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[ncc-services-wg] Update on Measures to Protect Ukrainian Networks
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Hans Petter Holen
hph+announce at ripe.net
Mon Dec 19 15:18:42 CET 2022
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
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