Re: [members-discuss] About transfer policies
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It seems to me they did not notice it earlier, but now they have and are seeking clarification from the issuing authority. Seems completely logical to me. Just because they did not notice it before doesn't mean that they are now forced to continue exactly as before... "doesn't have" on an extract may concern authority to represent a business or something important like that. I don't see what policy is contradicted here? Can you suggest one? -- Regards, Terrence Koeman, PhD/MTh/BPsy Darkness Reigns (Holding) B.V. Please quote relevant replies. Spelling errors courtesy of my 'smart'phone. ________________________________ From: Dmitry P <head@global-data-networks.com> Sent: Tuesday, 3 March 2020 03:13 To: members-discuss@ripe.net Subject: [members-discuss] About transfer policies
Hello,
we are in some weird situation with transfering out an IP range and RIPE doesn't provide any answers to our questions, the transfer is suspended for a very weird reason and we are out of options; I would like to hear other members opinions on that subject with a hope of seeking some answers that RIPE didn't provide after numerous attempts.
Our company's extracts are created by Ukraine's Ministry of Justice and have a specific line near the director field which says '(не має)' right after mentioning the director's name, which means "(doesn't have)" from Ukrainian. ПОЧТАРЬОВ ДМИТРО ОЛЕГОВИЧ - керівник з 25.05.2016 (не має);
We had this line on all our extracts since the company was opened and RIPE has a) accepted us as a member by reviewing those extracts b) approved numerous in and out transfers with those extracts since 2016 c) recently approved a transfer out about 2 weeks ago using the extract with the same line.
4 days ago we have requested another transfer and a RIPE rep. has asked us to clarify about what '(не має)' means in our extract. We have no clue what it means exactly and never interested because it was present since a first extract, also because RIPE has never questioned it before, and as I have mentioned, all the previous extracts came with that line.
We don't have a clue of what it means and the RIPE's rep. decided to suspend the transfer and make a request to Ukraine's Ministry of Justice, which was very unexpected decision from our point of view. She told us that "Though we process tens of requests of Ukrainian companies every day, it's first time that we see such a record. It's not entirely clear what it means and what you as a Director "do not have".", to which I responded it's a false statement, because RIPE certainly HAS SEEN this line before, at least because my company have performed many transfers and requests with RIPE, which have been approved using same extracts. In this case, she talked about her own experience in the name of RIPE, which already was not very professional.
So I obviously asked why does some her or RIPE's unawareness in Ukraine's legislation should concern us, to what I got no answer at all. Are we really responsible for RIPE's lack of knowledge on some subject? Our company is active and the extracts are all valid on the min. justice site, also the signee of the T.A. corresponds to the director name - this all makes us compliant to the RIPE's rules and policies, which, we believe should have made this transfer complete already.
Notwithstanding our expectations, RIPE didn't provide any answer to our questions and also didn't tell why this specific matter should concern this specific transfer, since there were already approved transfers using same extract. Now we must wait about 2 or 3 weeks until the Min. of Justice responds them to clarify this, which made us very disappointed, since we still do not understand why this case affects our transfer at all.
This is very frustrating and we have no more choices but hearing other members opinions and suggestions, if any. Doesn't it look like RIPE is very contradictory to its own policies in this case?
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What's contradictory is there is no policy stating that lacking knowledge on their part about some country's jurisdiction may affect transfers. The requirements for a transfer are an active company and a valid person who is signing the documents, which criteria is being meet completely by our company. In this case they want to make us wait about 2 weeks for a reason that doubtfully affects the transfer at all, since the general criteria is being meet on our side. If they made some mistake of not knowing the jurisdiction in full, why they wouldn't leave that for themselves instead of involving us in the waiting time? For me nothing is logical here, especially, when a company that provided a service to you during 4 years suddenly change their mind about way they do business without prior notification, specially when nothing have changed on your part. At least it's not how business is supposed to work in my opinion. This line doesn't affect the way our company exists, at least it's not the reason to suspend a business with us. It probably means that the director is not backed by an organisation and it's a private person. We have seen a lot of extracts of currently active companies we work with that have a same line, so it's quite common, though I am not sure what it means exactly. On 3/3/20 2:24 AM, Terrence Koeman wrote:
It seems to me they did not notice it earlier, but now they have and are seeking clarification from the issuing authority.
Seems completely logical to me. Just because they did not notice it before doesn't mean that they are now forced to continue exactly as before...
"doesn't have" on an extract may concern authority to represent a business or something important like that. I don't see what policy is contradicted here? Can you suggest one?
-- Regards, Terrence Koeman, PhD/MTh/BPsy Darkness Reigns (Holding) B.V.
Please quote relevant replies. Spelling errors courtesy of my 'smart'phone. ------------------------------------------------------------------------ *From:* Dmitry P <head@global-data-networks.com> *Sent:* Tuesday, 3 March 2020 03:13 *To:* members-discuss@ripe.net *Subject:* [members-discuss] About transfer policies
Hello,
we are in some weird situation with transfering out an IP range and RIPE doesn't provide any answers to our questions, the transfer is suspended for a very weird reason and we are out of options; I would like to hear other members opinions on that subject with a hope of seeking some answers that RIPE didn't provide after numerous attempts.
Our company's extracts are created by Ukraine's Ministry of Justice and have a specific line near the director field which says '(не має)' right after mentioning the director's name, which means "(doesn't have)" from Ukrainian. ПОЧТАРЬОВ ДМИТРО ОЛЕГОВИЧ - керівник з 25.05.2016 (не має);
We had this line on all our extracts since the company was opened and RIPE has a) accepted us as a member by reviewing those extracts b) approved numerous in and out transfers with those extracts since 2016 c) recently approved a transfer out about 2 weeks ago using the extract with the same line.
4 days ago we have requested another transfer and a RIPE rep. has asked us to clarify about what '(не має)' means in our extract. We have no clue what it means exactly and never interested because it was present since a first extract, also because RIPE has never questioned it before, and as I have mentioned, all the previous extracts came with that line.
We don't have a clue of what it means and the RIPE's rep. decided to suspend the transfer and make a request to Ukraine's Ministry of Justice, which was very unexpected decision from our point of view. She told us that "Though we process tens of requests of Ukrainian companies every day, it's first time that we see such a record. It's not entirely clear what it means and what you as a Director "do not have".", to which I responded it's a false statement, because RIPE certainly HAS SEEN this line before, at least because my company have performed many transfers and requests with RIPE, which have been approved using same extracts. In this case, she talked about her own experience in the name of RIPE, which already was not very professional.
So I obviously asked why does some her or RIPE's unawareness in Ukraine's legislation should concern us, to what I got no answer at all. Are we really responsible for RIPE's lack of knowledge on some subject? Our company is active and the extracts are all valid on the min. justice site, also the signee of the T.A. corresponds to the director name - this all makes us compliant to the RIPE's rules and policies, which, we believe should have made this transfer complete already.
Notwithstanding our expectations, RIPE didn't provide any answer to our questions and also didn't tell why this specific matter should concern this specific transfer, since there were already approved transfers using same extract. Now we must wait about 2 or 3 weeks until the Min. of Justice responds them to clarify this, which made us very disappointed, since we still do not understand why this case affects our transfer at all.
This is very frustrating and we have no more choices but hearing other members opinions and suggestions, if any. Doesn't it look like RIPE is very contradictory to its own policies in this case?
_______________________________________________ members-discuss mailing list members-discuss@ripe.net https://lists.ripe.net/mailman/listinfo/members-discuss Unsubscribe: https://lists.ripe.net/mailman/options/members-discuss/terrence%40darkness-r...
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Well, *you* say that you meet the requirement that a valid person is signing the documents, but RIPE is not convinced. And it's RIPE that needs to be convinced before it becomes a fact to them in regards of their policy. That there is some unconnected fact of the matter is irrelevant. If your logic worked I could just send in no documents at all and say "why is it my problem that RIPE doesn't know the content of the documents?" -- Regards, Terrence Koeman, PhD/MTh/BPsy Darkness Reigns (Holding) B.V. Please quote relevant replies.
-----Original Message----- From: members-discuss <members-discuss-bounces@ripe.net> On Behalf Of Dmitry P Sent: Tuesday, March 3, 2020 12:46 PM To: members-discuss@ripe.net Subject: Re: [members-discuss] About transfer policies
What's contradictory is there is no policy stating that lacking knowledge on their part about some country's jurisdiction may affect transfers. The requirements for a transfer are an active company and a valid person who is signing the documents, which criteria is being meet completely by our company.
In this case they want to make us wait about 2 weeks for a reason that doubtfully affects the transfer at all, since the general criteria is being meet on our side. If they made some mistake of not knowing the jurisdiction in full, why they wouldn't leave that for themselves instead of involving us in the waiting time?
For me nothing is logical here, especially, when a company that provided a service to you during 4 years suddenly change their mind about way they do business without prior notification, specially when nothing have changed on your part. At least it's not how business is supposed to work in my opinion.
This line doesn't affect the way our company exists, at least it's not the reason to suspend a business with us. It probably means that the director is not backed by an organisation and it's a private person. We have seen a lot of extracts of currently active companies we work with that have a same line, so it's quite common, though I am not sure what it means exactly.
On 3/3/20 2:24 AM, Terrence Koeman wrote:
It seems to me they did not notice it earlier, but now they have and are seeking clarification from the issuing authority.
Seems completely logical to me. Just because they did not notice it before doesn't mean that they are now forced to continue exactly as before...
"doesn't have" on an extract may concern authority to represent a business or something important like that. I don't see what policy is contradicted here? Can you suggest one?
-- Regards, Terrence Koeman, PhD/MTh/BPsy Darkness Reigns (Holding) B.V.
Please quote relevant replies. Spelling errors courtesy of my 'smart'phone.
________________________________
From: Dmitry P <head@global-data-networks.com> <mailto:head@global- data-networks.com> Sent: Tuesday, 3 March 2020 03:13 To: members-discuss@ripe.net <mailto:members-discuss@ripe.net> Subject: [members-discuss] About transfer policies
Hello,
we are in some weird situation with transfering out an IP range and RIPE doesn't provide any answers to our questions, the transfer is suspended for a very weird reason and we are out of options; I would like to hear other members opinions on that subject with a hope of seeking some answers that RIPE didn't provide after numerous attempts.
Our company's extracts are created by Ukraine's Ministry of Justice and have a specific line near the director field which says '(не має)' right after mentioning the director's name, which means "(doesn't have)" from Ukrainian. ПОЧТАРЬОВ ДМИТРО ОЛЕГОВИЧ - керівник з 25.05.2016 (не має);
We had this line on all our extracts since the company was opened and RIPE has a) accepted us as a member by reviewing those extracts b) approved numerous in and out transfers with those extracts since 2016 c) recently approved a transfer out about 2 weeks ago using the extract with the same line.
4 days ago we have requested another transfer and a RIPE rep. has asked us to clarify about what '(не має)' means in our extract. We have no clue what it means exactly and never interested because it was present since a first extract, also because RIPE has never questioned it before, and as I have mentioned, all the previous extracts came with that line.
We don't have a clue of what it means and the RIPE's rep. decided to suspend the transfer and make a request to Ukraine's Ministry of Justice, which was very unexpected decision from our point of view. She told us that "Though we process tens of requests of Ukrainian companies every day, it's first time that we see such a record. It's not entirely clear what it means and what you as a Director "do not have".", to which I responded it's a false statement, because RIPE certainly HAS SEEN this line before, at least because my company have performed many transfers and requests with RIPE, which have been approved using same extracts. In this case, she talked about her own experience in the name of RIPE, which already was not very professional.
So I obviously asked why does some her or RIPE's unawareness in Ukraine's legislation should concern us, to what I got no answer at all. Are we really responsible for RIPE's lack of knowledge on some subject? Our company is active and the extracts are all valid on the min. justice site, also the signee of the T.A. corresponds to the director name - this all makes us compliant to the RIPE's rules and policies, which, we believe should have made this transfer complete already.
Notwithstanding our expectations, RIPE didn't provide any answer to our questions and also didn't tell why this specific matter should concern this specific transfer, since there were already approved transfers using same extract. Now we must wait about 2 or 3 weeks until the Min. of Justice responds them to clarify this, which made us very disappointed, since we still do not understand why this case affects our transfer at all.
This is very frustrating and we have no more choices but hearing other members opinions and suggestions, if any. Doesn't it look like RIPE is very contradictory to its own policies in this case?
_______________________________________________ members-discuss mailing list members-discuss@ripe.net <mailto:members-discuss@ripe.net> https://lists.ripe.net/mailman/listinfo/members-discuss Unsubscribe: https://lists.ripe.net/mailman/options/members- discuss/terrence%40darkness-reigns.com
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I think what you are telling is out of the context of this issue. Me being a valid person or not in signing the documents is not in question and it is a proven fact because the extracts given by ministry of justice have a unique number that could be accessed and verified online any time by anyone. There are also a lot of resources that facilitate verifying any company information such as this one https://youcontrol.com.ua/en/catalog/company_details/40508891/ so I believe what you said is a little bit out of topic. The RIPE's issue with our extract is different and I believe I've described it very well in my first email. On 3/3/20 2:02 PM, Terrence Koeman wrote:
Well, *you* say that you meet the requirement that a valid person is signing the documents, but RIPE is not convinced. And it's RIPE that needs to be convinced before it becomes a fact to them in regards of their policy. That there is some unconnected fact of the matter is irrelevant.
If your logic worked I could just send in no documents at all and say "why is it my problem that RIPE doesn't know the content of the documents?"
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Dear Dmitry and all, While we do not discuss individual cases in detail publicly, we can share some information with the list on what is happening in situations like this. In some cases, we may undertake a more extended due diligence process that can take longer than usual. This could be, for example, because something has come to our attention that was previously not considered. In such cases we may need to verify issues with third parties (such as national authorities). Due to the number of countries in our service region and the differences in how national authorities in each country operate it is unfortunately not possible to always be aware of the meaning of every detail in the documents that we receive. And when we are not certain about a detail that can potentially be important, we need to verify it. We realise that this is sometimes inconvenient and might mean that the process can take longer for the parties involved. But we see this as essential in order to ensure the security of all our members' resources, especially in the current landscape where IPv4 addresses are increasingly the target of fraud and hijacking attempts. Our processes are not static but adapt where necessary so we can maintain strong due diligence for all members. With regards to our response times, for many years now our general aim has been to respond within one business day. Occasionally we do need more time to work through more complex situations, but in these cases we try to give regular updates as they progress. Kind regards, Nikolas Pediaditis Registration Services & Policy Development Manager RIPE NCC
On 3 Mar 2020, at 16:49, Dmitry P <head@global-data-networks.com> wrote:
I think what you are telling is out of the context of this issue. Me being a valid person or not in signing the documents is not in question and it is a proven fact because the extracts given by ministry of justice have a unique number that could be accessed and verified online any time by anyone. There are also a lot of resources that facilitate verifying any company information such as this one https://youcontrol.com.ua/en/catalog/company_details/40508891/ so I believe what you said is a little bit out of topic.
The RIPE's issue with our extract is different and I believe I've described it very well in my first email.
On 3/3/20 2:02 PM, Terrence Koeman wrote:
Well, *you* say that you meet the requirement that a valid person is signing the documents, but RIPE is not convinced. And it's RIPE that needs to be convinced before it becomes a fact to them in regards of their policy. That there is some unconnected fact of the matter is irrelevant.
If your logic worked I could just send in no documents at all and say "why is it my problem that RIPE doesn't know the content of the documents?"
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participants (3)
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Dmitry P
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Nikolas Pediaditis
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Terrence Koeman