[ncc-services-wg] Transfers from Ukraine, how to ideed protect resource holders

On behalf of UA.VISTI (LIR est. 1997, Kyiv, Ukraine) I have to tell that we can't support 
neither banning of IP transfers from Ukrasinian LIRs nor including any UA Government 
institution into process of transfer approval. In our opinion them cannot serve the aim 
declared by authors of such initiatives.

Instead, taking onto account the Russian aggression and that there are Ukrainian 
territories _temporarily_ occupied by enemy forces which widely use terror and robbery, 
RIPE NCC should consider additional due diligence procedures approving transfers from 
Ukrainian LIRs.

These procedures should be discussed, but they should remain possible in our realities.
The disclaimer about possibility of transfer reversion offered in [Protecting Resource 
Holders in Distressed Areas] seems reasonable, however bona fide buyers might avoid 
additional risk of such situation and choose not to deal with UA IP address blocks.

What would be offered instead: transfer request might be precessed by several-step 
verification, and one of the steps, for example, might include geolocation verification of 
the person submitting the request (presuming that there are definitely non-occupied and 
non-combat areas where Ukrainian governance  carried out in full, so  such person is not 
unburdened by the circumstances of the war).

Regards,
Vitaly Zubok
Deputy Director

ELVSITI Information Center
Kyiv, Ukraine
+380442399091
http://visti.net