Re: Cogent cutting links to Russia?

[Sean Donelan <sean () donelan com>]

On Fri, 4 Mar 2022, Martin Hannigan wrote:
> I would argue they don't have much of a choice:
>
> "The economic sanctions put in place as a result of the invasion and the
> increasingly uncertain security situation make it impossible for Cogent to
> continue to provide you with service."
>
> I would expect to see others follow suit  if that is the case.


Not a sanctions lawyer...

I understand why a company may make the business decision its not worth 
the effort to do a lot of extra work to get OFAC licenses. For example, 
some embassies in Washington DC have difficulty finding a local bank to 
handle their day-to-day transactions, and the State Department needs to 
step in to help.


The Department of Treasury, Office of Foreign Assets Control (i.e. the
sanctions people) issued a general license authorizing transactions
related to telecommunications and mail (gl19) and internet (gl22) 
regarding Ukraine.


https://home.treasury.gov/system/files/126/ukraine_gl19.pdf
https://home.treasury.gov/system/files/126/ukraine_gl22.pdf

The Russia sanctions are different (see a lawyer), and don't have an 
explicit general license for telecommunications and mail. In the past, its 
been possible to get individual export licenses for incidental 
telecommunications and mail services, even for places like North Korea.

Throughout the cold war, telephone and mail services continued to be
provided across the Iron Curtain.