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.