Hi Jay, Thank you for indulging this thread with is somewhat rambling content. You triggered me… We are obliged under US law to check the name of everyone who registers for a meeting with a number of US government databases and if one of those names is a match we are then obliged to check the identity of that person to determined if they are the sanctioned individual. We regularly get name matches but never an identity match. We occasionally get people who do not respond to the identity verification requests and so do not process their registration. We are currently conducting identity checks on four name matches for IETF 121 Dublin. This sent me scurrying to the registration pages and the linked privacy statement. I found… Legally required disclosure We may at times be required by law to release Non-Public Information, and we will do so if we believe in good faith that such release is required by applicable law, regulation or judicial order. I think I was surprised that US law requires you to check the sanction list for meetings held overseas. I suppose this is because the place of business of the LLC is the US. I’m not questioning who is on the US sanctions list, only pondering how the way we are set up commercially forces us to be subject to the vagaries of US law. It is certainly an uncomfortable truth. The flip side, of course, is that no one is in a position to gripe about other countries we might decide to meet in applying their own checks against sanction lists. Can you tell us whether the check against the US sanctions list is push or pull? That is, do you supply details to the USG for them to verify non-sanctioned status, or is there a list of sanctioned individuals that you check against? Many thanks, Adrian |
