Athina Fragkouli

A Note on Our Latest Sanctions Transparency Report

Athina Fragkouli

We recently removed sanctions-related restrictions from 49 RIPE NCC members and End Users who can now access our services again. In this article we provide some background information to explain why this is.

EU exemption and clarification from the Dutch authorities

As part of its sixth package of Russian sanctions released in 2022, the EU regulations introduced an exemption concerning 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.”

After this exemption was introduced, the RIPE NCC asked the Dutch authorities to clarify whether this exemption applies to Internet number resources. In April 2023, we received an official confirmation that it does (this was announced to the RIPE NCC membership shortly afterwards).

In our latest report

You can find our latest report here.

Our previous sanctions transparency report (published 11 May), listed 13 members and End Users who were confirmed to be subject to EU sanctions against Russia (or else were non-cooperative and had to be treated as though they were sanctioned). We also reported a further 602 cases requiring investigation, which meant that we also had to treat this wider group of members and End Users as though they were sanctioned until they could be investigated by our staff.

Since our last report, 34 members and 15 End Users have been confirmed as falling under the sanctions exemption. Some of the members and End Users who were marked as non-cooperative have also been confirmed as being exempted. This is reflected in our latest report with 8 members and 3 End Users who were previously confirmed as being subject to EU sanctions being removed from the table (the remaining members/End Users are those who were under investigation but not yet confirmed as being subject to EU sanctions).

In June 2023, we began restoring normal service levels to all members and End Users who fell within the scope of this exemption and started processing any requests that had been put on hold. Where applicable, we removed the ‘Sanctioned’ note we had added to their resources in the RIPE Database. We are also able to accept new membership applications and sponsorship agreements signed by End Users from sanctioned entities that fall within this exemption.

It's important to note that while most members and End Users subject to EU sanctions against Russia are covered by this exemption, some are not. Our staff will follow up with all affected members directly to let them know if this exemption applies to their specific case. Members and End Users who do not fall within the scope of the exemption will continue to have reduced service levels as per our regular sanctions procedure.

Finally, we have also started invoicing sanctioned members that fall under this exemption, after receiving clarification from our banks regarding their ability to accept payments from them. We need to reiterate that all members have the same payment obligations, and so we will require payment from all sanctioned members, exempted or not, once we have resolved the banking issue.

We are committed to providing services to all of our members

Since this can sometimes be a source of confusion, it is important to remind readers of the RIPE NCC’s approach to sanctions. A resolution from our Executive Board in 2022 clearly restated our position:

The Executive Board of the RIPE NCC believes that the means to communicate should not be affected by domestic political disputes, international conflicts or war. This includes the provision of correctly registered Internet numbering resources.
The Executive Board of the RIPE NCC is committed to taking all lawful steps available to ensure that the RIPE NCC can provide undisrupted services to all members across our service region and the global Internet community.
The RIPE NCC will publicly document all its efforts to ensure that the registry is not negatively affected by laws, regulations or political developments.

We will therefore continue to investigate the possibility of a blanket exemption from EU sanctions regulation for Internet number resources.


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About the author

I am the Chief Legal Officer at the RIPE NCC, responsible for all legal aspects of the organisation.

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