Internet resources partially removed from sanctions restrictions

The international Internet registrar is ready to resume issuing new IP addresses to Russian companies that have fallen under sanctions . But this will not apply to everyone, and the problem with paying for the resource will remain unresolved.

On Monday, June 12, the international Internet registrar RIPE NCC resumed service for its Russian participants, who fell under sanctions restrictions, but at the same time provide strictly telecommunication services (telephony, data transmission, television broadcasting, etc.). This is stated in a letter published on the website of the organization.

RIPE NCC is one of the five global Internet registries that distributes IP addresses and ASNs in RUSSIA, Europe and the Middle East (autonomous system number - autonomous system numbers, that is, blocks of addresses for which their owners are usually Internet providers, established uniform common routing rules). Those who wish can receive Internet resources both directly from the RIPE NCC and through LIR, that is, local Internet registrars that receive pools of IP addresses and assign them to their clients. Typically LIRs are ISPs, telecommunications companies, large enterprises, and academic institutions. To receive Internet resources directly from the RIPE NCC, you need to become a member of the organization by entering into a service agreement and paying an annual fee. As indicated on the RIPE NCC website, for 2022 its amount is €1.4 thousand.PAYPAL . Invoices are sent to companies in the first quarter of each year.

According to the letter, the RIPE NCC will remove the "sanctions" note from its database, and will also begin accepting new membership applications and sponsorship agreements with users who fall under this exemption. At the same time, it is indicated that for some Russian companies and individuals everything will remain unchanged, since they provide not only telecommunication services. In order to understand which category a member of an organization falls into, the RIPE NCC plans to contact each of them separately.

The RIPE NCC Report on Sanctions Transparency for the second quarter indicates that since 2021, the registrar has been investigating 1,046 cases for the sanctions of some of its members, of which 361 are related to hostilities in Ukraine (115 participants and 246 end users ). It also states that since February 2023, four Russian members of the organization have refused to cooperate with the RIPE NCC, but the reasons are not given.

At the same time, the RIPE NCC said that it will not issue invoices to excluded sanctioned participants until it becomes clear whether banks will be able to accept such payments or not. As Burtikov explained, those participants who were previously sanctioned or who were under investigation about the applicability of sanctions to them did not receive invoices for payment, since RIPE NCC was not entitled to receive payments from them. At the same time, such participants did not lose access to their Internet resources, but could not receive new ones either from the RIPE NCC or from other members of the organization. “However, more than 98% of Russian RIPE NCC members who received an invoice for 2023 have already successfully paid it,” Burtikov shared the statistics.

What happened after February 2022

After the start of a special military operation in Ukraine, representatives of the European Union and other countries imposed sanctions restrictions on Russia. The registration of Internet resources, including IP addresses, is an economic activity, and therefore the RIPE NCC, which is under the jurisdiction of the Netherlands, did not have the right to provide new Internet resources to persons or companies that fell under sanctions. Also, the international organization was obliged to freeze all the resources of sanctions clients.

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In March 2022, the Internet registrar allowed sanctioned companies to defer payment for Internet resources. They still had an obligation to pay, but if "sanction-related factors prevented the payment of bills," the RIPE NCC promised not to terminate the Standard Service Agreement (SSA). Already in June, within the framework of the sixth EU package, some of the prohibited financial restrictions were removed, in particular, a clause appeared that "financial restrictions do not apply to funds or economic resources that are strictly necessary for the provision of telecommunication services." At the same time, RIPE NCC sent a request to the authorities of the Netherlands and in May of this year received confirmation from them that Internet resources, including IP addresses, are not subject to sanctions restrictions, as they belong to the category of providing services for telecommunications.

The HEAD of the Coordination Center for .ru and .rf domains, Andrey Vorobyov, found it difficult to say which companies would be affected by the new interpretation of sanctions restrictions, “since there is no list of them in the public space and RIPE NCC works with each such organization on an individual basis.” At the same time, Vorobyov called the difficulties with payments to an international organization the main "cornerstone", explaining that "it is not clear how they will be organized taking into account banking sanctions restrictions."

Among the major Russian telecom operators, two companies fell under the sanctions - Rostelecom in February 2022 and MegaFon in April of this. Several interlocutors in the IT and telecommunications market told RBC that Rostelecom "is experiencing some difficulties in obtaining new IP addresses." RBC sent a request to Rostelecom.

A spokesman for MegaFon declined to comment.

Telecommunication services include quite a lot of services: IP-telephony, network access services, navigation, satellite communications, video communications, etc., said Yury Fedyukin, managing partner at Enterprise Legal Solutions. He believes that because of the sanctions, Internet providers and telecommunications companies are more at risk, "whose activity in the absence of access to RIPE NCC resources seems, if not impossible, then extremely difficult." Fedyukin suggested that communications market participants would take the news “positively,” although he noted that for most of them, the risks “remained unrealized, since only 12 RIPE members were confirmed to be under sanctions, and more than 600 were simply at risk.”

At the same time, he pointed out that even taking into account the new rules for servicing sanctioned clients, the situation with access to resources is still not normalized. “Until the end, the issue of payment for participation remains unresolved due to the sanctions imposed on Russian banks and restrictions imposed on cross-border transactions,” Fedyukin concluded.