One of the first reported cases of compliance uncertainty with sanctions imposed on former Yugoslavia, Serbia: An American satellite Internet feed provider reportedly was unclear how it could comply with the US government sanctions and still provide Internet satellite feed to Yugoslavia. The fears stemmed from Executive Order 13,121, which went into effect on May 1, 1999, after the Kosovo attack. The Executive Order prohibited a range of trade, a broad supply of goods or services, and any related transaction with Serbia and Montenegro. This event raised some of the earliest (but short-lived) political and compliance uncertainty about sanctions and Internet connectivity. In this period, the US issued various general licenses that exempted certain technologies and software from sanctions in Serbia. For a clearer picture and more details, see Jelena Cosic’s research on this topic.
UN sanctions Afghanistan, EU issued a Council Regulation prohibiting the export of certain goods and services to Afghanistan.
The 9/11 terrorist attack. The US began to use sanctions more aggressively. Sanctions also became more targeted (early smart sanctions), but there was no Internet-specific sanction relief yet. The Internet had been commercialized but had not achieved its later ubiquity. The US tightened its sanctions on Afghanistan.
Sudan ccTLD redelegation issue and sanctions.
One of the potential events that led to the provision of sanctions relief in the subsequent years was the Iranian uprising that used the Internet to effectively communicate to the world what was going on in Iran.
US-Iran & US-Cuba
US sanction relief for personal communication and the Internet for Iran, Cuba, and Sudan (through amending the sanction regulations) – Iran has been sanctioned since 1979, Sudan sanctions have been in place since 1997, and Sanctions on Cuba started in the 60s.
US-Cuba & Europe-Syria
Reports that Cuba could not develop its Internet partly due to US embargo, Europe sanctioned Syria.
EU Sanctions (in place since 2007 after the imposition of UN Sanctions) affected Internet governance organizations, and they had to ensure that they complied with sanctions while serving certain countries.
Sudan’s civil society reported frustration with how the US sanctions affected their access to digital technology and to the Internet.
US issued Iran General License D-1, with Respect to Certain Services, Software, and Hardware Incidents to Personal Communications
EU & US Sanctions
EU and US sanctions on Russia because of invading Crimea. Access to domain names in Crimea was hampered. Reportedly, the US general licenses did not apply to domain name registration services.
Ease of US embargo on Cuba and specific attention to facilitate access to the Internet. To a certain extent, the sanctions relief worked but there were still reports of restrictions on access to Internet services due to sanctions.
Iran & Syria
RIPE NCC became aware that two member entities based in Iran and one member in Syria might be on the sanction list. They informed the members and created additional sanction screening processes.
US withdrawal from Afghanistan and Taliban takeover. Afghanistan IP addresses are still registered, but it is not clear what will happen in the future. It might be difficult to verify who is in control of these addresses.
The Dutch Ministry of Foreign Affairs confirmed that they recognized IP resources as economic resources, as defined in the EU sanctions regulations. Therefore, RIPE NCC must freeze the resource if provided to a sanctioned entity.
EU, US & UK
US and EU impose sanctions against Russia because of Russia’s invasion of Ukraine. The UK joins the US and EU in imposing separate sanctions.
The UK issued a license and authorized limited transactions to facilitate Civilian Telecommunication Services, which are either an “electronic communication network” or “electronic communications service” as defined by Section 32 of the Communications Act 2003 that is used for civilian purposes.
The EU usually calls sanctions “European Restrictive Measures.” They also imposed sanctions on Russia, and a so-called “Internet carveout” was issued.
The most recent US sanction relief for Iran (Iran GL D-2) is to provide Internet services for the people of Iran as they are partaking in an uprising. It has imposed sanctions on the Minister of Communication along with others due to Internet censorship.