RIPE NCC Quarterly Sanctions Transparency Report (Q2 2022)

Introduction

This quarterly report provides data on how RIPE NCC members, End Users and legacy resource holders are affected by sanctions, while respecting their confidentiality and privacy.

As an organisation based in the Netherlands, the RIPE NCC must comply with EU sanctions. If we believe that a member or other resource holder is subject to EU sanctions that are applicable our services, we freeze the registration (not the use) of their resources in the RIPE Database. This means that sanctioned entities cannot acquire further resources or transfer existing ones. However, we do not deregister their resources or terminate their Standard Service Agreement (SSA) if they are RIPE NCC members.

Sanctions Data

The tables below show any changes since the previous quarter, as well as the total number of resource holders and resources affected. This includes the date of action and what action was taken. The table also shows our relation to a sanctioned entity – whether they are a RIPE NCC member, End User or legacy resource holder. We also specify the country in which the resource holder is legally registered.

We had formerly reported on requests from sanctioned entities to receive services from us, such as requests to become a member or to receive an assignment of Provider Independent (PI) resources as an End User. This category is largely redundant and so we have removed the corresponding table below.

New Tables: Cases Under Investigation

Alongside the number of resource holders confirmed to be subject to EU sanctions that are applicable to our services, there is a much larger number of potential matches under investigation. Leaving out these statistics masks the wider impact that sanctions are having on the Internet as well as the work needed to contact potential matches and request supporting documentation.

Most of these cases turn out to be false positives. However, because there is no grace period allowed for sanctions compliance, potential matches must be treated as though they are sanctioned until our staff can confirm otherwise. This means that we will not process any requests for new resources or to transfer existing ones until a potential sanctions case has been cleared.

Since early 2021, updates to the EU sanctions list have resulted in a total of 766 potential cases requiring investigation. 343 of these are RIPE NCC members, 420 are End Users, and four are in relation to inter-RIR transfers. The EU also recently announced a series of new sanctions against Russian entities in response to the war in Ukraine. Of the 766 cases above, 229 were in response to Russia’s war on Ukraine (59 members / 169 End Users).

Summary of Changes

Since our last report, two members in Russia have been identified as subject to EU sanctions that are applicable to our services. On 28 April 2022, they were frozen according to our sanctions procedure.

Changes Since Last Quarter

Status on 20 April 2021

Cases Under Investigation: Status of Cases

Cases Under Investigation: Type of Resource Holder

Note: we also check against the Office of Foreign Asset Control (OFAC) sanctions list, which is maintained by the United States Government. While we are under no obligation to comply with US sanctions, they are a factor for banking institutions in the Netherlands. Apart from making an internal note, no further action is taken if we find a match with the OFAC sanctions list.

Due to concerns on the part of our banks, we are not able to invoice members in Iran and Syria for their fees. We will not close these members for non-payment and we plan to invoice them retroactively for the full amount as soon as this is possible.