How network blocks come about because of sanctions
Summary
From an ISP’s perspective, Lutz Donnerhacke describes how sanctions lists lead to network blocks, overblocking and unclear responsibility between authorities and operators. The list at the time sometimes contained complete URLs instead of only domains. At least one operator who was contacted removed the linked content in question.
Ideas
- European decisions are passed on to providers via authorities and industry associations.
- URL lists cannot be implemented technically through DNS blocks without loss.
- Domains can contain sanctioned and uninvolved content at the same time.
- Overblocking hits operators and users outside the actual target of the sanctions.
- Deleted content quickly makes static block lists factually wrong.
- Unclear responsibility shifts legal risks onto the providers carrying out the blocks.
Insights
- Political granularity cannot be mapped arbitrarily onto technical namespaces.
- Lists without a verifiable justification make error correction and accountability harder.
- Censorship infrastructure remains error-prone even when its occasion seems lawful.
Quotes
Betroffenen Kunden steht Schadenersatz zu.
(“Affected customers are entitled to compensation.”) – Lutz Donnerhacke
Habits
- Donnerhacke asks authorities, associations and affected operators about the basis of their respective decisions.
Facts
- According to the author, the German Federal Network Agency communicated with providers via industry associations.
References
- Lutz Donnerhacke: how network blocks come about because of sanctions (German)
- Bundesnetzagentur: the German authority involved in the process described.
- BREKO: the association that passed the blocking information on to its member companies.
Critique
- The article mainly presents the operator’s perspective and not a complete official file.
- The legal situation and responsibilities may have changed since 2022.
Remarks
- The text distinguishes between deleting content and blocking its transport.
- The technical criticism is aimed particularly at disproportionate DNS blocks.
Recommendations
- Demand a legal basis, scope and expiry date for every blocking target.
- Continuously check targets for deletion, relocation and uninvolved content.
- Document technical limits and expected overblocking before implementation.
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