[address-policy-wg] Policy violation

Hi Aleksey,

> On the 7th of September the NCC implemeted the document https://www.ripe.net/publications/docs/ripe-709#transfer35 (The document is published on the 21th of September). The support clarify it that you cannot merge one LIR into the second LIR in case of M&A procedure because of the 24 month resource transfer restriction.

That section doesn't seem to be about M&A. It talks about normal transfers between LIRs that belong to the same member.

> However there is another document https://www.ripe.net/publications/docs/ripe-682#2-2-transfer…
> where you can read the next:
> 
> 2.2 Transfer Restrictions
> This restriction does not prevent the resources from being transferred due to further mergers or acquisitions within the 24-month period.

M&A is a different thing. It involves changes in legal business structures. Take a look at https://www.ripe.net/publications/docs/ripe-709#transfer31 item ii:

"""
If the transfer is taking place due to a change in the structure of the organisation(s) involved (e.g., merger, acquisition), a description of the changes among these organisation(s) is necessary. This description must be accompanied by the official legal documents issued by the relevant national authorities proving/supporting the changes the request is based on.

If the change in the structure of the organisation(s) involved cannot be proven/supported by official documentation from national authorities describing this change (e.g., a network acquisition from one member to another), then these cases will fall within the scope of RIPE Policy "RIPE Resource Transfer Policies".
"""

If it is not M&A then the normal policies apply, even when transferring between LIRs belonging to the same member. That includes the 24 month waiting period.

> In this case the NCC doesn't follow own policies. Or am I wrong?

As far as I can see the NCC is following the policy.

Cheers,
Sander