Subject: [hrpc] Fwd: [Gendispatch] IETF LLC Statement on OFAC Compliance Questions

From: Mallory Knodel <[email-masked]>
Date: Thu, 25 Mar 2021 12:51:31 -0400

Hi all,

Noting for our RG here that this statement quotes the UDHR because IETF 
participation is considered mostly speech.

It may also be an interesting thread to follow, backwards (since the 
issue appears sorted by this statement).

-Mallory

-------- Forwarded Message --------
Subject: 	[Gendispatch] IETF LLC Statement on OFAC Compliance Questions
Date: 	Wed, 24 Mar 2021 09:58:21 -0700
From: 	IETF Administration LLC Board of Directors Chair 
<[email-masked]>
Reply-To: 	[email-masked]
To: 	IETF Announcement List <[email-masked]>
CC: 	[email-masked], [email-masked], [email-masked]

Hi – The IETF LLC has today posted a statement on OFAC Compliance 
questions on our blog at 
https://www.ietf.org/blog/ietf-llc-statement-ofac-compliance-questions.

Thanks,
Jason Livingood
Chair, IETF LLC Board
[email-masked]
++++++++++ How to Contact the IETF LLC ++++++++++
Executive Director: [email-masked] Sponsorship: [email-masked]
Board: [email-masked]
++++++++++ General IETF LLC Board Background ++++++++++
About the IETF LLC: https://www.ietf.org/about/administration/
Meeting minutes: https://www.ietf.org/about/groups/llc-board/minutes/
Future meetings: https://www.ietf.org/about/groups/llc-board/meeting-info/
Financial statements: 
https://www.ietf.org/about/administration/financial-statements/

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---

From: farzaneh badii <[email-masked]>
Date: Thu, 25 Mar 2021 13:47:28 -0400

This was a fun read for me. I have been monitoring the effect of sanctions
on Internet infrastructure and access for a few years now. Some problems
might actually be raised for participation at face to face meetings at the
IETF. Or if IETF starts doing fellowships in the future it has to seek an
OFAC license or it will end up not being able to support those from
sanctioned countries.

I think at the moment there are only corner cases that don't really affect
participation at the IETF because: implementation takes place somewhere
else.

I find the "freedom of expression" argument and the US constitution
astonishing. The US constitution doesn't apply to foreign subjects! Years
ago Iranians had limited access to some Google and other tech-corporations
products  because they followed OFAC rules and just restricted access to
their products (easier to exclude 80 million people access than get an OFAC
license)- no one said their freedom of speech must be protected. Worth
mentioning that it's not only Iran that's affected. OFAC had to issue a
general OFAC license and allow for facilitation of noncommercial
communications. The nature of relations and activities are  complex and
unpredictable on the Internet, especially due to different legal
interpretations. We don't know how the court or the OFAC officers are going
to interpret the relationships and the activities. We should monitor the
issue and work on our arguments, but I doubt that if something serious
comes up, we can say what we are doing is only speech... if something
serious comes up, IETF can apply for an OFAC license.

Farzaneh

On Thu, Mar 25, 2021 at 12:52 PM Mallory Knodel <[email-masked]> wrote:

> It may also be an interesting thread to follow, backwards (since the issue
> appears sorted by this statement).
>
> -Mallory
>
>
> <[email-masked]> <[email-masked]>
> <[email-masked]>
> Gendispatch mailing [email-masked]://www.ietf.org/mailman/listinfo/gendispatch
>
> _______________________________________________
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