Voluntary Transfer Lock

Summary of proposal

The war in Ukraine has highlighted the fear of some resource holders that resources may be transferred to an aggressor under duress. It would be a great comfort to some resource holders if it was possible to signal to the RIPE NCC in advance that transfers should not occur for a predetermined period. Not all resource holders want this, so it is not a solution for everybody, but it is a solution for some.

While the situation in Ukraine was the trigger to write this policy, it does not exclusively apply to that situation. There are other situations where a resource holder may want to lock their resources to protect them from transfer, such as protecting specific resources from being transferred by mistake, or to make sure a disgruntled employee can’t cause problems. This proposal doesn’t list all possible reasons someone could use this policy, it merely offers the possibility for those who want it.

The important part is that this is a voluntary lock, not something that is forced on RIPE NCC Members or other resource holders. This proposal does not tell RIPE NCC to unilaterally limit any right that a resource holder has, but it gives resource holders the extra right to ask the RIPE NCC not to process any resource transfers for a certain amount of time.

Policy text

a. Current policy text:

There is no policy, but on request of the community, the RIPE NCC implemented a temporary voluntary lock mechanism following the RIPE NCC Executive Board resolution EB#163-R-02 ^[1].

The form to request this can be found at: https://www.ripe.net/manage-ips-and-asns/resource-transfers-and-mergers/registry-lock-request-form.

If this new policy is accepted, it will replace or succeed the current temporary solution.

b. New policy text:

Abstract

This document defines the guiding policy for the RIPE NCC to offer a Voluntary Transfer Lock to resource holders. It applies to all transferable resource types (IPv4, IPv6 and ASN) registered with the RIPE NCC. It explicitly does not apply to sub-allocations and assignments made by LIRs. It also does not apply to legacy resources.

The transfer lock option provided by this policy is completely voluntary and will not affect resources where a lock has not been explicitly requested by its resource holder.

Goal

This policy allows any resource holder whose resources are registered with the RIPE NCC to inform them which of these resources must not be transferred for a certain amount of time. The RIPE NCC will then respect the resource holder’s wishes and prevent those resources from being transferred, despite any requests to the opposite, during the time of the lock.

Scope

This policy only defines the constraints on the implementation of a Voluntary Transfer Lock. It explicitly does not prescribe a specific implementation by RIPE NCC. When requesting a Voluntary Transfer Lock, the procedural documentation published by the RIPE NCC is leading. These procedures must comply with the constraints set by this policy.

Constraints

• RIPE NCC must offer all its resource holders the option to temporarily lock their resources from transfer.
• The operational procedures to request a lock must be made publicly available.
• All transferable resource types (IPv4, IPv6 and ASN) registered with the RIPE NCC are lockable.
• Resource holders must only be able to lock their own resources.
• It must be possible for a resource holder to only lock certain resources.
• Only a whole allocation or assignment can be locked, not a part of it.
• The resource holder must explicitly state which resources to lock.
• Resource transfer requests received during the duration of the lock will not be processed by the RIPE NCC.
• A Voluntary Transfer Lock is an agreement between a resource holder and the RIPE NCC.
• The lock’s start and end date must be explicitly agreed between the RIPE NCC and the holder.
• From the start date onward, locked resources are irrevocably locked until the end date. Resource holders must explicitly acknowledge their understanding of this fact.

Recommendations

• At least 1 month before the lock expires, the RIPE NCC should notify the resource holder with the option to extend it or enter into a new locking agreement.
• The RIPE NCC should offer lock durations of 6, 12 and 24 months
• Locks expire automatically if an extension is not explicitely requested.
• The RIPE NCC should publish all active locks on its website.

Implementation choices

• The RIPE NCC may offer additional lock durations in addition to the ones mentioned above.
• The RIPE NCC may be unable to enforce the lock in certain situations such as mergers and acquisitions or due to restrictions from any applicable laws or regulations. These situations may have practical and/or legal reasons, although the RIPE NCC should keep the number of exceptions as small as possible.
• All such exceptional situations must be clearly defined in the RIPE NCC procedure referenced in the locking agreement.
• In cases where a resource is involved in conflicting situations, the RIPE NCC will act in accordance with existing policies and procedures.

Rationale

a. Arguments supporting the proposal:

• There have been requests from parts of the community to implement this option.
• The policy gives resource holders an option they can use, it doesn’t affect those who don’t want to use it.
• The policy solves a real-world problem for some resource holders.

b. Arguments opposing the proposal:

• It is unclear how many resource holders are actually going to use this option.
• The policy may only be useful for a small subset of resource holders.
• This policy doesn’t solve all possible cases of duress.

The author of this policy proposal feels that the arguments supporting the proposal outweigh the arguments opposing the proposal. No single policy will ever fix all possible scenarios, but if an option like this is never offered, we will never know how many resource holders would have used it. In the author’s opinion, considering the current situation in our service region, the risk of asking the RIPE NCC to spend money to implement a policy that is not widely used is outweighed by the peace of mind it may offer resource holders in distress.

[1] board resolution EB#163-R-02 https://www.ripe.net/about-us/executive-board/minutes/2022/minutes-163rd-executive-board-meeting