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

2023-03 Voluntary Transfer Lock
by Peter Hessler 20 May '23

20 May '23

I support 2023-03 Voluntary Transfer Lock. This is a good option for all members to have available. Since it is voluntary, and has the same authority requirements as transfers, I feel there is minimal risk that this will be inappropriately used. I also feel that we should _not_ unduely delay acceptance of this policy, even if we wish to propose another policy on this topic. Crucially, the very first sentence of: https://www.ripe.net/manage-ips-and-asns/resource-transfers-and-mergers/tra… gives us all of the authority needed: """All resource holders in the RIPE NCC region can transfer resources in accordance with RIPE policies.""" Furthermore, I disagree with Denis that there is a conflict between policies. This policy is clearly intended to carve out an exception, and it is very specific in describing how. -peter -- There are no data that cannot be plotted on a straight line if the axis are chosen correctly.

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Update of RIPE NCC Procedural Document and Transfer Agreement Template
by Kevin Brennan 19 May '23

19 May '23

Dear colleagues, The RIPE NCC Procedural document 'Closure of Members, Deregistration of Internet Resources and Legacy Resources' has been reviewed and updated. The following is an overview of the amendments made. Section A.1.2.1 (c) Incorrect registration in the RIPE Database was amended through the deletion of the following wording: “The inetnum and the inet6num object(s) for approved assignments must use the netname(s) approved by the RIPE NCC and not be larger than the size approved by the RIPE NCC” The reason for this change is that the RIPE NCC no longer approves assignments or netnames in this regard. Deletion of this wording under the abovementioned section therefore aligns current practices with the procedure outlined in ‘Closure of Members, Deregistration of Internet Resources and Legacy Resources’. Section B 1. (c) Deregistration of Internet Number Resources was amended for the same reason, with the same wording being deleted under this section as outlined above. Section B.1. (b) Deregistration of Internet Number Resources was further amended in order to correctly reflect current RIPE policy with regards to the needs-based approach for RIPE NCC-assigned resources. Resources are no longer allocated for a specific need. However, the RIPE NCC may assign resources to members/End Users for a specific need. Slight changes were made to the wording under this section to remove reference to historical RIPE policy provisions and to align it with current RIPE policy. Secondly, the RIPE NCC Transfer Agreement Template has been reviewed and updated. The following articles have been added: “2.1 The terms and conditions of this Transfer Agreement do not violate any existing laws applicable to the Offering Party or to the Receiving Party. 2.2 In the event that this Transfer Agreement is nullified or deemed invalid due to violation of laws described in Article 2.1, the transfer of registration of Internet Number Resources shall be reverted and the Internet Number Resources shall be returned to the Offering Party”. In light of a request for transfer of Internet Number Resources, the RIPE NCC was made aware of a law prohibitingcertain transactions between Ukrainian and Russian entities. Considering that different national laws might be applicable to the parties signing a transfer agreement, these articles were added in order for the RIPE NCC to have the parties’ confirmation that the Transfer Agreement does not violate any of the laws applicable to them, and their agreement that, in the event that the Transfer Agreement is nullified or deemed invalid due to violation of such laws, the transfer will be reverted and the Internet Number Resources will be returned to the Offering Party. Members are advised to use the updated Transfer Agreement template (v6.0) from the date of this announcement onwards. You can find the updated documents at: https://www.ripe.net/publications/docs/ripe-798 https://www.ripe.net/manage-ips-and-asns/resource-transfers-and-mergers/tra… Kind regards, Kevin Brennan Legal Counsel RIPE NCC

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NCC Services WG Draft Agenda - RIPE88
by Bijal Sanghani 19 May '23

19 May '23

Dear all, Below and shortly online you can find the NCC Services working group draft agenda, any additions or comments welcome. Kind regards, NCC Services working group chairs === Date: Wednesday 24 May 2023 Time: 14:30 - 16:00 CEST Chair: Kurtis Lindqvist Co-Chair: Rob Evans, Bijal Sanghani A. Administrative Matters (5 minutes) Welcome Select a scribe Finalise agenda Approve minutes from RIPE 85 - https://www.ripe.net/participate/ripe/wg/active-wg/services/minutes/ripe-85 <https://www.ripe.net/participate/ripe/wg/active-wg/services/minutes/ripe-85> B. RIPE NCC Past and Future Hans Petter Holen, RIPE NCC (20 mins) C. Registry and Technology Update Felipe Victolla Silveira, RIPE NCC (20 mins) D. RIPE NCC Survey 2023 Fergal Cunningham, RIPE NCC (10 mins) E. 2023-03 Voluntary Transfer Lock - Next steps Angela Dall’Ara, RIPE NCC (10 mins) F. Board as a service Christian Kaufmann (15 minutes) G. Open Microphone Session Kurtis Lindqvist, WG Chair (5 minutes) Z. Any other business Kurtis Lindqvist, WG Chair (5 minutes)

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Dutch Authorities Confirm Internet Number Resources Fall Within Sanctions Exemption
by Athina Fragkouli 17 May '23

17 May '23

Dear colleagues, Last week, we received confirmation from the Dutch authorities on a matter regarding the EU sanctions related to freezing or not making available economic resources to listed entities in Russia. They confirmed that Internet number resources fall within an exemption that was introduced in 2022, which excludes resources that are “strictly necessary for the provision of electronic communication services”. We are currently discussing internally the operational consequences of this confirmation and we will share more information once we are clear on how we will implement this. Background: As an association under Dutch law, the RIPE NCC is in principle subject to Dutch and EU legislation, and the Dutch authorities are responsible for their enforcement. In general, EU sanctions regulations relate to: Prohibiting specific products and services from being provided in a specific country. RIPE NCC services are not included in these regulations. Financial restrictions, which consist of: Freezing of funds and economic resources belonging to designated persons and entities; and A prohibition on making funds and economic resources available to such persons and entities. While country-based sanctions are not relevant to us, the financial restrictions (2.) are. This is because the registration of Internet number resources is considered an economic resource. Accordingly, we are prohibited from making new Internet number resources available to any sanctioned persons or entities. We are also required to freeze any resources they already have. The EU exemption: As part of its sixth package of Russian sanctions, the EU regulations introduced an exemption to the above mentioned financial restrictions. The exemption reads: “[Financial restrictions] shall not apply to funds or economic resources that are strictly necessary for the provision of electronic communication services by Union telecommunication operators, for the provision of associated facilities and services necessary for the operation, maintenance and security of such electronic communication services, in Russia, in Ukraine, in the Union, between Russia and the Union, and between Ukraine and the Union, and for data center services in the Union.” Clarification by the Dutch authorities: Following the introduction of this exemption in the EU regulation about Russian sanctions, the RIPE NCC requested clarification from the Dutch authorities on whether this exemption applies to Internet number resources. Last week we received an official confirmation from the Dutch authorities that the exemption applies indeed to Internet number resources. Operational consequences: We are now reviewing the operational consequences of this exemption and the relevant amendments that will be required to our current procedure. We will share more information about this once our review is finalised. Kind regards, Athina Fragkouli Chief Legal Officer RIPE NCC

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2023-03 status problem
by Sander Steffann 16 May '23

16 May '23

Hello working group, As the authors were in a bit of a difficult position. The chairs won't move this policy proposal forward as there was no feedback during the discussion phase. We were under the impression that the chairs had extended the deadline of the phase as we did talk about that, but it didn’t actually happen. When I sent my reminder the discussion phase was therefore already over, so all the support and feedback we got then Doesn’t Count™. They have indicated that they will only reopen the discussion phase if they know that there actually will be engagement for this to be meaningful. So, can the people who are interested in this proposal please pinky swear that they will contribute if it does get another discussion phase? ;) You may have to repeat your feedback in the proper phase of the PDP to be counted. This approach is less pragmatic than I would have chose when I was a chair, but this is not my working group :) And the chairs are right that the reason for this being a policy proposal is that the NCC (legal) team wants formal community support, so I can see why they are following the process to the letter. So let’s do this formally right. PS: Denis, thank you for your contribution! We’re going to ask the RIPE NCC to comment on the interaction between the policies, and whether a separate policy like this one (with maybe a cleanup of the text in Address Policy) is preferred to integrating this in the transfer policy or not. Considering that the RIPE NCC gave us a hard deadline to get this policy in place, I’m hesitant to restart the whole process this late. Cheers! Sander --- for every complex problem, there’s a solution that is simple, neat, and wrong

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Proposed Service Criticality Forms
by Theodoros Polychniatis 12 May '23

12 May '23

Dear Colleagues, During the RIPE NCC Services WG session at RIPE 84 in May, we discussed the Service Criticality Framework (https://ripe84.ripe.net/wp-content/uploads/presentations/101-101-Technology… and https://ripe84.ripe.net/archives/video/811). We mentioned that we would like the Working Group's input on the criticality ratings for www.ripe.net, our email service (MX), RIPE NCC Access (SSO) and the LIR Portal. We have completed the forms internally and would like to share them with you. We hope to receive your feedback by 23 December. Best regards, Theo -- Theodoros Polychniatis Asst. Manager Software Engineering RIPE NCC

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2023-03 Voluntary Transfer Lock
by James Kennedy 12 May '23

12 May '23

Hello, > Why don't we keep it simple? Let's modify ripe-682 and include an opt out clause to disallow transfers. If you invoke this opt out it is a part of ripe-682 so you are not violating it. All the transfer rules are in one policy, self contained and consistent. +1. This is the best permanent solution that I've heard so far. It would take some time to get through the PDP though, and a transfer lock mechanism is urgently needed by some members immediately. So I also support 2023-03 as a stopgap. 2023-03 may contradict ripe-682 as Denis flagged, but IMHO it's more important to get a ‘better-than-nothing’ temporary solution implemented ASAP. Regards, James

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Re: [ncc-services-wg] 2023-03 Voluntary Transfer Lock
by Athina Fragkouli 05 May '23

05 May '23

Dear Rob, all, At the last RIPE meeting in October 2022, a number of Ukrainian members asked for a way to prevent their resources from being transferred, even if a request was submitted that was compliant with RIPE policy. As the RIPE policy does not currently give the RIPE NCC the right to reject a compliant transfer request, we expressed our reluctance to take any decisions that would violate the RIPE policies, as this would potentially expose the RIPE NCC to liability and set a dangerous precedent. If, for example, a resource holder that has asked the RIPE NCC to restrict their ability to transfer resources later sends a policy-compliant transfer request, we would have a hard time rejecting their request without a relevant RIPE policy. In such a case, the resource holder may accuse the RIPE NCC of not adhering to RIPE policies or delaying the transfer without a solid basis. One might argue that the earlier request (to prevent any transfers) accompanied by some form of signed agreement could provide such a solid basis. However, the RIPE NCC cannot enter into agreements that violate RIPE policies or restrict their applicability. Any legal framework the RIPE NCC creates is to facilitate the implementation of RIPE policies, never to violate or restrict them. Recognising the time needed to develop a policy and the related PDP timeframes, and the level of support expressed by the RIPE community for a temporary solution, the RIPE NCC Executive Board decided in December 2022 to allow members and End Users (represented by their sponsoring LIRs) to request the prevention of their resources from being transferred for a period of six months, (i.e. until 1 July 2023): https://www.ripe.net/about-us/executive-board/minutes/2022/minutes-163rd-ex… The RIPE NCC Executive Board will review this decision in June. This temporary solution was based on an explicit understanding that the RIPE community would use this time to develop a RIPE policy that provides a more permanent solution. Kind regards, Athina Fragkouli Chief Legal Officer RIPE NCC

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2023-03 Voluntary Transfer Lock
by Rob Evans 03 May '23

03 May '23

Colleagues, It is four weeks since the end of the discussion phase of 2023-03. During the discussion phase there was no support expressed on the ncc-services-wg list for the policy proposal. Since the end of the discussion phase a small amount of support has been expressed, as well as several questions relating to why this was being handled via the PDP rather than as an NCC process. During the WG meeting in Belgrade, Athina commented that the NCC believed that denying members a service that existed in policy (transfers) was not something the NCC had done before and the NCC believed that without a policy backing up the process, it opened them up to liability. Could I invite the NCC’s legal counsel to confirm that is the case, to explain what liability the NCC believes they would be open to, and how the adoption of this policy would reduce that? Many thanks, Rob o.b.o NCC Services WG Chairs.

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2023-03 New Policy Proposal (Voluntary Transfer Lock)
by Angela Dall'Ara 27 Apr '23

27 Apr '23

Dear colleagues, A new RIPE Policy Proposal, 2023-03, “Voluntary Transfer Lock” is now available for discussion. The goal of this proposal is to allow resource holders whose resources are registered with the RIPE NCC to inform them which of these resources must not be transferred for a certain amount of time. You can find the full proposal at: https://www.ripe.net/participate/policies/proposals/2023-03 As per the RIPE Policy Development Process (PDP), the purpose of this four-week Discussion Phase is to discuss the proposal and provide feedback to the proposers. At the end of the Discussion Phase, the proposers, with the agreement of the WG Chairs, will decide how to proceed with the proposal. The PDP document can be found at: https://www.ripe.net/publications/docs/ripe-781 We encourage you to review this proposal and send your comments to ncc-services-wg(a)ripe.net before 6 April 2023. Kind regards, Angela Dall'Ara Policy Officer RIPE NCC

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