UANI Launches World Wide Web Campaign, Calls on ICANN and RIPE to Disconnect and Cease Business with Sanctioned Iranian Entities

FOR IMMEDIATE RELEASE
September 18, 2012
Contact: Nathan Carleton, [email protected]
Phone: (212) 554-3296  

UANI Launches World Wide Web Campaign, Calls on ICANN and RIPE to Disconnect and Cease Business with Sanctioned Iranian Entities

New York, NY - On Tuesday, United Against Nuclear Iran (UANI) launched its World Wide Web campaign, and called on both the Internet Corporate for Assigned Names and Numbers (ICANN) and Réseaux IP Européens Network Coordination Centre (RIPE) to disconnect the Internet access of sanction-designated Iranian entities such as its Central Bank and its military's engineering arm.

ICANN, based in Los Angeles, and RIPE, based in Amsterdam, license and authorize sanction-designated Iranian entities to acquire Unique Internet Identifiers, such as ".ir" domain names. These entities, such as Iran's nuclear brain trust, Malek Ashtar University, major Iranian banks, and Khatam al-Anbia, which serves as the IRGC's engineering arm, have active web presences that they misuse to pursue Iran's illegal nuclear weapons program, sponsor terror, and repress the Iranian people.

Sanctioned Iranian entities controlled by the Islamic Revolutionary Guard Corps (IRGC) further misuse their web access while censoring and denying Internet freedoms to the Iranian people.

UANI has presented ICANN and RIPE with a detailed analysis showing how ICANN and RIPE's provision of internet access to the worst of Iran's worst entities clearly violates U.S., EU and U.N. sanction laws.

In a letter sent this month to ICANN executives, UANI CEO, Ambassador Mark D. Wallace, wrote:

By this letter, United Against Nuclear Iran ("UANI") calls upon the Internet Corporate for Assigned Names and Numbers ("ICANN") and its department for key coordination and protocol functions of ICANN - the Internet Assignment Numbers Authority ("IANA") - to publicly clarify its work in Iran and to:

1.  Terminate its relationship with and deny any Iranian entity or person that has been sanction-designated by the United States, the European Union and the United Nations access to and revoke previously assigned Domain Name System ("DNS"), Internet Protocol ("IP") addresses, space allocation, protocol identifier assignment, generic ("gTLD") and country code ("ccTLD") Top-Level Domain name system management, and root server system management functions;

2.  Terminate its relationship and deny ICANN/IANA access to all sanction-designated Iranian entities and persons, including the Islamic Revolutionary Guard Corps ("IRGC") and the Iranian regime, and;

3.  Terminate its relationship and deny database services, technical services and information services to sanction-designated Iranian entities and persons and registrants that service sanction-designated Iranian entities and persons.

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Through RIRs, ICANN/IANA provides the primary means for access to the worldwide web for Internet Service Providers ("ISPs"), telecommunication organizations and end-users within particular regions. Any person or entity within the area covered by the RIPE NCC - including Iran - that has registered for an Internet domain name, utilizes ICANN/IANA services.

Attached is a spreadsheet that lists the web addresses for all Iranian sanction-designated entities with web addresses, their respective local/national registrars and the name servers that have been provided to them by ICANN/IANA through the RIPE NCC (See Exhibit A). No domain name registrant or registrar in the region, including those that provide services to Iranian sanction-designed entities and persons by the U.S., EU and UN, would be able to acquire domain names, IP addresses and ASNs (collectively "Unique Internet Identifiers") without ICANN/IANA. It is the key provider on which Iran wholly depends upon for access to the Internet.

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Unfortunately, ICANN/IANA and the Unique Internet Identifiers that it provides are misused by the sanction-designated Iranian entities and persons to facilitate their illicit operations, activities and communications including support for Iran's rogue nuclear weapons program, Iran's sponsorship of terrorism around the world, and the Iranian regimes brutal crackdown against its own people. Disturbingly, that crackdown includes the ruthless censorship of the Internet and other communication access, and the use of tracking technology to monitor, torture and kill freedom seeking dissidents. For example, on December 28, 2011 - the registration day for Iran's March 2012 parliamentary elections - Iranian Prosecutor-General Abdosamad Khoramabadi unveiled a list of election-related Internet crimes, which includes "calling for an election boycott, the publication of counter-revolutionary or opposition logos or website contents, etc." Further, cybercafés in Iran were required to produce ID, install cameras, keep tape recordings and maintain a record of their clients and a list of websites visited. 

Prominent sanction-designated Iranian entities have acquired .ir Unique Internet Identifiers from ICANN/IANA through the RIPE NCC. For example, Iran's nuclear brain trust, Malek Ashtar University holds the http://www.mut.ac.ir/ address. Major Iranian banks, including the country's central bank, maintain active websites (e.g. http://www.cbi.ir, http://www.bank-maskan.ir, http://www.bmi.ir and http://www.banksepah.ir). Further, Khatam al-Anbia, which serves as the IRGC's engineering arm with over 812 subsidiaries and is heavily involved in the construction of the Qom/Fordow nuclear weapons facilities, holds the web address of http://www.khatam.com. These sanction-designated entities could not gain such web access without ICANN/IANA.

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ICANN/IANA's role in Iran with sanction-designated entities violates various sanctions laws including U.S. and EU law. Given that ICANN/IANA is headquartered in California, it is directly governed by the laws of the U.S. The Iran Sanctions Act of 1996, as amended, prohibits the provision of "goods, services, technology, information, or support that could directly and significantly facilitate the maintenance or expansion of Iran's domestic production of refined petroleum products..." and "contribute materially to the ability of Iran to acquire or develop chemical, biological, or nuclear weapons or related technologies; or acquire or develop destabilizing numbers and types of conventional weapons." ICANN/IANA also provides services to entities and persons on the U.S. Treasury Department's Office of Foreign Assets Control's ("OFAC") Specially Designated Nationals ("SDN") List, which is a list of "individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries" such as Iran, and "also lists individuals, groups, and entities, such as terrorist and narcotics traffickers." Assets of those on the SDN List "are blocked, and U.S. persons are generally prohibited from dealing with them."  Further, Section 106 of the Comprehensive Iran Sanctions Accountability and Divestment Act of 2010 ("CISADA") requires the U.S. to ban the "procurement of goods or services with a person that exports sensitive technology to Iran." CISADA defines sensitive technology as "hardware, software, telecommunications equipment, or any other technology" that is used "(A) to restrict the free flow of unbiased information in Iran; or (B) to disrupt, monitor, or otherwise restrict speech of the people of Iran."

The RIPE NCC is headquartered in Amsterdam and is directly governed by the laws of the EU. Similar to the U.S.'s SDN List, the EU maintains a list of designated parties that are considered to be, among other things, involved in Iran's nuclear or ballistic missiles activities or affiliated with IRGC. In violation of EU law, the RIPE NCC provides key services to such entities and persons. Additionally, on April 19, 2007, the EU implemented UN Security Council Resolution 1737 (2006) by enacting Council Regulation (EC) No. 423/2007, which has now been strengthened by Council Regulation (EU) No. 961/2010 ...

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Please understand that we do not seek this action lightly. We fully support internet freedoms and access to all parties. In this case, however, you are providing internet access to a brutal regime that represses its own people and censors and restricts their ability to dissent and publicly reveal the brutality of the Iranian regime. As U.S. President Barack Obama stated during a video message to the Iranian people, "Because of the actions of the Iranian regime, an Electronic Curtain has fallen around Iran-a barrier that stops the free flow of information and ideas into the country, and denies the rest of the world the benefit of interacting with the Iranian people..." as Iran works to control and monitor what its citizens see and hear. ...

In a separate letter to RIPE CEO Nigel Titley, Ambassador Wallace wrote:

RIPE NCC serves as the RIR for Iran, and its coverage extends to Europe, the Middle East and parts of Central Asia and "provides Internet resource allocations, registration services and coordination activities that support the operation of the Internet globally." Internet resource allocation is distributed in a hierarchical manner. This means that "IANA delegates large ranges of Internet number resources to the RIRs, which then allocate the resources within their regions to members, Local Internet Registries, National Internet Registries, and end-users".

RIRs serve as the primary means for access to the worldwide web for Internet Service Providers ("ISPs"), telecommunication organizations and end-users within particular regions. Any person or entity within the area covered by the RIPE NCC - including Iran - that has registered for an Internet domain name, utilizes RIPE NCC's services.

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Unfortunately, RIPE NCC and the Unique Internet Identifiers that it provides are misused by the sanction-designated Iranian entities and persons to facilitate their illicit operations, activities and communications including support for Iran's rogue nuclear weapons program, Iran's sponsorship of terrorism around the world, and the Iranian regimes brutal crackdown against its own people. Disturbingly, that crackdown includes the ruthless censorship of the Internet and other communication access, and the use of tracking technology to monitor, torture and kill freedom seeking dissidents. For example, on December 28, 2011 - the registration day for Iran's March 2012 parliamentary elections - Iranian Prosecutor-General Abdosamad Khoramabadi unveiled a list of election-related Internet crimes, which includes "calling for an election boycott, the publication of counter-revolutionary or opposition logos or website contents, etc." Further, cybercafés in Iran were required to produce ID, install cameras, keep tape recordings and maintain a record of their clients and a list of websites visited.

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Absent access to the RIPE NCC, the dictatorial regime of Iran would be severely impeded in pursuing its illegal and amoral activities. For each day that the RIPE NCC knowingly continues to provide Iran sanction-designated persons and entities access to the worldwide web, the RIPE NCC will be increasingly complicit in the IRGC and Iranian regime's nefarious behavior. The RIPE NCC must stop transacting with such Iranian entities and persons and deny them access to Unique Web Identifiers, and therefore, the worldwide web. The U.S., EU and UN have enacted a series of sweeping sanctions against Iran. Yet during this period of international consensus and increasing global isolation of Iran, numerous Iranian sanctioned entities continue to acquire and have access to Unique Web Identifiers through the RIPE NCC.

The RIPE NCC should responsibly end all RIPE NCC business and access to Unique Web Identifiers to any U.S., EU or UN Iranian sanction-designated entity or person. As explained below, the RIPE NCC is in violation of law for its provision of services and access to its network to sanction-designated entities and persons. Please immediately cease and desist from providing RIPE NCC access to these entities and persons. ...

Click here to read UANI's full letter to ICANN.
Click here to read UANI's full letter to RIPE.

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