McTim's posting on dealing with the domain names of de-registered NGOs 
is what I had hoped for. It illustrates that there are things that will 
fall into the cracks between policies and processes. In some cases when 
a government de-registers a civil society organization all that means is 
that it loses its charitable status and cannot tax-receipt donations. In 
other cases it goes further, as in no bank accounts and supervised 
liquidation of assets. This leaves open the question of what happens if 
government policy to close bank accounts gets extended to closing web 
sites, or it doesn't. What issues are raised and what happens?

There is a wide and troublesome grey area here. While parts of it may be 
beyond ICANN's remit, it will certainly confront registrars and 
registries at both the gTLD and ccTLD levels, and be of concern to civil 
society groups.

Sam L.

On 05/07/2014 8:24 AM, McTim wrote:
> On Sat, Jul 5, 2014 at 7:00 AM, Sam Lanfranco <[log in to unmask]> wrote:
>> I would like to add a comment to flag the problems around maintaining
>> adequate domain name registration data, this in the case of ICANN’s targeted
>> support for the Internet in Africa, and NCSG’s focus on the not-for-profit
>> sector.
>>
>> Consider South Africa, by ordinary measures the most developed country in
>> Africa. Earlier this year the government de-registered over 300 South
>> African NGO’s and put an equal number on alert that they are about to lose
>> their registration. Without registration the NGO cannot even own a bank
>> account. The reason: failure to keep their required document filings up to
>> date. If they own a domain name (gTLD or ccTLD)
> ccTlds are not subject to contact re-verification AFAIK.
>
>
>   there is a high probability
>> that they are not even aware of those registration data obligations and a
>> high likelihood that they won’t keep that data current.
>>
>> As well, think of the nightmare that will arise for registrars, et. al. if
>> the civil society groups that are de-listed have one of the new domain names
>> where registered status is a requirement. Any policy that carries
>> requirements should not be based on the ideal situation, and should take
>> seriously subjecting itself to stress testing. As well, there is scope for
>> enlightened or unenlightened government policy here on the continued
>> ownership of particular gTLD domain names. If, for example, .ngo means a
>> registered NGO and registration is lost, who will be empowered, or obliged,
>> to act?
> no one, it seems:
>
> http://pir.org/what-are-the-eligibility-requirements-for-registering-ngo-and-ong-for-nonprofits-and-ngos/
>
> So as long as you show you are an NGO at initial registration, there
> does not seem to be re-verification of status as there is in highly
> regulated industries (.bank or .pharmacy for examples), apart from the
> contact data re-verification that is the subject of this thread.
>
> Registrars who signe the 2013 RAA know what the sign up for, nightmare or not.
>
>