Dear Ronald,

I've grouped some of your questions together for the sake of brevity.

1. Isn't RIPE already regulating route objects through restrictions in
the RIPE Database? What about the upcoming changes to out-of-region objects?

Sorry if I was unclear on this point. It's important to note the
distinction between RIPE (community/policy-setting) and the RIPE NCC
(legal organisation/implementation).

The RIPE community is absolutely able to set policy or issue directions
to the RIPE NCC that would regulate the creation of route objects (such
as the existing features in the RIPE Database or the upcoming changes
with out-of-region objects). However, while RIPE has this ability - the
RIPE NCC requires an explicit mandate or instructions from the community.

So, my original point stands - it's not the RIPE NCC or the Board you
should be addressing your comments to. If the RIPE community instructs
the RIPE NCC to monitor or validate route objects in the RIPE Database,
then that is what the organisation will do. If the community could reach
consensus on what a fraudulent route object looked like, that would be a
start. Again, the RIPE Policy Development Process is there for you to
suggest an approach that satisfies all stakeholders.

2. What does the RIPE NCC do when members are repeatedly caught making
fraudulent route objects? For what reasons can the RIPE NCC close a member?

The RIPE NCC does not have a mandate to determine whether route objects
in the RIPE Database are valid. Therefore, "caught" doesn't mean much in
this context - especially if the community hasn't provided a definition
of "fraudulent". Because the organisation doesn't have a mandate, it
can't take any action against its members for this behaviour.

Similarly, the community has never given the RIPE NCC a mandate to
examine murder cases - so to reference your other question - a member
would not be closed down for murdering or maiming someone. And to be
frank, I think we have the community's support on this. It's not the
role of the RIPE NCC to investigate murders, or any other crime for that
matter.

In your email, you asked what behaviour would be so extreme that the
RIPE NCC would be finally obliged to close down a member. In all cases
where members have been closed, it was because they violated the terms
of their Standard Service Agreement (SSA) with the RIPE NCC. It's
therefore important to approach this in terms of whether they broke
their agreement, rather than the severity of their behaviour.

The reasons for which the RIPE NCC can terminate a membership are listed
here: https://www.ripe.net/publications/docs/ripe-697

A few more members have been closed since the four you referenced. This
has come from an increase in members attempting to gain control of other
people's IPv4 addresses or opening LIR accounts with fraudulent or
untruthful information. In 2018 so far, 58 LIRs have been closed for
these reasons (up from five in 2016 and four in 2017). A further five
have been closed in 2018 for unresponsiveness.

A member could be closed for failing to maintain accurate data in the
RIPE Database - but the document linked above explains what types of
data must be maintained, and this does not include route objects. Also,
because the RIPE NCC is concerned primarily with correct registration,
it will work with the resource holder to update their information in the
first instance. A member has never been closed for this reason, and it
would only happen after they had been given ample opportunity to correct
their data. This is consistent with guidance from the RIPE community.

3. On brokers

Regarding brokers, there are certain legal considerations when deciding
whether to break the agreement with them - especially if this would be
on the basis of allegations the organisation is unable to take a
position on.

The RIPE NCC has canceled two broker agreements in cases where a broker
was found to have violated the terms of their agreement (spamming RIPE
Database contacts). As an aside, it's worth noting that brokers don't
pay anything to the RIPE NCC as part of this agreement.

Ronald, I trust that this has adequately clarified the RIPE NCC's
position. If you have any further comments, I suggest you share them
with your colleagues in the relevant working group, or perhaps consider
attending a RIPE Meeting where we could discuss this in person.

Best Regards

Nigel Titley
Chairman of the RIPE NCC Executive Board


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