[ncc-services-wg] State of sanctions

Kurt Kayser wrote:

> I consider Internet-resources as important as drinking water. How can
> "we" allow to restrict these resources, due to political pressure?

See:

	https://en.wikipedia.org/wiki/Cochabamba_Water_War

Bechtel, which tried to privatize water supply in Bolivia, is a
French company, from which you can guess moral standards of
EU.

Though it is written that

	The water network that they envisioned was projected to
	provide drinking water to all the people of Cochabamba.
	This was set to double the existing coverage area and
	also introduce electrical production to more of the
	region.[9]

many of us who understand the last mile problem know
projected "double the existing coverage area" is hard,
if not impossible.

							Masataka Ohta

> 
> Regards, Kurt
> 
> 
> Am 19.11.21 um 12:59 schrieb Alex Le Heux:
>> Hi Athina,
>>
>>> Apologies for the delay in getting back to you.
>> Likewise :)
>>
>> Thank you for publishing such excellent work 
>> athttps://labs.ripe.net/author/athina/how-sanctions-affect-the-ripe-ncc/
>>
>> I’m happy to see that the RIPE NCC is treating this as the serious 
>> long-term threat that it is and am looking forward to the results of 
>> your coordination efforts with the other RIRs.
>>
>> Best regards,
>>
>> Alex Le Heux
>>
>>
>>> As an association under Dutch law, the RIPE NCC is in principle 
>>> subject to EU and Dutch sanctions regulations. Of relevance to us are 
>>> financial sanctions, which consist of:
>>>
>>> - Freezing of funds and economic resources of designated persons and 
>>> entities; and
>>> - A prohibition on making funds and economic resources available to 
>>> such persons and entities.
>>>
>>> So far, these sanctions apply to designated persons and entities 
>>> listed in EU sanctions regulations for Iran and Syria. You can find 
>>> the legislation (along with sanctioned persons/entities) here:
>>>
>>> - 
>>> Iran:https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32012R0267 
>>>
>>>
>>> - 
>>> Syria:https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32012R0036 
>>>
>>>
>>> Please note that the list of designated persons and entities is 
>>> regularly updated.
>>>
>>> The RIPE NCC has reviewed its membership and has set a restriction on 
>>> transfer and resource requests for three of its members. This was 
>>> announced by the RIPE NCC Executive Board last year in April[1], 
>>> followed by an update in June[2].
>>>
>>> In late December 2020, the Dutch Ministry of Foreign Affairs (MFA) 
>>> confirmed to the RIPE NCC its understanding that IP resources are 
>>> considered economic resources, as defined in the EU sanctions 
>>> regulations, and must be frozen for sanctioned entities.
>>>
>>> The MFA's primary concern is in terms of preventing the IP resources 
>>> of sanctioned entities from being transferred, as well as preventing 
>>> the allocation of additional resources. However, the MFA also said it 
>>> believed the RIPE NCC had taken adequate steps to ensure compliance 
>>> with sanctions and there was no need to deregister the IP resources 
>>> of the three affected members. This was announced by the RIPE NCC 
>>> Executive Board in March[3].
>>>
>>> Please also note that the RIPE NCC had requested an exemption from EU 
>>> sanctions regulations. However, the MFA stated that according to the 
>>> regulation, there was no legal basis to exempt IP resources from 
>>> sanctions.
>>>
>>> Regarding your last point, it might be difficult to provide a 
>>> detailed overview, as anything we publish will have to be 
>>> sufficiently anonymised to avoid identifying the affected members. 
>>> However, we will see what we can do here, as we appreciate the value 
>>> in having transparent reporting around this issue.
>>>
>>> Kind regards,
>>>
>>> Athina Fragkouli
>>> Chief Legal Officer
>>> RIPE NCC
>>>
>>>
>>> [1] Sanctions and the RIPE NCC: Current Status and Executive Board 
>>> Position:
>>> https://www.ripe.net/ripe/mail/archives/ncc-announce/2020-April/001413.html 
>>>
>>>
>>> [2] Sanctions and the RIPE NCC: Status Update
>>> https://www.ripe.net/ripe/mail/archives/ncc-announce/2020-June/001427.html 
>>>
>>>
>>> [3] RIPE NCC Sanctions Update:
>>> https://www.ripe.net/ripe/mail/archives/ncc-announce/2021-March/001477.html 
>>>
>>>
>>>
>>>
>>>> From: Alex Le Heux<aleheux at tucowsinc.com>
>>>> Subject: [ncc-services-wg] State of sanctions
>>>> Date: 20 May 2021 at 16:28:49 CEST
>>>> To:ncc-services-wg at ripe.net
>>>>
>>>> Hi All,
>>>>
>>>> The various types of sanctions and or such limits that apply to the 
>>>> RIPE NCC’s services have been a recurring topic for a couple years 
>>>> now. Recently, this seems to pop up more often though. This isn’t 
>>>> surprising as sanctions have become a more popular tool in the last 
>>>> few years.
>>>>
>>>> It occurred to me that we don’t seem to have a clear overview of 
>>>> what the total effect is:
>>>>
>>>> - Which sanctions, imposed by whom, affect the RIPE NCC’s operations 
>>>> and services?
>>>> - Who are the targets of these sanctions?
>>>> - Which of the RIPE NCC’s services are affected by these sanctions, 
>>>> for whom and in which way?
>>>>
>>>> (Please read “sanctions” with a wide definition and include such 
>>>> things as Dutch banks looking for money laundering that was 
>>>> mentioned during RIPE82)
>>>>
>>>> If there is a detailed overview of all this available, could the 
>>>> RIPE NCC publish this periodically? If not, can they start doing so?
>>>>
>>>> Best regards,
>>>>
>>>> Alex Le Heux
>>>
>>
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