- ncc-services-wg - mailman.ripe.net

Final Cloud Strategy Published
by Felipe Victolla Silveira 13 Sep '23

13 Sep '23

Dear colleagues, We have now published the final version of our cloud strategy, which was approved by our Executive Board at its last meeting in September. You can find this on RIPE Labs here: https://labs.ripe.net/author/felipe_victolla_silveira/ripe-ncc-cloud-strate… <https://labs.ripe.net/author/felipe_victolla_silveira/ripe-ncc-cloud-strate…> Those of you who read our earlier draft won't find any surprises in the document. Apart from making it more concise, the only change is that the use of containers is now allowed under the strict interpretation of our 'Avoid vendor lock-in' requirement (this is noted in the table). The final part is to agree on the criticality of specific services with the community. We will give you an update on this at RIPE 83. Regards Felipe Victolla Silveira Chief Operations Officer RIPE NCC

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Re: [ncc-services-wg] Voluntary Transfer Lock V2
by Максим Смелянец 08 Sep '23

08 Sep '23

Dear Athina, Thank you very much for your reply and clarification. I`d like to draw your attention to what is specifically stated in the Impact Analysis “The RIPE NCC might also not be able to enforce the Lock if it is against any applicable laws or regulations”. That is, we are talking about legislation that can limit the holders rights to block. You write about due diligence procedures, according to which you can accept the documents of providers located in the occupied territories. But questions was specifically about the Impact Analysis for the Voluntary Transfer Lock Policy. When it comes to the specific legislation that can limit voluntary blocking, and as the Impact Analysis states, we can get situation that an ISP in the occupied territory cannot protect its resources because the law of the occupied territory forbids it from doing so. Then it can be concluded that the due diligence procedures completely undermine the purpose of the policy. That is why I am asking you to clarify again this part of the Impact Analysis «The RIPE NCC might also not be able to enforce the Lock if it is against any applicable laws or regulations». Best regards and nice day, Maxim Smelyanets.

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Re: [ncc-services-wg] Voluntary Transfer Lock V2
by Athina Fragkouli 05 Sep '23

05 Sep '23

Dear Maxim, all, Thank you for your email. As a membership association legally-based in the Netherlands, the RIPE NCC will only comply with court orders or other legally-enforceable orders under Dutch law. The RIPE NCC is in principle subject to Dutch and EU legislation. When we receive a request from a member or resource holder, we perform due diligence checks to verify the legality of the request and accompanying documentation. We also perform checks on an ongoing basis after the request has been approved as part of our audit activities. Examples of this can be found in the RIPE NCC procedural documents ‘Due Diligence for the Quality of the RIPE NCC Registration Data [1]’, ‘Transfer of Internet Number Resources and Change of a Member’s Official Legal Name [2]’, and ‘RIPE NCC Audit Activity [3]’. Due diligence checks may take into account legislation that is applicable to the party submitting the request (or the parties involved in the request). We perform these checks to protect the legitimate holder of the resources and to ensure the accuracy of the Internet number resource registry. The RIPE NCC can neither recognise nor deny one state’s authority over a region. According to the RIPE NCC procedural document ‘Due Diligence for the Quality of the RIPE NCC Registration Data [1]’, if a party is located in an area claimed by two or more widely recognised states, the RIPE NCC may accept proof of establishment issued by whichever national authority the signing party chooses. Accordingly, we may evaluate the impact of local legislation or authorities’ decisions on occupied areas on a case by case basis. Regarding the last part of your email, it is impossible to provide a comprehensive list of cases that constitute an exception, as we cannot predict all possible scenarios and the details of specific cases may differ. Discussing potential cases in general is problematic because it can easily lead to incorrect assumptions about our procedures. All of our decisions in this context will be consistent and seek to achieve the goals of the policy. Regards, Athina Fragkouli Chief Legal Officer RIPE NCC [1] Due Diligence for the Quality of the RIPE NCC Registration Data: https://www.ripe.net/publications/docs/ripe-791 [2] Transfer of Internet Number Resources and Change of a Member’s Official Legal Name https://www.ripe.net/publications/docs/ripe-758 [3] RIPE NCC Audit Activity https://www.ripe.net/publications/docs/ripe-694 > > Subject: [ncc-services-wg] Voluntary Transfer Lock V2 > Date: Tue, 29 Aug 2023 08:01:52 +0300 > From: Максим Смелянец <maxim.smelyanets3(a)gmail.com> <mailto:maxim.smelyanets3@gmail.com> > To: ncc-services-wg(a)ripe.net <mailto:ncc-services-wg@ripe.net> > > Hello for everyone! > > In general I agree with the new policy text, thanks for all your efforts and work. > > But I also have some questions and wishes. > > 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 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. > > 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. > > With best regards to everyone, > > > Maxim Smelyanets. >

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Transfer Voluntary Lock
by Oleksandr Tsaran 01 Sep '23

01 Sep '23

Hello. We maintain the current version of the policy. -- Net-City 2020, LLC Oleksandr Tsaran

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Voluntary Transfer Lock Policy
by Igor Tarasenko 31 Aug '23

31 Aug '23

Dear Colleagues, Good job with new policy draft, I support it. Best regards, Igor Tarasenko

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Voluntary Transfer Lock V2
by Максим Смелянец 30 Aug '23

30 Aug '23

Hello for everyone! In general I agree with the new policy text, thanks for all your efforts and work. But I also have some questions and wishes. 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 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. 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. With best regards to everyone, Maxim Smelyanets.

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Review phase for 2023-03
by Rob Evans 29 Aug '23

29 Aug '23

All, Thank you for those that have stated their support for 2023-03, this is just a reminder that the review phase finishes this Thursday, 31st August. Please send any comments to the list before then. Cheers, Rob on behalf of NCC Services WG Co-Chairs.

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Voluntary Transfer Lock Policy
by Alexey Levanenko 28 Aug '23

28 Aug '23

Hi working group! I support the current policy proposal text. Kind regards, Olexiy Levanenko.

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Voluntary Transfer Lock Policy
by Oksana Prykhodko 28 Aug '23

28 Aug '23

Dear all, I would like to welcome and support a great job on drafting Voluntary Transfer Lock Policy! Kind regards, Oksana Prykhodko, director of iNGO European Media Platform

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Voluntary Transfer Lock Policy
by Volodymyr Kuzmin 28 Aug '23

28 Aug '23

Hi working group! I support the current policy proposal text. -- Best regards, Volodymyr Kuzmin Chief Technical Officer, Web Pro LLC mob +38(093)-711-92-66 https://webpro.ua

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