[Ncsg-discuss] [EXTERNAL] Statement of the Noncommercial Stakeholders Group (NCSG) on the Suspension of Domain Services

[Reynaldo Alonso Reyes]

Unfortunately, the United States government uses the list of those who
presumably sponsor terrorism or are terrorists, an utterly spurious list,
for political purposes, to label and then sanction governments or
organizations that are inconvenient to its policies.
S,
Reynaldo

MSc. Reynaldo Alonso Reyes
         Presidente de la Unión de Informáticos  de Cuba en Camaguey
         Universidad de Camaguey
         "Ignacio Agramonte Loynaz", Camaguey, Cuba
         Telef. (53)(32) 262810
                 (53) 52112116
email: ralonsoreyes at gmail.com
          reynaldo.alonso at reduc.edu.cu





El jue, 15 oct 2026, 10:35 a. m., Rafik Dammak <
00001e06d4af460b-dmarc-request at listserv.syr.edu> escribió:

> Hi all
>
>
> Please find PIR response to our letter.
>
> Best,
>
> Rafik
>
> ---------- Forwarded message ---------
>
>
>
> Hello Rafik - Thank you for your letter. Public Interest Registry (PIR) is
> a U.S.-based organization and is required to comply with U.S. law,
> including applicable sanctions. In this case, the affected .ORG domain name
> was identified on the U.S. Treasury Department’s Office of Foreign Asset
> Control (OFAC) Specially Designated Global Terrorist List. Therefore, PIR
> is legally mandated to suspend it. The registrant of the domain has a right
> to challenge the designation determination. PIR has no involvement in that
> process. Should the registrant be successful in such a proceeding, the
> suspension would be lifted. This was not a discretionary suspension under
> our Anti-Abuse Policy; this was a compulsory compliance action.
>
> Regarding the referenced General License, that specific License strictly
> covers transactions that are "ordinarily incident and necessary to the wind
> down of any transaction," and because suspension of a domain name does not
> require any “wind-down,” this situation falls outside of the covered scope
> of the license. While some OFAC General Licenses permit transactions that
> cover “the maintenance of operations” in their scope, this License does
> not. As OFAC has clarified in its guidance in other wind-down situations (
> *see* OFAC Frequently Asked Questions, Question 975), wind-down
> authorizations without this maintenance of operations coverage are not
> grace periods to continue ongoing business activities but are applicable
> only where a transaction genuinely requires a process to unwind rather than
> where the service can be stopped immediately. Evidently, other service
> providers, including Paypal and the registrant’s bank, interpreted the
> License the same way.
>
> We are not in a position to assess the validity of, or override, OFAC’s
> determination of a terrorist organization. We understand the concerns, but
> they are best directed towards the Office of Foreign Assets Control.
>
> Best regards,
>
>
> Brian
>
> Brian Cimbolic
> Chief Legal and Industry Affairs Officer
>
>
>
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