[Sanctions-Discuss] More specific subdomains

[Bill Woodcock]

> On Apr 11, 2022, at 11:49 AM, Niels ten Oever <mail at nielstenoever.net> wrote:
> 
> Excellent question.
> 
> [question]
> If a domain name (for instance "badperson.net") is sanctioned, should all subdomains of that domain (for instance "www.badperson.net") be automatically sanctioned as well? Or should each specific domain be sanctioned individually, recognizing that the operator of the sanctioned domain is then free to create additional as-yet-unsanctioned subdomains at will?
> [/question]
> 
> To what extend does this question differ from the question: what happens if different website are hosted on the same IP address ? This can be a case of the 'human shield' problem, but by no means has to be.
> 
> To make this decision, I think there are several things to take into account:
> 
> a. proportionality
> 	- is there another way to reach the subdomain or website that is not the target of the sanction?
> 
> b. impact
> 	- is this service an important infrastructure for exercising human rights?
> 
> c. alternatives
> 	- is there another way to implement the sanction against the originally intended entity that would not hamper the non-sanctioned entity?

Actually, BEREC’s statement today addressed exactly this issue:

https://berec.europa.eu/eng/news_and_publications/whats_new/9340-berec-supports-isps-in-implementing-the-eu-sanctions-to-block-rt-and-sputnik

It is BEREC’s understanding that the obligations to block RT and Sputnik are to be read in a broad manner and that all websites belonging to the entities mentioned in the Annex XV of the Regulation are covered…  BEREC considers that all domains incl. subdomains (such as www.rt.com, francais.rt.com, *.sputniknews.com, sputniknewslv.com, sputniknews.gr, sputniknews.cn, etc. ) related to the entities mentioned in the Annex XV fall under this exception. BEREC trusts that all parties will take action to implement the EU sanctions in a precise and timely manner.

                                -Bill

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