[ncc-services-wg] Voluntary Transfer Lock V2

Hi,

> There are some notices in the Impact Analysis as «There might be situations where the RIPE NCC cannot enforce the Lock. If the RIPE NCC receives a legally binding decision/order related to Internet number resources under a Lock, the RIPE NCC will have to comply with the order.

The RIPE NCC is based in The Netherlands, so to be legally binding to the RIPE NCC it has to be legally binding under Dutch law.

> The RIPE NCC might also not be able to enforce the Lock if it is against any applicable laws or regulations». Can you concretize what does it mean «binding decision/order»? And when you write about the «any applicable lows and regulations» - what exactly it meant by this? The same applies to the text of the policy itself in the paragraph Implementation Choices when you wrote about restrictions from any applicable laws or regulations. It is not clear what applicable lows do you mean. Because for example for Ukrainian holders it can be read as you can apply also low of occupying authorities.

It is intended to laws and regulations that apply to RIPE NCC. Athina: can you confirm or clarify how the RIPE NCC reads that bit of the policy proposal?

> And my wish is to clarify all exceptions of the inability to enforce the lock and provide a comprehensive list of cases that constitute an exception, or provide criteria for determining the relevant situations in further accompanying documents or in the final version of the policy. Because the lack of clarity may lead to inconsistent decision-making and the implementation of the RIPE NCC blocking mechanism.

I understand what you mean, but it is impossible to make an extensive list, as laws and regulations are always changing, and sometimes depend on the view of a (Dutch) judge etc. They are also not something we can influence in a policy: RIPE NCC *always* has to follow Dutch laws and regulations, no matter what we write :)

Cheers,
Sander