On: Let's Encrypt bans certificate usage in any US sanctioned territory [pdf]

[jaas]

Let's Encrypt certificates continue to be available in both Iran and Russia, just not for the Iranian and Russian governments.

The terms of service update to clarify what we have always done, comply with relevant law, has not changed the situation for either country.

[joshuaissac → jaas]

> Let's Encrypt certificates continue to be available in both Iran and Russia, just not for the Iranian and Russian governments.

According to https://news.ycombinator.com/item?id=48457280 it affects all people ordinarily resident in those territories, not just their governments:

> You are not a person or entity that is:

> (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions;

> [other 'or' conditions]

[jaas → joshuaissac]

Sanctions compliance is unfortunately fairly complex.

Let's Encrypt can issue certificates for non-government entities in Iran and Russia due to statutory exemptions protecting personal communications, alongside specific Office of Foreign Assets Control (OFAC) authorizations designed to promote Internet freedom and human rights.

We will look into whether we can make things more easily understandable in the subscriber agreement.

[thayne → jaas]

> You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions

Seems to be pretty clear that it would include non-government entities in sanctioned countries.

[lioeters → joshuaissac]

I wonder what "ordinarily resident" means legally. Like has a permanent address there, even if they don't live there physically..?

[Hundredth0006 → lioeters]

Yes. If you are, for example, even a US citizen, permanently living in Crimea, you are still subject to limitations, imposed by sanctions.

[jaas → Hundredth0006]

I'm not sure if you're talking generally about sanctions or specifically about Let's Encrypt, but to avoid any doubt: citizens of Crimea are free to use Let's Encrypt. We do not, however, serve government entities in occupied Crimea.

[john_strinlai → jaas]

you should update the documents to reflect this stance.

"You are not a person or entity that is: (a) located in, organized under the laws of, or ordinarily resident in any country or territory that is the target of comprehensive U.S. sanctions; "

this says nothing (edit: specific) about government (edit: only), and is applicable to normal people in those areas.

[joemi → john_strinlai]

A government falls under "entity". So it's about normal people AND governments (and other entities).

Still needs updating if it's supposed to only apply to governments, though.