Although EU does not have a single agency that is a direct equivalent to the U.S. Office of Foreign Assets Control (OFAC), EU still has similar policies as US and there is bilateral relationship between OFAC and the European External Action Service (EEAS), and the European Commission Directorate-General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA). Owning business in few EU countries, I had to make several declarations to the government in country, and that was reported to EEAS and DG FISMA. On 2 Oct 2024, at 8:56, Jay Daley wrote: > Hi Eric > > For info, this subject was discussed in detail on this list and admin-discuss in 2021 and is covered by a public LLC policy: > > https://www.ietf.org/media/documents/IETF_LLC_OFAC_Compliance_Policy_2022-09-26.pdf > > Jay > >> On 2 Oct 2024, at 13:43, Eric Vyncke (evyncke) <evyncke@xxxxxxxxx> wrote: >> >> Jay, >> First of all: thank you for the open discussion. >>> 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. >> To be honest, reading the above text is rather puzzling [1] to say the least. As written by Adrian, I am even shocked that an EU-based meeting in Dublin must be vetted by the Government of the USA for an international organization such as the IETF/IRTF. Curious to see how it will apply to the IETF-125 meeting... >> I understand that: >> • The IETF LLC is incorporated in the USA >> • Most banks/credit cards will refuse payments from some countries >> • None of the IETF participants should probably appear on this sanction list >> Having written this, I am unsure how to address this ‘annoying’ [1] process. >> Regards >> -éric >> [1] my English knowledge prevents me to find the right word though > > > -- > Jay Daley > IETF Executive Director > exec-director@xxxxxxxx > S Moonesamy <sm+ietf@xxxxxxxxxxxx>
