[ncc-announce] [news] RIPE NCC Sanctions Update

Dear members,

I want to update you on the latest developments regarding sanctions, after my earlier messages from April[1] and June[2] last year.

Overall, this is positive news - though it is not what we hoped for and it means there is still work to be done.

EXEMPTION REQUEST AND STATUS OF SANCTIONED RIPE NCC MEMBERS

In late December 2020, the Dutch Ministry of Foreign Affairs (MFA) responded to the RIPE NCC's request for an exemption from EU sanctions regulations.

In its response, the MFA confirmed its understanding that IP resources are considered economic resources, as defined in the EU sanctions regulation, and must be frozen for sanctioned entities. The MFA further stated that according to the EU sanctions regulation, there was no legal basis to exempt IP resources from sanctions.

However, the MFA also said it believed the RIPE NCC had taken adequate steps to ensure compliance with sanctions. It said there was no need to deregister the IP resources being used by the three affected members, which it understood are being used by their customers.

The MFA's primary concern is in terms of preventing the IP resources of sanctioned entities from being transferred, as well as preventing the allocation of additional resources. A restriction on transfer and resource requests must therefore remain in place.

2021 INVOICES FOR IRANIAN AND SYRIAN MEMBERS

In my earlier mails, I noted that the RIPE NCC's bank had temporarily revoked its ability to receive direct bank transfers from members in Iran and Syria. This restriction has remained in place since then, and is relevant now that the 2021 billing cycle has started.

Discussions on this issue between the RIPE NCC and its bank, which had been on hold pending a response from the MFA, have started again.

The timing is not ideal here, as Q1 is when the RIPE NCC issues its 2021 invoices. To avoid further complicating these discussions, the RIPE NCC has postponed invoicing its members in Syria and Iran until it can reach an agreement with its bank.

The RIPE NCC has emailed members in these countries to explain the delay with their invoices and confirm that this will not affect their ability to access its services as usual.

THE BOARD'S POSITION

While this clarification from the MFA addresses risks in terms of the RIPE NCC's sanctions compliance and should help to resolve the banking issue - it also leaves the affected RIPE NCC members in a stable but disadvantaged state.

As we have stated previously, the position of the RIPE NCC Executive Board is that Internet number resources should not be affected by political disputes[3]. The COVID-19 pandemic has shown the critical role the Internet can play in our societies - in many cases it has provided the foundation that supports coordination efforts, keeps our economies operating, and helps us to maintain social contact with others.

The board has therefore instructed the RIPE NCC to continue its work to find some form of lasting and comprehensive exemption from sanctions. We believe it is crucial that all RIPE NCC members can be sure that their ability to access Internet number resources will not be interrupted.

Regards

Christian Kaufmann
RIPE NCC Executive Board Chairman

[1] Sanctions and the RIPE NCC: Current Status and Executive Board Position:
https://www.ripe.net/ripe/mail/archives/ncc-announce/2020-April/001413.html

[2] Sanctions and the RIPE NCC: Status Update:
https://www.ripe.net/ripe/mail/archives/ncc-announce/2020-June/001427.html

[3] Executive Board Resolution on Continuity of Services to all RIPE NCC Members:
https://www.ripe.net/publications/news/about-ripe-ncc-and-ripe/executive-board-resolution-on-continuity-of-services-to-all-ripe-ncc-members