>>>>             +216 52 385 114 <+216%2052%20385%20114>
>>>>
>>>> ------------------------------------------------------------
>>>> -----------------
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> Le 22 sept. 2017 à 13:13, Paul Rosenzweig <
>>>> 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
>>>>
>>>> paul.rosenzweig at redbranchconsulting.com
>>>>
>>>> O: +1 (202) 547-0660 <(202)%20547-0660>
>>>>
>>>> M: +1 (202) 329-9650 <(202)%20329-9650>
>>>>
>>>> VOIP: +1 (202) 738-1739 <(202)%20738-1739>
>>>>
>>>> www.redbranchconsulting.com[redbranchconsulting.com]
>>>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.redbranchconsulting.com_&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=w1jlqVWntmqtI5dedIDLQ6uBxH_Jh-uBee_4imohzko&m=dYTtbBIgukseIqTDSE_jTP6FcRo3hGEm3jck9IgSNlI&s=FsheHq6zPytklxrdyXT0gBBB9bIiM9n2wk_Fbuglkwg&e=>
>>>>
>>>> My PGP Key: https://keys.mailvelope.com/pks/lookup?op=get&search=0x
>>>> 9A830097CA066684[keys.mailvelope.com]
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__keys.mailvelope.com_pks_lookup-3Fop-3Dget-26search-3D0x9A830097CA066684&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=w1jlqVWntmqtI5dedIDLQ6uBxH_Jh-uBee_4imohzko&m=dYTtbBIgukseIqTDSE_jTP6FcRo3hGEm3jck9IgSNlI&s=5LOM0e7F4IVRj4YB10BUhCEuJx6mKXl3NBgL0KM8-Nk&e=>
>>>>
>>>>
>>>>
>>>> *From:* ws2-jurisdiction-bounces at icann.org [mailto:ws2-jurisdi
>>>> ction-bounces at icann.org <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>
>>>> *Cc:* ws2-jurisdiction <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.
>>>>
>>>>
>>>>
>>>> ------------------------------------------------------------
>>>> -----------------
>>>>
>>>> *Tijani BEN JEMAA*
>>>>
>>>> Executive Director
>>>>
>>>> Mediterranean Federation of Internet Associations (*FMAI*)
>>>>
>>>> Phone: +216 98 330 114 <+216%2098%20330%20114>
>>>>
>>>>             +216 52 385 114 <+216%2052%20385%20114>
>>>>
>>>> ------------------------------------------------------------
>>>> -----------------
>>>>
>>>>
>>>>
>>>> Le 21 sept. 2017 à 20:45, Samantha Eisner <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
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__maps.google.com_-3Fq-3D12025-2BWaterfront-2BDrive-2C-2BSuite-2B300-5F-5F-5F-5F-2BLos-2BAngeles-2C-2BCalifornia-2B90094-5F-5F-5F-5F-2BUSA-26entry-3Dgmail-26source-3Dg&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=l0zMXq81yFPIhPWH9iYzDLnDtfycIlng1sD9-RJ8UNM&e=>
>>>>
>>>> Los Angeles, California 90094
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__maps.google.com_-3Fq-3D12025-2BWaterfront-2BDrive-2C-2BSuite-2B300-5F-5F-5F-5F-2BLos-2BAngeles-2C-2BCalifornia-2B90094-5F-5F-5F-5F-2BUSA-26entry-3Dgmail-26source-3Dg&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=l0zMXq81yFPIhPWH9iYzDLnDtfycIlng1sD9-RJ8UNM&e=>
>>>>
>>>> USA
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__maps.google.com_-3Fq-3D12025-2BWaterfront-2BDrive-2C-2BSuite-2B300-5F-5F-5F-5F-2BLos-2BAngeles-2C-2BCalifornia-2B90094-5F-5F-5F-5F-2BUSA-26entry-3Dgmail-26source-3Dg&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=l0zMXq81yFPIhPWH9iYzDLnDtfycIlng1sD9-RJ8UNM&e=>
>>>>
>>>> Direct Dial: +1 310 578 8631 <(310)%20578-8631>
>>>>
>>>>
>>>>
>>>> *From: *Tijani BEN JEMAA <tijani.benjemaa at topnet.tn>
>>>> *Date: *Wednesday, September 20, 2017 at 3:20 PM
>>>> *To: *Seun Ojedeji <seun.ojedeji at gmail.com>
>>>> *Cc: *Samantha Eisner <samantha.eisner at icann.org>, ws2-jurisdiction <
>>>> 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?
>>>>
>>>>
>>>>
>>>> ------------------------------------------------------------
>>>> -----------------
>>>>
>>>> *Tijani BEN JEMAA*
>>>>
>>>> Executive Director
>>>>
>>>> Mediterranean Federation of Internet Associations (*FMAI*)
>>>>
>>>> Phone: +216 98 330 114 <+216%2098%20330%20114>
>>>>
>>>>             +216 52 385 114 <+216%2052%20385%20114>
>>>>
>>>> ------------------------------------------------------------
>>>> -----------------
>>>>
>>>>
>>>>
>>>> Le 20 sept. 2017 à 21:44, Seun Ojedeji <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>
>>>> 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
>>>>
>>>> ____
>>>>
>>>> Samantha Eisner
>>>>
>>>> Deputy General Counsel, ICANN
>>>>
>>>> 12025 Waterfront Drive, Suite 300[maps.google.com]
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__maps.google.com_-3Fq-3D12025-2BWaterfront-2BDrive-2C-2BSuite-2B300-250D-2BLos-2BAngeles-2C-2BCalifornia-2B90094-250D-2BUSA-26entry-3Dgmail-26source-3Dg&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=w1jlqVWntmqtI5dedIDLQ6uBxH_Jh-uBee_4imohzko&m=9ca8NCIEA-Ax-xcRchljermQjUSdiR0U4i7sHsVe4pU&s=jqlKpYuoR60ghP7UB1YO7aIqTRwXGUJTucqk39U7mRA&e=>
>>>>
>>>> Los Angeles, California 90094[maps.google.com]
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__maps.google.com_-3Fq-3D12025-2BWaterfront-2BDrive-2C-2BSuite-2B300-250D-2BLos-2BAngeles-2C-2BCalifornia-2B90094-250D-2BUSA-26entry-3Dgmail-26source-3Dg&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=w1jlqVWntmqtI5dedIDLQ6uBxH_Jh-uBee_4imohzko&m=9ca8NCIEA-Ax-xcRchljermQjUSdiR0U4i7sHsVe4pU&s=jqlKpYuoR60ghP7UB1YO7aIqTRwXGUJTucqk39U7mRA&e=>
>>>>
>>>> USA[maps.google.com]
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__maps.google.com_-3Fq-3D12025-2BWaterfront-2BDrive-2C-2BSuite-2B300-250D-2BLos-2BAngeles-2C-2BCalifornia-2B90094-250D-2BUSA-26entry-3Dgmail-26source-3Dg&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=w1jlqVWntmqtI5dedIDLQ6uBxH_Jh-uBee_4imohzko&m=9ca8NCIEA-Ax-xcRchljermQjUSdiR0U4i7sHsVe4pU&s=jqlKpYuoR60ghP7UB1YO7aIqTRwXGUJTucqk39U7mRA&e=>
>>>>
>>>> Direct Dial: +1 310 578 8631 <+1%20310-578-8631>
>>>> ------------------------------
>>>>
>>>> *From:*ws2-jurisdiction-bounces at icann.org <ws2-jurisdiction-bo
>>>> unces at icann.org> on behalf of Seun Ojedeji <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> 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-jurisdic
>>>> tion-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>;
>>>> Thomas Rickert <rickert at anwaelte.de>; León Felipe Sánchez Ambía <
>>>> leonfelipe at sanchez.mx>; Jordan Carter <jordan at internetnz.net.nz>
>>>> *Cc:* 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> 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-jurisdict
>>>> ion-bounces at icann.org] Em nome de Jorge.Cancio at bakom.admin.ch
>>>> Enviada em: quarta-feira, 20 de setembro de 2017 05:10
>>>> Para: gregshatanipc at gmail.com
>>>> Cc: 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>
>>>> Datum: 20. September 2017 um 07:25:56 MESZ
>>>> An: Arasteh <kavouss.arasteh at gmail.com>
>>>> Cc: ws2-jurisdiction <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<mai
>>>> lto: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.rosenzw
>>>> eig 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
>>>> paul.rosenzweig at redbranchconsulting.com<mailto:paul.rosenzwe
>>>> ig at redbranchconsulting.com>
>>>> O: +1 (202) 547-0660 <+1%20202-547-0660><tel:(202)%20547-0660
>>>> <(202)%20547-0660>>
>>>> M: +1 (202) 329-9650 <+1%20202-329-9650><tel:(202)%20329-9650
>>>> <(202)%20329-9650>>
>>>>
>>>> VOIP: +1 (202) 738-1739 <+1%20202-738-1739><tel:(202)%20738-1739
>>>> <(202)%20738-1739>> www.redbranchconsulting.com[r
>>>> edbranchconsulting.com]
>>>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.redbranchconsulting.com&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=w1jlqVWntmqtI5dedIDLQ6uBxH_Jh-uBee_4imohzko&m=SSg9DqnAreY7rqmepf941C1TwRABY8LDqML_434HenE&s=v-k9kgNfbevSG1hsn5C_hu8J81Lt2LmdyMcrbvhL3e8&e=>
>>>> <http://www.redbranchconsulting.com/[redbranchconsulting.com]
>>>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.redbranchconsulting.com_&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=w1jlqVWntmqtI5dedIDLQ6uBxH_Jh-uBee_4imohzko&m=SSg9DqnAreY7rqmepf941C1TwRABY8LDqML_434HenE&s=HnmhcBwRiPc7pnKaGKkyyI8tqyDISzgIfxYVHliaAzU&e=>
>>>> >
>>>> My PGP Key: https://keys.mailvelope.com/pks/lookup?op=get&search=0x
>>>> 9A830097CA066684[keys.mailvelope.com]
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__keys.mailvelope.com_pks_lookup-3Fop-3Dget-26search-3D0x9A830097CA066684&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=w1jlqVWntmqtI5dedIDLQ6uBxH_Jh-uBee_4imohzko&m=SSg9DqnAreY7rqmepf941C1TwRABY8LDqML_434HenE&s=3dySAIxgq5-Bu6Q6V_dX3UG4LDr_Xc36YIrFFDwE5L0&e=>
>>>>
>>>>
>>>>
>>>> From: ws2-jurisdiction-bounces at icann.org<mailto:ws2-jurisdic
>>>> tion-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>>
>>>> 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>> 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
>>>>
>>>> _______________________________________________
>>>> Ws2-jurisdiction mailing list
>>>> Ws2-jurisdiction at icann.org<mailto:Ws2-jurisdiction at icann.org>
>>>> https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_ws2-2Djurisdiction&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=5MBhZo9ZQ16Oh9-oTT0ueNZBLLEhBYLfWOsCUtn-yqU&e=>
>>>>
>>>> _______________________________________________
>>>> Ws2-jurisdiction mailing list
>>>> Ws2-jurisdiction at icann.org
>>>> https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_ws2-2Djurisdiction&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=5MBhZo9ZQ16Oh9-oTT0ueNZBLLEhBYLfWOsCUtn-yqU&e=>
>>>> _______________________________________________
>>>> Ws2-jurisdiction mailing list
>>>> Ws2-jurisdiction at icann.org
>>>> https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_ws2-2Djurisdiction&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=5MBhZo9ZQ16Oh9-oTT0ueNZBLLEhBYLfWOsCUtn-yqU&e=>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> _______________________________________________
>>>> Ws2-jurisdiction mailing list
>>>> Ws2-jurisdiction at icann.org
>>>> https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_ws2-2Djurisdiction&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=5MBhZo9ZQ16Oh9-oTT0ueNZBLLEhBYLfWOsCUtn-yqU&e=>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> _______________________________________________
>>>> Ws2-jurisdiction mailing list
>>>> Ws2-jurisdiction at icann.org
>>>> https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_ws2-2Djurisdiction&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=5MBhZo9ZQ16Oh9-oTT0ueNZBLLEhBYLfWOsCUtn-yqU&e=>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> _______________________________________________
>>>> Ws2-jurisdiction mailing list
>>>> Ws2-jurisdiction at icann.org
>>>> https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
>>>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_ws2-2Djurisdiction&d=DwMFaQ&c=MOptNlVtIETeDALC_lULrw&r=62cJFOifzm6X_GRlaq8Mo8TjDmrxdYahOP8WDDkMr4k&m=Jfd6XppNR7epMjIOy8D72ZpL7AqIw_wnhitKzx-slBM&s=5MBhZo9ZQ16Oh9-oTT0ueNZBLLEhBYLfWOsCUtn-yqU&e=>
>>>>
>>>>
>>>>
>>>>
>>>> _____________________
>>>>
>>>>
>>>> _______________________________________________
>>>> Ws2-jurisdiction mailing list
>>>> Ws2-jurisdiction at icann.org
>>>> https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
>>>>
>>>> ...
>>>
>>>
>>> _______________________________________________
>>> Ws2-jurisdiction mailing list
>>> Ws2-jurisdiction at icann.org
>>> https://mm.icann.org/mailman/listinfo/ws2-jurisdiction
>>>
>>>
>>
>>
>
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