Hi Athina, > Apologies for the delay in getting back to you.
Likewise :) Thank you for publishing such excellent work at https://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 <[email protected]> >> Subject: [ncc-services-wg] State of sanctions >> Date: 20 May 2021 at 16:28:49 CEST >> To: [email protected] >> >> 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 > > To unsubscribe from this mailing list, get a password reminder, or change your subscription options, please visit: https://lists.ripe.net/mailman/listinfo/ncc-services-wg
