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RIPE Cooperation Working Group Interim Session: Open Discussion on Internet Sanctions and Connectivity

WG co-Chairs: Achilleas Kemos, Johan Helsingius, Desiree Miloshevic

On 22 March 2022 from 14:00 to 15:30 (UTC+1), the RIPE Cooperation Working Group will hold a remote session via Zoom.


Session Description

The current war in Ukraine has raised a lot of discussion and concern around the application of Internet-related sanctions and their effects on the Internet and the broader community. To better understand the different positions, proposals, priorities and trade-offs, the RIPE Cooperation Working Group will hold a 90-minute remote session to hear from some of the individuals involved, and provide a space for open conversation. 


  • Niels ten Oever, University of Amsterdam
  • Marina Kaljurand, Member of European Parliament
  • Bart Groothuis, Member of European Parliament
  • Daniel Karrenberg, RIPE NCC
  • Mallory Knodel, Center for Democracy & Technology
  • Farzaneh Badii, Digital Medusa

Relevant documents

Session Minutes

RIPE Cooperation Working Group Remote Session: Open Discussion on Internet Sanctions and Connectivity 

22 March 2022 from 14:00 to 15:30 (UTC+1) 

WG Co-Chairs: Achilleas Kemos, Johan Helsingius, Desiree Miloshevic 

 - Niels ten Oever, University of Amsterdam 
 - Marina Kaljurand, Member of European Parliament 
 - Bart Groothuis, Member of European Parliament 
 - Daniel Karrenberg, RIPE NCC 
 - Mallory Knodel, Center for Democracy & Technology 
 - Farzaneh Badii, Digital Medusa 

RIPE Cooperation Working Group Co-Chair Desiree Miloshevic introduced the session and explained the format.

Niels ten Oever introduced himself and clarified that while he works with the University of Amsterdam, he spoke on his own behalf. He explained that his position was taken in response to atrocities committed in the course of the invasion of Ukraine and to the request from the Ukrainian government that the RIPE NCC de-register Russian IP address resources. He also noted that there have been examples in the past of proposals to use the number registries for political purpose, such as the proposal to prevent Internet shutdowns in AFRINIC. He noted the RIPE NCC Board’s response to the Ukrainian request, but felt that there is an open question as to what a community response should be to the kinds of events happening in Ukraine. 

Niels explained that some people have developed an alternative approach, based on a bottom-up approach and modelled on current approaches to preventing spam and abuse. He noted that such a proposal would require a new kind of decision-making venue. He stressed that current sanctions are often not well-designed, and those implementing sanctions often “over-apply” sanctions to avoid risk. He explained that the proposal is designed to avoid disconnecting civilian populations. 

Marina Kaljurand, member of the European Parliament and a former Minister from Estonia, noted that she comes from a diplomatic perspective, and that she feels it is important to react to these events and to react in a multistakeholder format. She noted that applicability of human rights law and international law must be the red line in developing and applying sanctions. She also noted the proactive approach that many in the private sector are already taking against Russian interests, and that government needs to account for this new development. She noted that there were discussions of these kinds of scenarios in the GSCS, which argued against “hack-backs” and similar ad hoc measures, and she stressed that there is a need to continue these conversations in various venues. She clarified, however, that she was very open to re-wording or further developing the proposal currently under discussion. 

Bart Groothuis, member of the European Parliament, also co-signed the letter, coming from a political point of view. He noted that sanctions have to be accepted, and therefore it is vital to ensure that sanctions are human rights compliant, that they target military, rather than civilian, subjects, and that it should avoid broad targets such as the .ru domain name. But he stressed that if sanctions are imposed, there should not be extra sanctions applied on top of those by private actors - this is important to governments. He feels that there is a need for a multistakeholder engagement with sanctions to ensure that sanctions in the digital space are better conceived and applied. 

Daniel Karrenberg, speaking in his private capacity as an Internet engineer, explained his position, that introducing any mechanisms that disrupt connectivity has the potential to destabilise the operation of the Internet, and that such mechanisms will be abused once in place. Managing such a mechanism by a multistakeholder model would not prevent the imposition of “extra” sanctions - once an “off switch” is developed, it will be used in unintended ways. 

Mallory Knodel, with the Center for Democracy and Technology, noted that on the same day as the proposal for ‘Multistakeholder Imposition of Internet Sanctions’ was published, a separate letter was published, signed mainly by civil society organisations, asking that there be a carve-put in sanctions to exempt Internet connectivity, and she feels this is a more appropriate request. She noted that while the US administration had made some concessions towards the need to carve out Internet connectivity from sanctions, the EU seems to have gone a different path and is now banning connection to Russian media outlets (such as RT and Sputnik), though she noted that the current war has been heavily reliant on disinformation and use of Internet connectivity. She argued that the RIPE NCC and similar organisations were correct to refuse the Ukrainian request, but noted that there was a need to reaffirm that the Internet is always a net positive and access is aligned with human rights; it’s also necessary to better define good/bad behaviour, including positive engagement with multistakeholder processes or rogue Internet operations (such as running “alternate roots”); and finally, it’s necessary to better define what sanctions require of Internet operators (and she argued that circumvention of sanctions, where possible, should be a “North Star”). 

Farzaneh Badii, speaking as founder of Digital Medusa, noted that sanctions (in relation to the Internet) have a long history (in the context of countries such as Iran), and this has historically had significant impact on civilian populations. She noted that in 2014, the RIPE NCC was asked to de-register resources to Iranian entities (which it refused to do), and noted that corporate “over-compliance” (by companies that do not want to risk non-compliance) is a particularly significant indirect impact of sanctions. She suggested that the recent removal of two Russian ASes from LINX had had this kind of broader impact. She argued that the proposed use of community-targeted sanctions is a simplistic solution to a very complex situation, and that a great deal of study has been done on the consequences of sanction in relation to Internet services that should be considered. She concluded that sanctions are in the sovereign power of governments to impose, and that this will never really be a multistakeholder activity. She finally noted that the RIPE NCC and ICANN have not refused to help, but have refused to implement discrimination at the infrastructure level, and this should be applauded, while we look for other ways to assist those in need. 
Desiree opened the floor for discussion. Hans Petter Holen, RIPE NCC Managing Director, noted that this is a necessary discussion to be having and emphasised that the RIPE NCC’s position is linked strongly to our registry role, and the understanding that removing resources from the registry would be destructive, but would also not have the desired effects. He noted the RIPE NCC’s belief that maintaining the global Internet, via an accurate registry, is the priority. He also noted that the RIPE NCC has been dealing with imposition of sanctions for some time, and has been transparent with its membership and community about this - he also stressed that a similar principle has also been foundational for other organisations such as the International Telecommunication Union (which has repeatedly urged that telecommunications be maintained). 
David Frautschy of the Internet Society noted that ISOC has an Impact Assessment Toolkit that it has applied to the use of sanctions - their findings are that there are politically motivated requests to remove networks from the Internet, which ISOC is strongly against. ISOC argues that Internet access, like other vital services, should be exempt from sanctions, and urges that this should be enshrined in sanctions regulations. 

Desiree noted that Rob Evans in the Zoom chat suggested that it was not so much about being asked to implement sanctions as about understanding what operators can do to protect their networks from attacks. 

Niels argued that the Internet is already playing a very political role, and sanctions are already in place and in some cases disproportionally affecting civilians. His position is that we should define ways to keep civilians connected, but also understand what can be done against aggressors - we cannot tolerate intolerance. So where is the red line? People are invited to research and identify that line, but doing nothing would be to stand on the side of the oppressor. 

Desiree asked how the proposal suggests balancing out that sanctions be very precise but also reasonably effective - Niels notes that even if you only disconnect a Russian military network, it may also be linked to civilian connectivity, but believes that we should not wait for a perfect solution. 

Mallory noted that keeping the Internet on is a lot of work, and many governments have developed means of preventing connection and censoring content. What is new in the current era is that so much social life and public services are reliant on the Internet itself, and people are especially reliant on it in times of crisis. She sees the stronger policy position as “keep it on and resist disconnection, no matter what”, and a misalignment between human rights and Internet connectivity is a far weaker position. 

Bart reiterated his basic position that sanctions will continue to be used, and the proposal under discussion is a step towards a better model for sanctions development and imposition. There is a need to look ahead, where the geopolitical situation may further deteriorate, and now is the moment to ensure that there is a multistakeholder approach deployed. 

Daniel suggested that it was wishful thinking in more precisely targeted sanctions, and even if it was possible, it would increase the complexity of Internet operations (whereas the Internet’s strength has been that it is fundamental a simple model, so we should avoid increasing the complexity of the system where possible). 

Alexander Isavnin asked the MEPs about their willingness to cooperate with the private sector in imposing sanctions, but we see private actors already applying sanctions very broadly that are effecting civilians. He sought an official European position on this kind of private sanctioning. 

Marina noted that there is no “official position”, but she agrees that the private sector is already taking measures, and she does not agree with this approach. She noted an approach she had heard about of a piece of software that could delete data from Russian and Belarusian computers. She referred back to the GCSC, and its outcomes, and that after this discussion we may again re-affirm that sanctions should be purely the domain of state actors. But this would be challenging, as the digital domain operates beyond the reach of state actors in some ways. 

Karla Wagner noted that the “bad guys” are often outside the country, and that there is a need for as much engagement and diversity as possible in multistakeholder discussions. 

Chris Buckridge suggested that there is a common agreement that sanctions in their current form are problematic, too broad, and cause indirect impacts. He noted that the RIPE NCC has been managing this for a while. He noted that there are multistakeholder venues that might be useful in making recommendations to reduce the risk that sanctions pose to the Internet itself. 

Michele Neylon noted his support for the RIPE NCC (and others’) positions on neutrality of the infrastructure, particularly as RIPE NCC provides the authoritative database of the registration data, and to meddle with that would be chaotic. He also noted that there are always conflicts, and these kinds of conversations, so any solution should be scaleable and repeatable. He noted that network operators (without monopoly positions) can make their own decisions and take actions on their own, but there is a difference for those that hold monopolies on specific services. 

Wolfgang Kleinwächter noted that in this community, the focus should be the future of the Internet - are the actions we take going to support that? Is there a possibility of “positive sanctions”, providing additional assistance to the operator and civil society communities? He also noted that we have one Internet, but spread across many national jurisdictions - the Russian government has already pushed the idea of a “national Internet segment” in international venues, while China has pushed a “New IP” model - this suggests we may be on the verge of a watershed event, perhaps splitting into multiple, distinct “Internets”. 

Desiree noted a question from chat about a “slippery slope”, and how far such a proposal would go in relation to other conflict situations. 

Niels noted that the Internet currently has holes - we do not have a consistent, global version of the Internet or connectivity, even on the infrastructure level. He suggested that not having acted in the past should not mean we do not take action now or in the future. He believes a discussion with governments about what is proportional, what is measured, would be a helpful move. 

Daniel noted that the arguments against the proposal are about the consequences of such action - and there are bad consequences from even considering the steps proposed. He also argued that inconsistency or inequality in Internet infrastructure cannot be an argument for making it worse. 

Brian Nisbet suggested that Russia is an easy target - will the same apply when a Western country gets into an illegal war? He noted that infrastructure or core operators (like RIPE NCC, or RIPE) getting involved will not help. RIPE should not make the inequality and brokenness of the global Internet worse, and would not achieve the anticipated outcomes if it did. 

Roelof Meijer noted that he is a signatory of the proposal, but supports the position that the RIPE NCC and ICANN have taken. However, he is in favour of looking at what operators can do, without cutting off all of Russia or breaking the Internet, and those measures will not be perfect. He is reminded the of the response that SIDN get when they started to fight malware and abuse 10 years ago - that it wouldn’t work, it was a slippery slope, that it would make the Internet more complex - but he believes that if done carefully and proportionally, it can work. 

In the closing comment, Niels noted that most importantly, we agree that citizens and the general population should not be targets or victims, and the final aim should be to provide connectivity, but that may entail using expertise and insight to work with governments on refining sanctions approaches. 

Tom Smyth agreed that citizens should not be sanctioned, and questioned the idea of cutting off Russian citizens from the information and media available on the Internet. He suggested that it’s better to be able to communicate ideas, which requires maintaining connectivity. 

Marina emphasised that discussion is needed, and we need to continue work towards common positions and solutions, but noted that there was not enough voice of government in today’s discussion. She also noted that on many points there is already broad agreement, and that no one wants to cut off all of Russia. 

Farzaneh closed in noting that introducing more discrimination into the infrastructure will not solve the current problems. We need to think of the Internet as a global phenomenon that can provide life-saving services to those who have been the victims of (non-digital) sanctions. 

Julf Helsingius, Co-Chair of the RIPE Cooperation Working Group, closed the session noting that the discussion highlighted how complicated this subject was, that there was a need to involve governments more, and that the discussion should continue.