[ncc-services-wg] [members-discuss] [address-policy-wg] Crimea papers

Dear all,

The RIPE NCC follows the developments regarding sanctions adopted by the
European Union (EU) and reviews whether these sanctions restrict us from
providing services to network operators in certain regions or from
having a contractual relationship with them.

Additionally, the RIPE NCC communicates with the Dutch authorities in
order to clarify the details of the imposed sanctions and our obligations.

So far, the EU sanctions adopted for the Crimea region (including the
newest sanctions imposed by the EU by adopting the Council Regulation
(EU) No 825/2014 of 30 July 2014) do not restrict us from doing any of
the above.

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2014.226.01.0002.01.ENG

In response to the concerns raised about this new Regulation, we have
the following remarks:

According to Article 2c of the Regulation:
1. It shall be prohibited to sell, supply, transfer, export, directly or
indirectly, key equipment and technology as listed in _Annex_III_ to any
natural or legal person, entity or body in Crimea or Sevastopol or for
use in Crimea or Sevastopol.
2. _Annex_III_ shall include key equipment and technology related to the
creation, acquisition or development of infrastructure in the following
sectors:
...
(b) telecommunications;
...
3. It shall be prohibited to:
(a) provide, directly or indirectly, technical assistance or brokering
services related to the key equipment and technology listed in
_Annex_III_, or related to the provision, manufacture, maintenance and
use of items listed in _Annex_III_ to any natural or legal person,
entity or body in Crimea or Sevastopol or for use in Crimea or Sevastopol;
...


So any prohibition is related to key equipment and technology as listed
in Annex III.

Annex III does not include anything related to the services we provide,
including the registration of Internet number resources.

We will continue to follow the development of any sanctions that affect
the provisioning of services in our region.

Kind regards,

Athina Fragkouli
Legal Counsel
RIPE NCC



On 31/07/14 14:38, Sander Steffann wrote:
> Hi,
> 
> I just got a question about how I meant this sentence:
> 
>> As a networking person 'related to the provision [...] and use of items listed' does seem to include allocating number resources.
> 
> Just so that people don't misunderstand me: what I meant here is that the terminology used in this legal document has some specific meaning in the networking world. The meaning in a legal sense is probably completely different from what I as a networking engineer would read. Which is why I think we need to let a legal specialist comment on this. IANAL and my opinion doesn't mean anything here :)
> 
> Sorry for the confusion!
> 
> Cheers,
> Sander
> 
> 
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