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.

Andrew

From: Alex de Joode <[email protected]>
Sent: 04 October 2025 16:36
To: [email protected]
Subject: [ripe-list] beIN && RIPE NCC && Notorious Markets

https://torrentfreak.com/bein-says-issues-at-ripe-ncc-help-piracy-as-a-service-entities-stay-online-251003/
https://torrentfreak.com/images/USTR-2025-0018-0029-beIN_Miramax_2025-Notorious-Markets-submission.pdf

We had a nice presentation from beIN (rightsholder) at the Lisbon RIPE meeting, 
unfortunately it seems they are not very happy with the KYC procedure that RIPE 
NCC applies to their customers (I believe they mean the subsequent KYC for 
letting/renting (sub)resources).

(from the article)
​“Poor governance and a non-existent know your customer”

In the case of off-shore/bulletproof providers, beIN says that identifying the 
owner of an ASN using information held by RIPE NCC can prove impossible.

“RIPE NCC requests its members or those who use RIPE NCC resources to provide 
accurate contact information. Some rogue providers abuse this system by posting 
false or incomplete information. This prevents rights owners and authorities 
from reaching them or successfully sending takedown notices,” beIN explains.

Inaccurate information can include fake or unmonitored email addresses, false 
business addresses or shared locations with many tenants. This ultimately makes 
it impossible for beIN to identify the owners of off-shore hosting companies. 
If it’s unable to do that, targeting the operators of the PaaS platforms 
becomes impossible too.

“In other words, the very concept of an offshore or bulletproof hosting 
provider seeks to rely on the ease by which this registration system can be 
misused through the provision of false or incomplete information,” the company 
adds.

If RIPE NCC gets added to the Notorious Markets list, their Public Affairs and 
Regulatory team will be busy and as RIPE NCC is a Dutch and European 
association pressure from those directions cannot be ruled out (then change 
will happen whether or not the members agree (even as membership organisation 
the RIPE policies must be inline with the law)).

The above statement of beIN does signal a important issue that not only 
facilitates copyright infringement but a larger enablement of criminal internet 
infrastructure, that can and is used for support for  various nefarious 
activities. Renting ASN, IP blocks and not chancing to registration to the 
correct user makes it difficult to find the bad apples. Now the RIPE members 
can change the policies that deal with this themselves (I would guess this 
should be started in Bucarest) otherwise the likelyhood of RIPE NCC receiving a 
'gatekeeper' assignment (as banks have in the financial industry) and the need 
for extra (expensive !) lawyers by the NCC will increase the membership 
contribution. (In NL Dutch banks have approx. 25% of their employees commited 
to this gatekeeper role)

Cheers,
Alex


​--
IDGARA | Alex de Joode | [email protected]<mailto:[email protected]> | +31651108221
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