[ncc-services-wg] Update on Measures to Protect Ukrainian Networks

Dear colleagues,

I want to update you on measures to protect the resources of RIPE NCC 
members in Ukraine following my last email in October[1].

After discussions with our Executive Board, we are now ready to begin 
implementation of a ‘voluntary registry lock’ in the LIR Portal. This 
will be available for all RIPE NCC members, including those in Ukraine, 
on an opt-in basis. The lock will allow members to prevent their 
resources from being transferred for a defined period. We expect 
technical implementation to be completed before the end of the year.

The authority to implement this feature comes from a Board resolution 
that was passed at the 163rd RIPE NCC Executive Board Meeting on 14-15 
December 2022. The effect of the resolution is that Members and End 
Users (represented by their sponsoring LIRs) will be allowed to request 
the prevention of their resources from being transferred for a period of 
six months. And all transfer requests from Ukraine, including the 
pending ones, will only be processed if accompanied by notarised 
supporting documents. We will contact all Ukrainian members with pending 
transfers to make sure they are aware of these requirements. And for 
members with pending transfers who wish to make them before the end of 
the year, we will not charge fees for 2023 if these extra requirements 
mean that the LIR accounts in question cannot be closed by the end of 2022.

The Board made this resolution taking into account:
- The concerns expressed by Ukrainian members at the RIPE 85 Meeting in 
October 2022
- The RIPE NCC’s commitment to be neutral and impartial
- The time needed for the formation of a permanent solution addressing 
these concerns through the Policy Development Process (PDP)
- The RIPE community’s support to accommodate a temporary solution

This resolution comes with an expiry date of 1 July 2023. We hope that 
the RIPE community will use this time to agree on a policy proposal that 
gives us a clear mandate to provide this lock as a lasting solution to 
all members who see the need for it. Our Policy Officer is available to 
offer guidance and administrative support to get the proposal through 
the RIPE Policy Development Process.

 From comments at RIPE 85, we understand that some people do not think 
this should be a policy matter. However, as we explained at that 
meeting, the RIPE NCC cannot limit the transfer rights of paying members 
without either a solid legal basis or a clear mandate from the RIPE 
community.

It is in this context that we must note that the lock will not prevent 
resources from being transferred in cases of merger or acquisition. It 
will also not prevent transfers in cases where a bankrupt company goes 
into liquidation.

Finally, in my last email, I said that requests from Ukraine would 
receive the ‘highest levels of due diligence’, and I want to explain 
what this means. In recent years, we have developed a framework that 
describes what information our staff will ask for when handling 
requests. By applying the strongest approach within this framework, we 
will be going beyond our standard requirements and asking to verify 
additional documents. With the passing of this resolution, transfers 
will follow the process outlined here and will not be escalated to the 
Managing Director for approval.

We hope that our Ukrainian members will understand that this is part of 
our efforts to protect their resources.

As mentioned above, we will share more specific information on the 
registry lock before the end of the year – including how it can be 
activated and by whom, and what it does and does not restrict.

Kind regards

Hans Petter Holen
Managing Director
RIPE NCC

[1] Measures to Protect Ukrainian Networks:
https://www.ripe.net/ripe/mail/archives/ncc-services-wg/2022-November/003668.html