[address-policy-wg] Block/Suspend sanctions on address space.

Sat Feb 26 19:51:20 CET 2022

I don’t think the extend of sanctions compliance needs to be discussed. Obviously the RIPE NCC will need to comply with EU sanctions in full.

An explanation from RIPE’s legal team on who will be affected may be useful, but I don’t think there would be a lot of value in a meeting as few aspects of this are under the community’s (or the RIPE NCC’s) control.

Regarding “We all know now that EU banks will not allow the collection of the 2022 RIPE NCC fees from Russia, and invoices are due in a few days.”, I don’t think this is true. There would be issues where payers or their banks are involved in sanctions, but not for unrelated Russian entities.

Matthias Merkel
Staclar, Inc.

From: address-policy-wg <address-policy-wg-bounces at ripe.net> on behalf of Mathias Westerlund <mathias.westerlund at wdmab.se>
Date: Saturday, 26. February 2022 at 19:39
To: Thomas Brenac IPv4 Broker <thomas at brenac.eu>
Cc: Alexey Shkittin <alexey.shkittin at interlir.com>, RIPE Address Policy Working Group <address-policy-wg at ripe.net>, Gert Doering <gert at space.net>
Subject: Re: [address-policy-wg] Block/Suspend sanctions on address space.
I have to say, even tho we are a new entity, we do support the calling of a potential emergency meeting to alteast discuss this.
RIPE is an EU entity. We need to be clear on what levels we are following EU sanctions.

On Sat, Feb 26, 2022 at 5:35 PM Thomas Brenac IPv4 Broker via address-policy-wg <address-policy-wg at ripe.net<mailto:address-policy-wg at ripe.net>> wrote:
Gert mentioned, '' NCC already does this - if a country is officially sanctioned by the EU
    (it can not opt to not-do this, anyway, if there is a legal requirement)''

Indeed, we can see in https://www.ripe.net/publications/docs/ripe-776   ''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, we freeze their resources in the RIPE Database''

As several Russian LIR starting with Yandex (exemple) do have a clear, publicly known, relationship / shareholders with sanctioned Russian individuals and Russian entities, as a LIR member I do suggest that RIPE NCC hold a proper emergency meeting on the matter.

The report is made quarterly.

There is now a situation of emergency that need a quick due diligence on the application of the EU sanctions on the resources hold by the Russian entities concerned by the EU sanctions, including transfer policy, access to RIPE database and services, routing, RDNS etc etc. and hopefully with more impact that the one mentioned in the last report.

We all see the important use of allocated resources for massive DoS and other attacks, RIPE NCC shall support a clear limitation and use of the RIPE NCC services and resources of the Russian, Byelorussian LIRs (that are directly or indirectly , Byelorussian, Russian state owned or owned by listed sanctioned individuals).

Side note: We all know now that EU banks will not allow the collection of the 2022 RIPE NCC fees from Russia, and invoices are due in a few days. That is a good reason to freeze the resources a bit faster that usual. Taken into account the number of LIR that could also impact the whole budget for 2022, and I'm not sure the rest of the community will be happy to support...

Again, we need to see a quick reaction from RIPE NCC, within days, not on a quarterly basis.

Thank you.

______________________
Thomas BRENAC
CEO
https://www.brenac.eu <https://www.brenac.eu/>
+33686263575
Registered IPv4 Broker by RIPE NCC, ARIN, APNIC and LACNIC,
Member of AFRINIC.

On 26/02/2022 10:07, "address-policy-wg on behalf of Gert Doering" <address-policy-wg-bounces at ripe.net<mailto:address-policy-wg-bounces at ripe.net> on behalf of gert at space.net<mailto:gert at space.net>> wrote:

    Hi,

    On Sat, Feb 26, 2022 at 08:44:35AM +0100, Alexey Shkittin wrote:
    > *Block/Suspend sanctions on address space.*
    >
    > Based on events with Russian aggression on Ukrain.
    >
    > Policy Proposal for discussion.
    >
    > Update RIPE NCC policy in according to be able suspend management of
    > internet resource numbers in RIPE NCC database of the countries under
    > Sanctions in EU/US.

    NCC already does this - if a country is officially sanctioned by the EU
    (it can not opt to not-do this, anyway, if there is a legal requirement).

    See here, for example, for the Q1 2022 sanctions transparency report:

      https://www.ripe.net/publications/docs/ripe-776

    Gert Doering
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