Andrew Campling wrote on 06/10/2025 15:27:
Irrespective of any view regarding rights holders, the lack of effective
KYC procedures is also a problem in combating both malicious and illegal
content. For example, you may be surprised that the Internet Watch
Foundation finds a large percentage of illegal CSAM images hosted within
Europe (here
<https://www.iwf.org.uk/annual-data-insights-report-2024/data-and-insights/geographical-hosting-domains/>)
– for transparency, I’m an IWF trustee. I am not a lawyer but
I understand that KYC is a requirement under the EU’s NIS2 Directive.
In my view, extending effective KYC processes across the ecosystem will
add friction, making the life of malicious actors more difficult.
the ripe ncc already implements kyc for its members and direct
assignment resource holders. You can't get a PI assignment without
validating your identity, and there are comparable processes for
businesses who wish to become LIRs. These are hard-enforced. If you
don't comply, your application will be rejected.
In addition to this, all LIRs are subject to a periodic Assisted
Registry Check.
The BEIN letter seems to confuse data about RIPE members / direct
assignees with general end users of ISPs.
The confusion may be happening because the RIPE database is a mixture of
several different categories of data. Some of the data is authoritative
(i.e. RIPE LIR and Direct Assignments) and some is non-authoritative
(i.e. LIR assignments). A good deal of the non authoritative data is of
very poor quality, but the authoritative data is all subject to RIPE KYC
processes and regularly audited. Mixing these two data sets up does not
benefit anyone.
It's the job of the ISP to ensure that they have KYC processes with
their end users.
Nick
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