[address-policy-wg] @EXT: FW: Last Call - 2023-04 (Add AGGREGATED-BY-LIR status

Dear All, 
I would have some comments about the previous points that mentions Europol
Thanks for your cooperation spirit
Regards
Emmanuel Kessler

-----Original Message-----
From: address-policy-wg <address-policy-wg-bounces at ripe.net> On Behalf Of Kai 'wusel' Siering via address-policy-wg
Sent: vendredi 5 avril 2024 21:41
To: address-policy-wg at ripe.net
Subject: Re: [address-policy-wg] Last Call - 2023-04 (Add AGGREGATED-BY-LIR status

Moin,

am 05.04.24 um 16:51 schrieb denis walker:
> I used to wonder why no one
> would even talk about bringing the RIPE Database into the modern 
> world.
Because this is address-policy (»The Address Policy Working Group develops policies relating to the management and registration of Internet number resources.«), not database (»The Database Working Group deals […]«).

> Europol has expressed serious concerns about these changes.
Europol has the means to challenge the maintainer of the address space for more information on individual usage; there is no real thread to Europol's operation by the change, it might just become less convenient to get the wanted information.

--> Sorry, but reading this, I observe that you may indeed have only a fuzzy/limited idea of what Europol does, and the impact on LE operations.. 
      As knowing the scope of Europol  and digital investigation (we work here), we repeat that the matter is not only being less convenient. The matter is the loss of opportunities of identification that will vanish for investigators...



> If someone had informed them earlier
> of the changes being considered that may affect them,
Well, this is happening all in the open. IF Europol is depending so greatly on the RIPE DB, they SHOULD be following the PDP already for years and years and voiced their concerns more timely.

--> the matter is not just Europol, but the impact on investigations of LE services....Europol has been regularly well active in various working groups of RIPE... 
Please consider that capacities of investigators are impacted by a large number of negotiation processes :  at E-governance level (ICANN, RIPE,..), UN treaties, Council of Europe conventions, numerous EU legislations (Nis2, E-evidence package, DSA,...), national levels ones... (and I may forget some..?!)....
linked with judicial cooperation frameworks, companies regulations, cybersecurity actors, technological standards in permanent evolution, .... The number of working groups, regulations, proposals, legal acts, is the most consequent...it is a "jungle" of processes that have to be covered,...you can believe me...
in spite of the efforts of our committed people, we are unfortunately not omniscient an always present everywhere....(nobody is...!). As in all organisations, capacities are not infinite and we have sometimes to prioritize those we have, under emergencies and the various agendas..

...but whatever the raised questions, THE relevant question is overall that a joint work in open spirit is THE best way...beyond considering the only question of a seat gap at a moment... --> The matter should remain in the end, which impact (positive/negative...) ?
when all know new popping processes from the beginning, it allows to formalize swiftly a full knowledge about impact, and prevent 2 undesirable ends that are : wasting time on a proposal that should be given up/ or persisting on the difficult adoption of a measure that will bring damage on victims protection...

we can do great job to secure digital space, (just see Lockbit and the latest operations against ransomwares : https://www.europol.europa.eu/media-press/newsroom?q=cyber  ) including protecting private sector and companies that are essential for business and the economic health of our countries,
but if we lose the access to data, it means less operational achievements/ and criminals being more in capacity to target companies and peoples, who still "pay the bill" of crimes...



> proceed with all haste to
No haste visible at all; this is about 2023-04 — we already are in 2024-04.

Regards,
-kai

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