RE: [bc-gnso] FW: [council] Response from ICANN Compliance re. RAP recommendations

[Marilyn Cade <marilynscade@xxxxxxxxxxx>]

It sounds like the recommendation is indeed an increase in compliance demands, 
but no funding for an automated monitoring tool, and that sounds silly to some. 
However, often organizations, whether commercial or non, lag behind in 
developing such tools. 
BUT, this is helpful to our purposes of interacting related to budget, and my 
draft letter, which I hope to finalize and share with others tomorrow. Sorry 
for delay. But, thanks, Ron, for your efforts to keep this a focus...







From: randruff@xxxxxxxxxxxxxxx
To: zahid@xxxxxxxxx; bc-gnso@xxxxxxxxx
Subject: RE: [bc-gnso] FW: [council] Response from ICANN Compliance re. RAP 
recommendations
Date: Thu, 24 Feb 2011 15:32:03 -0500




























It’s starting to feel like Alice in Wonderland… 
A Working Group spends countless hours debating VI, followed by the Board making
its own decision “based on experts” rather than the community.  We
are informed that a Code of Conduct will resolve the issues and, not to worry, 
all
the resources necessary for a fully-funded Compliance Department will be made
available.  Then the positions for the Head of Compliance plus two other
officers remain unfilled for the better part of a year… 

 

Now Pam Little’s response to GNSO
Council questions is scary (emphasis added):

 

With regard to part “b)” of
Recommendation 2, the RAA requires that registrars provide an interactive web 
page and a
port 43 WHOIS access.  As mentioned above, the Compliance department uses an
automated tool to monitor registrar port 43 access obligations.   However, the 
monitoring
tool does not monitor web-based WHOIS obligations. Monitoring registrar 
compliance with web based WHOIS access requires a
manual check of each the 970+ registrars’ websites, as the Compliance
department currently does not have an automated monitoring tool.  

 

I wonder which compliance officer(s)
spends their life on this task?  In reality, not enough.  So, as I now
understand it, we will have a set of laws in the new ‘Code of Conduct’
(pdp or staff generated?) that the vertically integrated entities will honorably
abide by, left unchecked due to lack of staff and clearly structural issues 
vis-à-vis
how ICANN monitors compliance.

 

My head is spinning…   Is it just
me?

 

RA

 



Ronald N. Andruff

RNA Partners, Inc.

 

 











From:
owner-bc-gnso@xxxxxxxxx [mailto:owner-bc-gnso@xxxxxxxxx] On Behalf Of Zahid 
Jamil

Sent: Thursday, February 24, 2011
11:44 AM

To: 'Bc GNSO list '

Subject: [bc-gnso] FW: [council]
Response from ICANN Compliance re. RAP recommendations



 

 

 



Sincerely,

 

 

Zahid Jamil

Barrister-at-law

Jamil & Jamil

Barristers-at-law

219-221 Central Hotel
Annexe

Merewether Road, Karachi. Pakistan

Cell: +923008238230

Tel: +92 21 35680760
/ 35685276 / 35655025

Fax: +92 21 35655026

www.jamilandjamil.com

 

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From:
owner-council@xxxxxxxxxxxxxx [mailto:owner-council@xxxxxxxxxxxxxx] On Behalf Of 
Marika Konings

Sent: 23 February 2011 13:48

To: council@xxxxxxxxxxxxxx

Subject: [council] Response from
ICANN Compliance re. RAP recommendations





 



Dear All,





 





Please find attached
the response from ICANN's Compliance Department in relation to resolved #1 of
the recently adopted motion on the Registration Abuse Policies Working Group
Final Report (RESOLVED #1, the GNSO Council
instructs ICANN Policy Staff to forward the two issues identified by the RAP
IDT as having low resource requirements, WHOIS Access recommendation #2 and Fake
Renewal Notices recommendation #1, to ICANN Compliance Staff for resolution.
ICANN Compliance Staff is requested to provide the GNSO
Council with its feedback on the two recommendations and proposed
implementation in a timely manner).





 





Pam Little, Interim Head of Contractual Compliance, is not
available to participate in the Council meeting coming Thursday, but she is
happy to take further comments / questions by email. In addition, she has
indicated that she is available to discuss the response and any further
questions in person with the Council during the weekend session at the ICANN
meeting in San Francisco,
if required.





 





With best regards,





 





Marika