3 апр. 2019 г., в 18:55, Sascha Luck [ml] <ripe-md@c4inet.net> написал(а):

On Wed, Apr 03, 2019 at 06:32:06PM +0300, Andrejs Guba wrote:
I think that mistakes and typos should be somehow distinguished from cases
where falsified documents and data is used.
Let’s say after serious mistake RIPE NCC should WARN LIR. Three serious
mistakes = closure.
Falsified documents = closure.

Yes, definitely!

There must be compelling reasons for closing a membership. And this decision must be preceded by a specific warning (penalty).

In addition, cases of forgery (photoshop, fabricated registration documents, etc. ..) and unintentional errors should be treated differently.

That is - incorrect data is not equal to falsification!

For example, when the end-user sends a scan PI-agreement signed by the person that is not in the founding documents (head of department)?

Will this be considered a violation?

Or in the agreement clearly shows that the signature is a facsimile and not a real handwritten signature?

It is indicated that the agreement is valid in electronic form. Is this a violation?

In general, we need a simple and transparent rules describing the purpose of penalties.

Perhaps it will be good practice to make public information about the penalty on ripe.net web-site and/or create a certain grade scale for each LIR.

And of course, such steps must be slow, gradual and accurate. No hurry!

I've yet to hear of a case where the NCC deregistered/closed a
LIR without giving it ample oportunity to correct any incorrect
data. This does not mean it *couldn't* though, the contract language
provides for it

:)) That is exactly what happened to us ...

We would like to be able to explain without referring to the procedure of Arbitration, but unfortunately we were not given such an opportunity.

another interesting insertion into ripe-716:

"In the event a Dutch authority orders the RIPE NCC to deregister
specific Internet number resources, the RIPE NCC may comply
without following the process or the timeframes described above."

Note that this does not mention any court orders. One wonders who
the "Dutch authorities" are that can order the NCC to dereg
resources... Police? Amsterdam Dog Warden? BREIN?

It could be funny if it were not so sad, right now we are seeing the RIPE NCC becoming the REGULATOR instead of the COORDINATOR.

Considering the latest offers from the RIPE NCC about BGP hijacks, this is similar to how government structures (RKN) operate in Russia.

P.S. sorry for my clumsy english ...

—

regards,

Nikolay Gorstkin

rgds,
SL

Kind regards,

Andrejs Guba

Dear Maria,

Thank you for the announcement.

I'm moving the discussion to members-discuss.

Other amendments were carried out to align the wording of specific
sections with the wording used in the rest of the document, the RIPE NCC
Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other
RIPE NCC procedural documents (Section A.1.1). Similarly, changes were
made to reflect changes in the RIPE Database (both operational and
structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and
B.1.c).

I would not call this 'wording changes':

$ diff ripe697 ripe716
7c7
< The Member repeatedly provides falsified data or information, or
purposefully and/or repeatedly provides incorrect data or information (for
example, falsified registration documents or IDs, incorrect/inaccurate
contact details, etc.).
---
The Member provides falsified or misleading data or information (for
example, falsified registration documents or IDs), or repeatedly
provides incorrect data or information (for example,
incorrect/inaccurate contact details).
11c11
< The Member submits repeatedly fraudulent requests for Internet number
resources (for example, providing incorrect purpose/need or falsified
information about the network, etc.).
---
The Member submits fraudulent requests for Internet number resources
(for example, providing incorrect purpose/need or falsified information
about the network, etc.).

So the word 'repeatedly' disappear and in case of _any_ only document
mistake, deliberately or not made by the member, the RIPE NCC can call
this 'misleading data' or 'fraudulent request' and terminate the
membership?

Thank you.

--
Kind regards,
Sergey Myasoedov

On 1 Apr 2019, at 10:56, Maria Stafyla <mstafyla@ripe.net> wrote:

Dear Colleagues,

The RIPE NCC Procedural document 'Closure of Members, Deregistration of
Internet Resources and Legacy Resources' has recently been reviewed and
updated. The following is an overview of the amendments made.

Section A.1.1 was amended to include situations where both the Member
and the RIPE NCC agree to terminate the SSA before the usual three month
period has passed. Other changes were made to avoid duplication of
information.

Section B.2 was updated to specify certain conditions under which a
three month timeframe for deregistration of either Member or End User
resources would be unreasonable.

The wording in Section B.2.1 was amended to clarify that during the
deregistration process the Member is not allowed to make new
announcements using the resources to be deregistered, and that the RIPE
NCC will update the maintainer on all the Member's resource objects -
not just on the inetnum object.

Section B.2.2 was amended to bring about alignment of the procedures for
the deregistration of End User and Member resources and to clarify that
if an End User does not have a sponsoring LIR when the deregistration
procedure is initiated, they must first establish a contractual
relationship with one before they can object to that procedure.

Other amendments were carried out to align the wording of specific
sections with the wording used in the rest of the document, the RIPE NCC
Standard Service Agreement (Sections A.1.2.2.g and B.1.d), and other
RIPE NCC procedural documents (Section A.1.1). Similarly, changes were
made to reflect changes in the RIPE Database (both operational and
structural) and in RIPE Policy requirements (Sections A.1.2.1.1.c and
B.1.c).

Please see here the relevant link:
https://www.ripe.net/publications/docs/ripe-716/

Kind regards,

Maria Stafyla
Legal Counsel
RIPE NCC

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