[ncc-announce] [news] Implementing EU Sanctions Exemption

Dear colleagues,

My previous mail [1] explained that Internet number resources fell under an exemption within the EU sanctions regulations against Russia that exclude resources “strictly necessary for the provision of electronic communication services.” I now want to update you on how we will be implementing this.  

In our last sanctions transparency report (published on 11 May), we listed 12 members and End Users who were confirmed to be subject to EU sanctions against Russia (or else were non-cooperative and therefore had to be treated as though they were sanctioned) [2]. We also reported a further 602 cases requiring investigation, which meant that we also had to treat this wider group of members and End Users as though they were sanctioned until they could be investigated by our staff.

On Monday, 12 June, we will begin restoring normal service levels to all members and End Users who fall within the scope of this exemption and we will start processing any requests that were put on hold due to these sanctions. Where applicable, we will remove the "Sanctioned" note that we added to their resources in the RIPE Database. We will also accept new membership applications and sponsorship agreements signed by End Users from sanctioned entities that fall within this exemption.

It's important to note that while most members and End Users impacted by EU sanctions against Russia are covered by this exemption, some are not. Our staff will follow up with all affected members directly to let them know if this exemption applies to their specific case. Members and End Users who do not fall within the scope of the exemption will continue to have reduced service levels as per our regular sanctions procedure [3]. 

We will not invoice sanctioned members that fall under the exemption until we have clarity from our banks regarding their ability to accept payments from them. However, we need to reiterate that all members have the same payment obligations, and so we will require payment once we have resolved the banking issue.

Kind regards

Athina Fragkouli
Chief Legal Officer
RIPE NCC

[1] Dutch Authorities Confirm Internet Number Resources Fall Within Sanctions Exemption:
https://www.ripe.net/ripe/mail/archives/ncc-announce/2023-May/001654.html 

[2] Sanctions Transparency Report (Q3 2023):
https://www.ripe.net/publications/docs/ripe-799 

[3] How Sanctions Affect the RIPE NCC: 
https://labs.ripe.net/author/athina/how-sanctions-affect-the-ripe-ncc