[address-policy-wg] [ncc-announce] [news] RIPE NCC Response to Committee of the Verkhovna Rada of Ukraine

Hi Hans Petter!

> I would encourage you to have a look at the article outlining some of the alternatives:
> https://labs.ripe.net/author/athina/protecting-resource-holders-in-distressed-areas/ 

Yeah, I did read that. I just don’t agree with the arguments. 

> While this might seem like an easy solution on the surface, we cannot help but anticipate situations where this could be abused. For example, we can imagine cases where malicious employees want to prevent an upcoming transfer. Such a solution would also have some administrative challenges, because who is authorised to activate this freeze would need to be specified.

Make it the same person who is authorised to open/close an LIR. The NCC already has those contracts. To prevent abuse make it a paper form with signatures over registered mail, or whatever the NCC has in place already. I’d put the authorisation level at the same one as closing the LIR. 

> Also, we wouldn't be able to adhere to such a requested freeze when companies are bankrupt, liquidated or in case of a legitimate merger and acquisition.

Yeah, I agree there is little you can do about those in any circumstance. 

> In any case, if the period of time for the lock is longer than a couple of days, we would again be very reluctant in implementing this solution without a policy proposal.

Why? An LIR explicitly and voluntarily giving up some rights they have under the service agreement is surely a matter between the member and the NCC? The policy stays exactly the same. 

> I can assure you that we have taken the measures we believe we can within the existing policy.

I think adding a disclaimer that allows for making transfers null and void retroactively is a much bigger risk to all involved than a transfer lock would have been. I don’t see how on one hand the NCC can’t verify whether a transfer lock is valid, but can verify with absolute certainty that existing paperwork is null and void.

To me it feels more like a “let someone else figure this out in court” attitude than an actively helpful one.

> Looking forward to hearing what the community thinks here at the list or the meeting next week.

Me too! I’m only a single voice here, and this is a community!

Cheers,
Sander

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