28 Abuse Prevention and Mitigation

Prototypical answer:

1. COMPREHENSIVE ABUSE POLICIES, WHICH INCLUDE CLEAR DEFINITIONS OF WHAT CONSTITUTES ABUSE IN THE TLD, AND PROCEDURES THAT WILL EFFECTIVELY MINIMIZE POTENTIAL FOR ABUSE IN THE TLD
ICE plans to administer the .ice gTLD as a closed corporate brand and will not accept registration of second-level domains and⁄or records from external sources. Implementation of any corporate-initiated registrations will be limited to approved ICE Engineers with proper authorization and approval.
1.1 .ice Abuse Prevention and Mitigation Implementation Plan
Internal registration requests must pass through the ICE Change Control Process before being available and approved for implementation by the Systems Engineering team. While the primary vetting processes described in the ICE Change Control Policy is designed to prevent interruption of service or erroneous changes, the process also provides the mechanism by which abusive registration attempts would be detected and thwarted. The Change Control Policy requires review by 5 Senior-level reviewers, approval by one, and notification of all. Rejection by any reviewers will terminate a change control request. Only with approval and during the pre-defined ICE Change Control window (18:30EST weeknights) can System Engineering staff implement a change.
1.2 Policies for Handling Complaints Regarding Abuse
Internally-sourced complaints regarding abuse in the .ice TLD are received via the ICE corporate ticketing system. Tickets may be submitted via a web form or e-mail. Employee office location is used to automatically route complaints to an IT Support group in the geographically-closest support group in Atlanta, Chicago, London, New York, or Singapore. Externally-sourced complaints will also be receivable via e-mail or a web form. Once complaints are received, they will be routed to the ICE Information Security team, where an Incident Ticket will be raised. The Information Security group will review any complaints, escalating as needed.
1.3 Proposed Measures for Removal of Orphan Glue Records
Although orphan glue records often support correct and ordinary operation of the Domain Name System (DNS), registry operators will be required to remove orphan glue records (as defined at http:⁄⁄www.icann.org⁄en⁄committees⁄security⁄sac048.pdf) when provided with evidence in written form that such records are present in connection with malicious conduct. ICE’s selected backend registry services provider’s (Verisign’s) registration system is specifically designed to not allow orphan glue records. Registrars are required to delete⁄move all dependent DNS records before they are allowed to delete the parent domain.
To prevent orphan glue records, Verisign performs the following checks before removing a domain or name server:

Checks during domain delete:
• Parent domain delete is not allowed if any other domain in the zone refers to the child name server.
• If the parent domain is the only domain using the child name server, then both the domain and the glue record are removed from the zone.

Check during explicit name server delete:
• Verisign confirms that the current name server is not referenced by any domain name (in-zone) before deleting the name server.

Zone-file impact:
• If the parent domain references the child name server AND if other domains in the zone also reference it AND if the parent domain name is assigned a serverHold status, then the parent domain goes out of the zone but the name server glue record does not.
• If no domains reference a name server, then the zone file removes the glue record.

1.4 Resourcing Plans
Details related to resourcing plans for the initial implementation and ongoing maintenance of ICE’s abuse plan are provided in Section 2 of this response.
1.5 Measures to Promote Whois Accuracy
While the .ice TLD will be administered as a closed corporate domain name, measures will be taken nonetheless to promote Whois accuracy. These measures include tightly limiting the universe of potential registrants and regularly recertifying record content in addition to authorization to modify that content.
1.5.1 Authentication of Registrant Information
ICE will limit potential Registrants to only ICE employees submitting requests through the internal ICE corporate ticketing system
1.5.2 Regular Monitoring of Registration Data for Accuracy and Completeness
ICE will monitor registration data via an automated quarterly recertification ticket. This ticket will require all .ice domains and records to be listed and sent to the Vice Present and Senior Director of Information Security for review. Any subsequent deletions, additions, or modifications will need to follow the standard ticketed request procedure.
Additionally Verisign, ICE’s selected backend registry services provider, has established policies and procedures to encourage registrar compliance with ICANN’s Whois accuracy requirements. Verisign provides the following services to ICE for incorporation into its full-service registry operations.
Registrar self certification.
The self-certification program consists, in part, of evaluations applied equally to all operational ICANN accredited registrars and conducted from time to time throughout the year. Process steps are as follows:
• Verisign sends an email notification to the ICANN primary registrar contact, requesting that the contact go to a designated URL, log in with his⁄her Web ID and password, and complete and submit the online form. The contact must submit the form within 15 business days of receipt of the notification.
• When the form is submitted, Verisign sends the registrar an automated email confirming that the form was successfully submitted.
• Verisign reviews the submitted form to ensure the certifications are compliant.
• Verisign sends the registrar an email notification if the registrar is found to be compliant in all areas.
• If a review of the response indicates that the registrar is out of compliance or if Verisign has follow-up questions, the registrar has 10 days to respond to the inquiry.
• If the registrar does not respond within 15 business days of receiving the original notification, or if it does not respond to the request for additional information, Verisign sends the registrar a Breach Notice and gives the registrar 30 days to cure the breach.
• If the registrar does not cure the breach, Verisign terminates the Registry-Registrar Agreement (RRA).

Whois data reminder process. Verisign regularly reminds registrars of their obligation to comply with ICANN’s Whois Data Reminder Policy, which was adopted by ICANN as a consensus policy on 27 March 2003 (http:⁄⁄www.icann.org⁄en⁄registrars⁄wdrp.htm). Verisign sends a notice to all registrars once a year reminding them of their obligation to be diligent in validating the Whois information provided during the registration process, to investigate claims of fraudulent Whois information, and to cancel domain name registrations for which Whois information is determined to be invalid.
1.5.3 Use of Registrars
Registrar(s) used to process domain registrations within .ice will be required to restrict access to approve ICE Systems Engineering staff to submit any record deletions, additions, or modifications. ICE termination procedures will be amended to require looking for an disabling any Registrar accounts when ICE System Engineering staff leave. Further, an automated quarterly recertification will be added to ensure all accounts at any Registrar(s) are reviewed and maintained.
1.6 Malicious or Abusive Behavior Definitions, Metrics, and Service Level Requirements for Resolution
Abuse in .ice registration is defined as the registration of a domain name or record for a purpose that is not aligned with the strategic interest of ICE.
1.7 Controls to Ensure Proper Access to Domain Functions
To ensure proper access to domain functions, ICE incorporates Verisign’s Registry-Registrar Two-Factor Authentication Service into its full-service registry operations. The service is designed to improve domain name security and assist registrars in protecting the accounts they manage by providing another level of assurance that only authorized personnel can communicate with the registry. As part of the service, dynamic one-time passwords (OTPs) augment the user names and passwords currently used to process update, transfer, and⁄or deletion requests. These one-time passwords enable transaction processing to be based on requests that are validated both by “what users know” (i.e., their user name and password) and “what users have” (i.e., a two-factor authentication credential with a one-time-password).
Registrars can use the one-time-password when communicating directly with Verisign’s Customer Service department as well as when using the registrar portal to make manual updates, transfers, and⁄or deletion transactions. The Two-Factor Authentication Service is an optional service offered to registrars that execute the Registry-Registrar Two-Factor Authentication Service Agreement. As shown in Figure 28-1, the registrars’ authorized contacts use the OTP to enable strong authentication when they contact the registry. There is no charge for the Registry-Registrar Two-Factor Authentication Service. It is enabled only for registrars that wish to take advantage of the added security provided by the service.

2. TECHNICAL PLAN THAT IS ADEQUATELY RESOURCED IN THE PLANNED COSTS DETAILED IN THE FINANCIAL SECTION
Resource Planning
ICE maintains a dedicated Information Security group comprised of 10 full-time employees. Abuse prevention and mitigation responsibilities surrounding the .ice gTLD registration will fall under the existing remit of this group, and the group has adequate capacity to handle any resulting activity.
Resource Planning Specific to Backend Registry Activities
Verisign, ICE’s selected backend registry services provider, is an experienced backend registry provider that has developed a set of proprietary resourcing models to project the number and type of personnel resources necessary to operate a TLD. Verisign routinely adjusts these staffing models to account for new tools and process innovations. These models enable Verisign to continually right-size its staff to accommodate projected demand and meet service level agreements as well as Internet security and stability requirements. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its staffing models, Verisign derived the necessary personnel levels required for this gTLD’s initial implementation and ongoing maintenance. Verisign’s pricing for the backend registry services it provides to ICE fully accounts for cost related to this infrastructure, which is provided as “Total Critical Registry Function Cash Outflows” (Template 1, Line IIb.G) within the Question 46 financial projections response.
Verisign employs more than 1,040 individuals of which more than 775 comprise its technical work force. (Current statistics are publicly available in Verisign’s quarterly filings.) Drawing from this pool of on-hand and fully committed technical resources, Verisign has maintained DNS operational accuracy and stability 100 percent of the time for more than 13 years for .com, proving Verisign’s ability to align personnel resource growth to the scale increases of Verisign’s TLD service offerings.
Verisign projects it will use the following personnel roles, which are described in Section 5 of the response to Question 31, Technical Overview of Proposed Registry, to support abuse prevention and mitigation:
• Application Engineers: 19
• Business Continuity Personnel: 3
• Customer Affairs Organization: 9
• Customer Support Personnel: 36
• Information Security Engineers: 11
• Network Administrators: 11
• Network Architects: 4
• Network Operations Center (NOC) Engineers: 33
• Project Managers: 25
• Quality Assurance Engineers: 11
• Systems Architects: 9

To implement and manage the .ice gTLD as described in this application, Verisign, ICE’s selected backend registry services provider, scales, as needed, the size of each technical area now supporting its portfolio of TLDs. Consistent with its resource modeling, Verisign periodically reviews the level of work to be performed and adjusts staff levels for each technical area.
When usage projections indicate a need for additional staff, Verisign’s internal staffing group uses an in-place staffing process to identify qualified candidates. These candidates are then interviewed by the lead of the relevant technical area. By scaling one common team across all its TLDs instead of creating a new entity to manage only this proposed gTLD, Verisign realizes significant economies of scale and ensures its TLD best practices are followed consistently. This consistent application of best practices helps ensure the security and stability of both the Internet and this proposed gTLD, as Verisign holds all contributing staff members accountable to the same procedures that guide its execution of the Internet’s largest TLDs (i.e., .com and .net). Moreover, by augmenting existing teams, Verisign affords new employees the opportunity to be mentored by existing senior staff. This mentoring minimizes start-up learning curves and helps ensure that new staff members properly execute their duties.

3. POLICIES AND PROCEDURES IDENTIFY AND ADDRESS THE ABUSIVE USE OF REGISTERED NAMES AT STARTUP AND ON AN ONGOING BASIS
3.1 Start-Up Anti-Abuse Policies and Procedures
ICE plans to administer the .ice gTLD as a closed corporate brand and will not accept registration of second-level domains and⁄or records from external sources. As such, internal corporate standard and policies on business-alignment and appropriateness of requests will govern any domain startup and registration.
3.2 Ongoing Anti-Abuse Policies and Procedures
3.1 Policies and Procedures That Identify Malicious or Abusive Behavior
Verisign, ICE’s selected backend registry services provider, provides the following service to ICE for incorporation into its full-service registry operations.
Malware scanning service. Registrants are often unknowing victims of malware exploits. Verisign has developed proprietary code to help identify malware in the zones it manages, which in turn helps registrars by identifying malicious code hidden in their domain names.
Verisign’s malware scanning service helps prevent websites from infecting other websites by scanning web pages for embedded malicious content that will infect visitors’ websites. Verisign’s malware scanning technology uses a combination of in-depth malware behavioral analysis, anti-virus results, detailed malware patterns, and network analysis to discover known exploits for the particular scanned zone. If malware is detected, the service sends the registrar a report that contains the number of malicious domains found and details about malicious content within its TLD zones. Reports with remediation instructions are provided to help registrars and registrants eliminate the identified malware from the registrant’s website.
3.2 Policies and Procedures That Address the Abusive Use of Registered Names
ICE plans to administer the .ice gTLD as a closed corporate brand and will not accept registration of second-level domains and⁄or records from external sources. Implementation of any corporate-initiated registrations will be limited to approved members of the ICE Systems Engineering team with proper authorization and approval.

4. WHEN EXECUTED IN ACCORDANCE WITH THE REGISTRY AGREEMENT, PLANS WILL RESULT IN COMPLIANCE WITH CONTRACTUAL REQUIREMENTS

5. TECHNICAL PLAN SCOPE⁄SCALE THAT IS CONSISTENT WITH THE OVERALL BUSINESS APPROACH AND PLANNED SIZE OF THE REGISTRY
Scope⁄Scale Consistency
ICE plans to administer the .ice gTLD as a closed corporate brand and will not accept registration of second-level domains and⁄or records from external sources. As such, the scale and volume is expected to be very small, with less than 100 second-level domains expected each year.
Scope⁄Scale Consistency Specific to Backend Registry Activities
Verisign, ICE’s selected backend registry services provider, is an experienced backend registry provider that has developed and uses proprietary system scaling models to guide the growth of its TLD supporting infrastructure. These models direct Verisign’s infrastructure scaling to include, but not be limited to, server capacity, data storage volume, and network throughput that are aligned to projected demand and usage patterns. Verisign periodically updates these models to account for the adoption of more capable and cost-effective technologies.
Verisign’s scaling models are proven predictors of needed capacity and related cost. As such, they provide the means to link the projected infrastructure needs of the .ice gTLD with necessary implementation and sustainment cost. Using the projected usage volume for the most likely scenario (defined in Question 46, Template 1 – Financial Projections: Most Likely) as an input to its scaling models, Verisign derived the necessary infrastructure required to implement and sustain this gTLD. Verisign’s pricing for the backend registry services it provides to ICE fully accounts for cost related to this infrastructure, which is provided as “Other Operating Cost” (Template 1, Line I.L) within the Question 46 financial projections response.

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