RIPE Sanctions Report (Q4 2023)

This report presents data regarding the impact of sanctions on RIPE NCC members, Users, and legacy resource holders, while adhering to confidentiality and privacy requirements.

As an organization based in the Netherlands, RIPE NCC is obliged to comply with EU sanctions. If they determine that a member or resource holder is subject to relevant sanctions, they have decided to freeze the registration (not the usage) of their resources in RIPE’s Database. This implies that sanctioned entities are prohibited from acquiring additional IPv4 addresses or transferring existing ones. However, RIPE will not deregister their IPv4 address space or terminate their Standard Service Agreement (SSA) if they are RIPE NCC members.

If a member or End User fails to cooperate with RIPE’s verification processes, they will treat the member as if they are subject to sanctions. This is because RIPE has no means to establish otherwise.

RIPE’s Sanctions Exemptions

In RIPE’s previous report in May 2023, they received confirmation from Dutch authorities that IPv4 address resources are exempted from sanctions against Russia, which was introduced in 2022. In September 2023, they obtained separate confirmation from Dutch authorities regarding the prohibition of direct or indirect transactions related to certain listed entities. This confirmation affirmed that transactions involving IPv4 resources fall under an exemption introduced in June 2022, which exempts “transactions related to the provision of electronic communication services, data center services, and the provision of services and equipment necessary for their operation.” Following this clarification, RIPE resumed regular services for all members and End Users falling within the scope of this exemption, including those under investigation and marked as non-cooperative.

RIPE’s Sanctions Data

The following tables display any changes since the previous quarter and the total number of affected members and their IPv4 & IPv6 addresses. The information includes the date of action and the specific action taken. The tables also indicate our relationship to a sanctioned entity.

Changes Since Last Quarter

Status as of October 2023

RIPE Member Cases Under Investigation

Investigation is underway for a significant number of potential RIPE members who hold IPv4 address resources and are subject to EU sanctions. These statistics demonstrate the broad impact of sanctions on the Internet and highlight the effort required to contact potential matches and acquire supporting documentation.

While most of these cases might be false positives (FP), RIPE will examine each potential match as sanctioned until they verify otherwise, given the absence of a sanctions compliance grace period. Consequently, RIPE will withhold processing of any requests for new IPv4 addresses or the transfer of existing ones until potential sanctions cases are resolved.

Since early 2021,  EU sanctions have resulted in a total of 1,218 potential cases that require further investigation: