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[rpd] Assisted Registry Checks
Caleb Olumuyiwa Ogundele
muyiwacaleb at gmail.com
Tue Jun 25 05:13:54 UTC 2019
See comments inline
On Mon, Jun 24, 2019 at 10:21 PM JORDI PALET MARTINEZ via RPD <
rpd at afrinic.net> wrote:
> Hi Dewole,
>
> This is actually a good idea, and if I recall correctly, in the case of
> RIPE NCC, this was designed by the staff itself, looking for an objetive
> and fair process, and avoiding "flase claims" about possible competitors.
>
CO: This then supports an earlier argument that this is an operational
thing and does not need community approval.
>
> https://www.ripe.net/publications/docs/ripe-694
>
> You can see that this doesn't have the "random" bit of the review policy
> proposal, and still allows any member that has suspicius information about
> another member to tell the staff.
>
CO: In this case, the same document you share allows for appeal and
dispute resolution in section 4 as seen below:
If the Resource Holder does not agree with the outcome of the performed
audit, they can apply for the initiation of the RIPE NCC Conflict
Arbitration Procedure <http://www.ripe.net/publications/docs/arbitration>.
>
> The staff will then review that information, but the main difference is
> that if they feel the information is wrong, they aren't mandated to start a
> complete audit.
>
> Regards,
> Jordi
> @jordipalet
>
>
>
> El 24/6/19 22:45, "Dewole Ajao" <dewole at forum.org.ng> escribió:
>
> [was Re: [rpd] Proposal Update received: Internet Number Resources
> Review by AFRINIC]
>
> With the type of audit/review being discussed, the costs may vary
> significantly from member to member - whether AFRINIC-side or
> Member-side.
>
> I have however in the past mentioned that RIPE NCC has something
> simple
> and time-efficient called Assisted Registry Checks and if I remember
> correctly, they aim to check records for every member once in two
> years.
> While we await the audit/review/recovery policy, it would be nice to
> see
> AFRINIC start to implement basic checks (even before a member comes
> for
> a repeat allocation).
>
> See
>
> https://www.ripe.net/manage-ips-and-asns/resource-management/assisted-registry-check
>
>
> These are simple checks to ensure registry accuracy and I see no
> reason
> why anyone would try to discourage AFRINIC from checking the accuracy
> of
> its records with the assistance of members.
>
> This first step we can all agree on and staff can implement almost
> immediately (in addition to the work they are already doing when
> members
> come to them with issues arising from our lame-delegations and
> no-reverse-unless-assigned policies).
>
> Regards,
>
> Dewole.
>
>
> On 6/24/2019 7:20 PM, JORDI PALET MARTINEZ via RPD wrote:
> > Hi Ish,
> >
> > I understand that, but my point is that there are two sides of the
> cost. And both should be considered:
> >
> > a) The cost for Afrinic (lets talk about average) for each review to
> an ISP.
> >
> > b) The cost for each member being reviewed (again we can get
> examples to calculate an average).
> >
> > Regards,
> > Jordi
> > @jordipalet
> >
> >
> >
> > El 24/6/19 20:00, "Ish Sookun" <ish.sookun at lasentinelle.mu>
> escribió:
> >
> > I only requested an indicative value. I didn't ask to consider
> all
> > possibilities (e.g litigation, big or small ISP etc). The idea
> is to
> > obtain an approximate cost figure to evaluate whether the mere
> > implementation of this policy brings a financial burden on
> AfriNIC.
> >
> > Regards,
> >
> > Ish Sookun
> >
> > On 6/24/19 7:31 PM, JORDI PALET MARTINEZ via RPD wrote:
> > > I think there is one more cost to be considered here as well.
> > >
> > >
> > >
> > > Each time an ISP gets the audit, it will need to dedicate
> staff for that.
> > >
> > >
> > >
> > > It is dificult to calculate “how much” that means, as it may
> depend on
> > > many factors, such as how big is the ISP, how many resources
> they have,
> > > how many customers from different types (business,
> residential), what
> > > provisioning system they have, IPAM if any, level of
> “automation” and
> > > “inventory” of the network, etc.
> > >
> > >
> > >
> > > May be it is a good exersice for some of you to calculate
> (rought idea),
> > > how much staff/resources and how many weeks, this will take
> to you, if
> > > the policy it is implemented?
> > >
> > >
> > >
> > > A few examples, could help the community to take a decision.
> > >
> > >
> > >
> > > Regards,
> > >
> > > Jordi
> > >
> > > @jordipalet
> > >
> > >
> > >
> > >
> > >
> > >
> > >
> > > El 24/6/19 17:25, "Timothy Ola Akinfenwa" <
> akin.akinfenwa at uniosun.edu.ng
> > > <mailto:akin.akinfenwa at uniosun.edu.ng>> escribió:
> > >
> > >
> > >
> > > Hello Andrew,
> > >
> > > While I also agree that Staff provide information on the
> likely
> > > financial implication for the audit, I don't understand why
> there should
> > > be a separate allocation for litigation.
> > >
> > >
> > >
> > > Is it wise for an organisation to budget funds for likely
> court cases
> > > when instead they should strive to prevent one in the first
> place?
> > >
> > >
> > >
> > > For me, I think it is critical to ensure that Staff actions
> on any audit
> > > review does not amount to litigation. And this may be
> captured as a
> > > suggestion in the policy as well, if necessary.
> > >
> > >
> > >
> > > Best!
> > >
> > > Sent from my OnePlus mobile device! </>$aa;
> > >
> > >
> > >
> > > On Mon, 24 Jun 2019, 3:53 PM Andrew Alston,
> > > <Andrew.Alston at liquidtelecom.com
> > > <mailto:Andrew.Alston at liquidtelecom.com>> wrote:
> > >
> > > I would agree that these numbers would be useful - and
> must in
> > > addition include contingent liability allocation for
> litigation that
> > > could result due to implementation of this policy
> > >
> > >
> > >
> > > Andrew
> > >
> > >
> > >
> > > Liquid Telecommunications - Group Head Of IP Strategy
> > >
> > >
> ------------------------------------------------------------------------
> > >
> > > *From:*Ish Sookun <ish.sookun at lasentinelle.mu
> > > <mailto:ish.sookun at lasentinelle.mu>>
> > > *Sent:* Monday, June 24, 2019 5:39:19 PM
> > > *To:* rpd at afrinic.net <mailto:rpd at afrinic.net>
> > > *Subject:* Re: [rpd] Proposal Update received: Internet
> Number
> > > Resources Review by AFRINIC
> > >
> > >
> > >
> > > Dear PDWG Co-Chairs,
> > >
> > > It was expressed during the last meeting that this policy
> will have
> > > financial implications on AfriNIC due to costs associated
> to auditing.
> > >
> > > Is it possible to obtain an approximate cost figure (from
> staff) that
> > > such audits would entail?
> > >
> > > Regards,
> > >
> > > Ish Sookun
> > >
> > > On 6/8/19 10:24 PM, Dewole Ajao wrote:
> > > > Dear PDWG members,
> > > >
> > > > This is to inform you that authors of the policy
> proposal named
> > > "Internet Number Resources Review by AFRINIC" have
> submitted an
> > > updated version (Draft version 8) as included below. The
> URL will be
> > > shared once published online.
> > > >
> > > > Please take some time to go through the proposal
> contents and
> > > provide your feedback.
> > > >
> > > > Thank you.
> > > > PDWG Co-Chairs
> > > >
> > > >
> > > >
> ------------------------------------------------------------
> > > >
> > > > ------------------- Begin
> > > >
> > >
> ---------------------------------------------------------------------------------
> > > >
> > > > Name : Internet Number Resources Review by AFRINIC
> (Draft 8)
> > > > Ref. Name: AFPUB-2016-GEN-001-DRAFT08
> > > > Status: Under Discussion
> > > > Date: 7 June 2019
> > > >
> > > > Authors:
> > > > (a) Amelina A. A. Arnaud | <
> arnaud.amelina at togorer.tg
> > > <mailto:arnaud.amelina at togorer.tg>
> > > > <mailto:arnaud.amelina at togorer.tg
> > > <mailto:arnaud.amelina at togorer.tg>>> | AUF/TogoRER
> > > > (b) Jean-Baptiste Millogo |<
> jean.millogo at orange.com
> > > <mailto:jean.millogo at orange.com>
> > > > <mailto:jean.millogo at orange.com
> > > <mailto:jean.millogo at orange.com>>>| Orange Burkina
> > > > (c) Marcus ADOMEY <madomey at ug.edu.gh
> > > <mailto:madomey at ug.edu.gh>
> > > > <mailto:madomey at ug.edu.gh <mailto:madomey at ug.edu.gh>>>
> |
> > > University of Ghana
> > > >
> > > > 13.0 Summary of the Problem Being Addressed by this
> Policy Proposal
> > > >
> > > > As Internet Number resources are finite, their
> allocation is based on
> > > > the operational needs of end-users and Internet
> Services Providers,
> > > > while avoiding stockpiling in accordance with RFC7020,
> IPv4 Allocation
> > > > Policy CPM 5.5, IPv6 Allocation and assignment policy
> CPM 6.5 and
> > > Policy
> > > > for Autonomous System Numbers (ASN) Management in the
> AFRINIC
> > > region CPM
> > > > 7.0.Section 4 of the Registration Service Agreement
> (RSA) provides the
> > > > framework for investigations of the usage of allocated
> Internet Number
> > > > resources, defines members’ obligation to cooperate and
> the
> > > measures to
> > > > be taken by AFRINIC in case of failure to comply. The
> lack of such
> > > > investigation or regular control can lead to
> inefficient usage of the
> > > > Internet Number resources, to stockpiling and other
> type of abuses.
> > > >
> > > > 13.0.1 Summary of How this Proposal Addresses the
> Problem
> > > >
> > > > In order to ensure efficient and appropriate use of
> resources, AFRINIC
> > > > shall conduct regular reviews of resource utilisation
> held by its
> > > > members. This would allow recovery of any type of
> resource, where
> > > usage
> > > > is not in compliance with the RSA. Those resources can
> be reallocated
> > > > for better usage.
> > > >
> > > > 13.0.2 Proposal
> > > >
> > > > The policy proposal will modify the CPM as follows:
> > > >
> > > > Insert a section 13 to the CPM as follows:
> > > >
> > > > 13.0 Internet Number Resources Review
> > > >
> > > > Regular reviews of resource utilisation are conducted
> by AFRINIC to
> > > > ensure efficient and appropriate usage of resources.
> This allows for
> > > > recovery of any type of resource where usage is not in
> compliance with
> > > > the RSA; to allow such resources to be reallocated for
> better usage.
> > > >
> > > > 13.1 The reviews shall be based on compliance with the
> terms
> > > outlined in
> > > > the RSA and Allocation/Assignment Policies.
> > > >
> > > > 13.2 The reviews cover all allocated/Assigned
> resources, but priority
> > > > goes to IPv4 and ASN mappable to two-octet ASN.
> > > >
> > > > 13.3 Classes of review: Members to be reviewed shall be
> selected
> > > > according to the following classes:
> > > >
> > > > 13.3.1 Random
> > > >
> > > > The member is chosen by AFRINIC at random between the
> members who has
> > > > not been reviewed for any other reasons in the
> preceding 24 months.
> > > >
> > > >
> > > > 13.3.2 Selected
> > > >
> > > > Member is selected because of an internal report or
> due to a lack of
> > > > contact between the AFRINIC and the member.
> > > >
> > > > 13.3.3 Reported:
> > > >
> > > > Here, members are reviewed either because:
> > > >
> > > > A) They have requested the review themselves or
> > > >
> > > > B) There has been a community complaint made against
> them that
> > > warrants
> > > > investigation. Complaints shall be backed by evidence
> and AFRINIC
> > > staff
> > > > shall evaluate the facts as appropriate to conduct the
> review. However
> > > > this review is not applicable to a member with the
> same resources
> > > > portfolio on which a full review has been completed in
> the
> > > preceding 24
> > > > months.
> > > >
> > > > AFRINIC staff may, at its sole discretion, after
> having assessed the
> > > > nature of the evidence found in the community
> complaint, require that
> > > > such evidence be (i) submitted in the form of a sworn
> affidavit or
> > > (ii)
> > > > declared to be true before a Commissioner of Oath.
> > > >
> > > > 13.4 In case of non-compliance and if evidence has been
> established in
> > > > accordance with:
> > > >
> > > > • Breach of AFRINIC policies
> > > > • Breach of the provisions of the registration
> service agreement or
> > > > other legal agreements between the organisation holding
> the
> > > resource and
> > > > AFRINIC.
> > > >
> > > > AFRNIC shall initiate the resource recovery process on
> the portion of
> > > > addresses found to be noncompliant.
> > > >
> > > > A) AFRINIC shall attempt to contact the organisation
> and correct any
> > > > discrepancy towards the RSA. Except in cases of
> fraudulent resource
> > > > acquisition or unlawful usage and abuse, the
> organization shall be
> > > > given a minimum of six(6) months to effect the return
> of the
> > > resources.
> > > >
> > > > If the organisation is cooperative and working in good
> faith to
> > > > substantially restore compliance or has a valid need for
> > > additional time
> > > > to renumber out of the affected blocks, AFRINIC shall
> negotiate a
> > > longer
> > > > term.
> > > >
> > > > The acceptance level of compliance and duration of the
> longer term are
> > > > at AFRINIC staff discretion.
> > > >
> > > > B) If the situation cannot be rectified and the member
> did not
> > > transfer
> > > > the resources to meet other AFRINIC-approved needs as
> per adopted
> > > policies
> > > >
> > > > AFRINIC shall publish the resources to be recovered
> for a period of
> > > > three (3) months; during which the organisation may at
> any time, seek
> > > > compliance or transfer the resources to other members
> > > >
> > > > After this period, the resource shall be recovered and
> therefore the
> > > > records of the previous holder of the recovered
> resource shall be
> > > > updated in AFRINIC’s databases.
> > > >
> > > > C) Any Internet Number Resources recovered under this
> policy may be
> > > > assigned/allocated under existing Allocation and
> Assignment Policies.
> > > >
> > > > 13.5 Appeal procedure
> > > >
> > > > Reviewed members who are not satisfied have the right
> to appeal
> > > against
> > > > the results on the review within the four weeks
> following
> > > communication
> > > > of the results by AFRINIC. Appeals shall follow an
> arbitration process
> > > > as provided for in the
> > > > Code de Procedure Civile (Code of Civil Procedure) of
> the Republic of
> > > > Mauritius. AFRINIC may, on request from an aggrieved
> party, suggest a
> > > > pool of arbitrators who shall be knowledgeable
> volunteers from the
> > > > community.
> > > >
> > > > 13.6 Compliance Report
> > > >
> > > > AFRINIC shall publish an annual meaningful report
> describing review
> > > > activities, in accordance with all applicable laws and
> regulations.
> > > >
> > > > 13.7 Acknowledgements
> > > >
> > > > The authors thank Ms Wafa Dahmani Zaafouri (become
> Afrinic GC
> > > Chair), Mr
> > > > Serge ILUNGA (become Afrinic Board member) and Mr
> Alain P. Aina for
> > > > their contributions in the development of this Policy
> proposal.
> > > >
> > > > The authors also thank the community for the
> discussions and
> > > contributions.
> > > >
> > > > 4.0 Revision History
> > > >
> > > > 18 May 2016
> > > > Version 1.0
> > > > - First Draft AFPUB-2016-GEN-001-DRAFT01
> > > > - Posted on RPD list
> > > >
> > > > 05 Aug 2016
> > > > Version 2.0
> > > > - Second Draft AFPUB-2016-GEN-001-DRAFT02
> > > > - Change on the policy’s name
> > > > - Addition of the Acknowledgement section
> > > > - Rephrasing of section 3.3.3
> > > >
> > > > 18 Nov 2016
> > > > Version 3.0
> > > > - Third Draft AFPUB-2016-GEN-001-DRAFT03
> > > > - Update of section 3.3.3 from discussions on mailing
> list
> > > > - Update of section 3.7 (Acknowledgements) to thank the
> community for
> > > > discussions and contributions
> > > >
> > > > 11 Apr 2017
> > > > Version 4.0
> > > > - Fourth Draft AFPUB-2016-GEN-001-DRAFT04
> > > > - Update and Rephrasing of section 3.4
> > > > - Update and Rephrasing of section 3.5
> > > > - Update and Rephrasing of section 3.6
> > > >
> > > > 21 Oct. 2107
> > > > Version 5.0
> > > > - Fifth Draft AFPUB-2016-GEN-001-DRAFT05
> > > > - Adding the paragraph C to 13.3.3. according to the
> legal counsel
> > > > proposition
> > > > - Rephrasing the paragraph 13.5 to comply with staff
> and legal
> > > assessment
> > > > - Rephrasing the paragraph 13.6 to comply with staff
> assessment and
> > > > avoid any ambiguity
> > > > - Changing the co-authors list
> > > > - Updating the Acknowledgement session
> > > > - Amending 13.4 (B) to reflect the Transfer policies
> > > >
> > > > 06 Apr. 2018
> > > > Version 6.0
> > > > - Sixth Draft AFPUB-2016-GEN-001-DRAFT06
> > > > - Removing categorisation between membership in random
> class
> > > section 13.3.1
> > > >
> > > > 06 Apr. 2019
> > > > Version 07
> > > > - Seventh Draft AFPUB-2016-GEN-001-DRAFT07
> > > > - Modifying section 13.4 Paragraph A) to clarify the
> resources
> > > recovery
> > > > process: set conditions under which a member could be
> given
> > > longer term
> > > > to effect the return of affected resources.
> > > >
> > > > 29 may. 2019
> > > > Version 08
> > > > - Eighth Draft AFPUB-2016-GEN-001-DRAFT08
> > > > - Section 13.3.1 changes to : "..The member is chosen
> by AFRINIC at
> > > > random between the members who has not been reviewed
> for any other
> > > > reasons in the preceding 24 months."
> > > > - Section 13.4 last paragraph changes to : "AFRINIC
> shall initiate
> > > > ... on the portion of addresses found to be
> noncompliant."
> > > > - Section 13.5 changes to “Reviewed members who are
> not satisfied
> > > > have the right to appeal against the results on the
> review within the
> > > > four weeks following communication of the results by
> AFRINIC……..”
> > > > - Typos and grammatical errors fixed.
> > > >
> > >
> -------------------------------------------------------------------------------
> > > > End
> > > >
> > >
> ---------------------------------------------------------------------------------
> > > >
> > > >
> > > > _______________________________________________
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> > >
> > > **********************************************
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> This electronic message contains information which may be privileged or
> confidential. The information is intended to be for the exclusive use of
> the individual(s) named above and further non-explicilty authorized
> disclosure, copying, distribution or use of the contents of this
> information, even if partially, including attached files, is strictly
> prohibited and will be considered a criminal offense. If you are not the
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--
*Ogundele Olumuyiwa Caleb*
*muyiwacaleb at gmail.com <muyiwacaleb at gmail.com>*
*234 - 8077377378*
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