How safe are our domain names from US sanctions?
Hi all, As we all know, the DNS infrastructure has been built to be decentralised and resilient, so that its functionality does not depend on a single continent, country or government. But what if your gTLD domain name can be wiped out of the DNS by a single government? This is exactly what happened to Autistici/Inventati (A/I), an Italian non-profit, volunteer-run service provider that caters to hundreds of activist groups around the world. They have operated using the autistici.org domain name for the past 25 years. On August 26, the Office of Foreign Assets Control (OFAC) at the US Department of the Treasury included them in their list of “Specially Designated Global Terrorists” (SDGT). On August 28, PIR, the US headquartered registry operator for the .org TLD, placed autistici.org on status severHold, effectively wiping it from the DNS. This all happened without A/I committing any crime, neither in Italy nor in the US, and without any prosecutor ever indicting them either for felonies or misdemeanors. Simply the fact they provided services to certain activist groups that may be labeled as controversial or extremist by some authorities, was enough to place the whole provider on the SDGT list. In this case it was PIR (created by ISOC) that acted on the sanctions imposed by OFAC, although PIR still hasn't officially released any statement about this. A lot of organisations with an .org domain name are now very concerned about the future of their domains, but .org is not the only large gTLD that is run by a US based registry operator, both .net and .com are operated by Verisign, which is also headquartered in the US. So we can not rule out that something similar could happen to other domains. As an example: Just over two weeks ago, the US Department of the Treasury has begun "Operation Economic Outcast: an unprecedented, whole-of-government, economic campaign against the Islamic Republic of Iran and its enablers. The Treasury is significantly expanding sanctions risk for those who continue to choose to do business with Iran." What if RIPE NCC would be classified as an organisation that provides services to sanctioned entities, could that mean that ripe.net gets put on serverHold? Should we still depend so heavily on US based gTLD registry operators? For more background on the A/I case, see: https://www.article19.org/resources/usa-terrorism-designation-has-global-con... https://keepitfree.ai/ https://www.inventati.org/ Timo
Hello Timo, I think your concerns should not be left unanswered. While less likely that RIPE itself will be affected, it is not impossible. They delegate IP space for Ukraine/Russia, Israel/Palestine, Iran and such. Managing this for such (political) conflict zones does come with legal risk. Ideally RIR's should be able to carry out their work regardless of sanctions. But that is a political question about an infrastructure's legal immunity. And a technical workgroup is perhaps not the best place to answer that... (Unless someone here is also from RIPE's legal team?) Organizations like the one you mentioned should take care choosing a TLD. The ccTLD of one's own country usually only answers to the local laws. And if they do apply sanctions, you will likely have legal options available. For decentralization's sake, i make the suggestion to move one of the three main TLD's (.net, .com, .org) under Europa's management. This might distribute and improve legal stability of the DNS ecosystem. (And if this is not possible, that is indicative of a problem with DNS!) Does anyone of the WG have opinions over this? Sincerely, Named T. Relay On Monday, September 14th, 2026 at 1:01 AM, Timo Hilbrink via dns-wg <dns-wg@ripe.net> wrote:
Hi all,
As we all know, the DNS infrastructure has been built to be decentralised and resilient, so that its functionality does not depend on a single continent, country or government. But what if your gTLD domain name can be wiped out of the DNS by a single government?
This is exactly what happened to Autistici/Inventati (A/I), an Italian non-profit, volunteer-run service provider that caters to hundreds of activist groups around the world. They have operated using the autistici.org domain name for the past 25 years.
On August 26, the Office of Foreign Assets Control (OFAC) at the US Department of the Treasury included them in their list of “Specially Designated Global Terrorists” (SDGT). On August 28, PIR, the US headquartered registry operator for the .org TLD, placed autistici.org on status severHold, effectively wiping it from the DNS.
This all happened without A/I committing any crime, neither in Italy nor in the US, and without any prosecutor ever indicting them either for felonies or misdemeanors. Simply the fact they provided services to certain activist groups that may be labeled as controversial or extremist by some authorities, was enough to place the whole provider on the SDGT list.
In this case it was PIR (created by ISOC) that acted on the sanctions imposed by OFAC, although PIR still hasn't officially released any statement about this. A lot of organisations with an .org domain name are now very concerned about the future of their domains, but .org is not the only large gTLD that is run by a US based registry operator, both .net and .com are operated by Verisign, which is also headquartered in the US. So we can not rule out that something similar could happen to other domains.
As an example: Just over two weeks ago, the US Department of the Treasury has begun "Operation Economic Outcast: an unprecedented, whole-of-government, economic campaign against the Islamic Republic of Iran and its enablers. The Treasury is significantly expanding sanctions risk for those who continue to choose to do business with Iran."
What if RIPE NCC would be classified as an organisation that provides services to sanctioned entities, could that mean that ripe.net gets put on serverHold?
Should we still depend so heavily on US based gTLD registry operators?
For more background on the A/I case, see: https://www.article19.org/resources/usa-terrorism-designation-has-global-con... https://keepitfree.ai/ https://www.inventati.org/
Timo ----- To unsubscribe from this mailing list or change your subscription options, please visit: https://mailman.ripe.net/mailman3/lists/dns-wg.ripe.net/ As we have migrated to Mailman 3, you will need to create an account with the email matching your subscription before you can change your settings. More details at: https://www.ripe.net/membership/mail/mailman-3-migration/
Responding in reverse order of your paragraphs: On Tue, Sep 15, 2026 at 06:46:41AM +0000, Named T. Relay via dns-wg wrote:
For decentralization's sake, i make the suggestion to move one of the three main TLD's (.net, .com, .org) under Europa's management. This might distribute and improve legal stability of the DNS ecosystem. (And if this is not possible, that is indicative of a problem with DNS!)
This sounds like wishful thinking because you must be well aware that these large TLDs are operated and administered in a different jurisdiction that would not give up their control over it. They are also run as businesses. And how would moving just one TLD such as org. help avoid such issues for the domains under a different TLD that was not moved such as com. ?
Organizations like the one you mentioned should take care choosing a TLD. The ccTLD of one's own country usually only answers to the local laws. And if they do apply sanctions, you will likely have legal options available.
DNS names, social media accounts, etc. become identifiers which an audience uses to identify and receive information. So they are a popular target of takedowns. There is hurt and outrage when the audience is no longer able to reach the source, and the source is no longer able to publish to their audience. Third-parties who like to call out the erosion of freedom also like to participate. DNS and social media operators may be target of this outrage, but they operate under laws and have to obey the government's directives. The com./net./org. TLDs have been popular choices for registrants as they are associated with being familiar to users, especially com. Some social media platforms are also preferred over others due to the amount of audience a creator can quickly reach, but their content may not be compatible with the jurisdiction of the person (individual, company) that owns and operates the service. Even within a country, within a single administrative boundary of "local laws", dissent may be silenced and property of various kinds may be seized if one falls afoul of the government. Internet resources may appear to "belong" to a registrant, but they are not inalienable. As you mention, some ccTLDs could offer more protection against takedowns, even to foreign internet website owners. Perhaps the better course of action may be to promote knowledge/educate registrants that other TLD choices are available and the core gTLDs may not be the best choice for a given website's content. Mukund
On 15/09/2026 12:31, Mukund Sivaraman wrote:
This sounds like wishful thinking because you must be well aware that these large TLDs are operated and administered in a different jurisdiction that would not give up their control over it. They are also run as businesses. And how would moving just one TLD such as org. help avoid such issues for the domains under a different TLD that was not moved such as com. ? ...
The com./net./org. TLDs have been popular choices for registrants as they are associated with being familiar to users, especially com. Some social media platforms are also preferred over others due to the amount of audience a creator can quickly reach, but their content may not be compatible with the jurisdiction of the person (individual, company) that owns and operates the service.
There are so many gtlds these days, why not just leave .org and move content to any of the other possibilities: https://getnonprofitweb.site/top-level-domain-for-nonprofits/ as well as .community (examples - https://samarth.community/ - https://mlops.community/) Regards, Hank
On 16. Sep 2026, at 07:36, Hank Nussbacher <hank@efes.iucc.ac.il> wrote:
There are so many gtlds these days, why not just leave .org and move content to any of the other possibilities: https://getnonprofitweb.site/top-level-domain-for-nonprofits/ as well as .community (examples - https://samarth.community/ - https://mlops.community/)
It's not about the TLD itself but rather about the Registry that manages the TLD. Ironically, the nonprofit TLDs you suggest (.ngo, .ong, .foundation, …) are all managed by PIR, the same US-based registry that also manages .org. So, no luck, I guess … Cheers -Andi
participants (5)
-
Andreas Härpfer -
Hank Nussbacher -
Mukund Sivaraman -
Named T. Relay -
Timo Hilbrink