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
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