The current (ASN) policy is not clear regarding the obligation to register an abuse contact (abuse-c) or its specific fo
rmat, nor as to whether this applies to other WHOIS records.

As a result, some organizations that have received resources from LACNIC may not have this contact information on record
for their resources, and there are even cases of LIRs/ISPs, end users or others that use a non-existent email address o
r one that is not actively monitored.

Because these contacts are not validated, cases of abuse cannot be effectively reported. This creates security issues an
d costs for the victims.

To solve this problem, a simple, periodic verification of abuse contacts is proposed that will avoid unnecessary costs t
o third parties.

The proposal guarantees that the cost of processing an abuse falls on the recipient of the resource who is responsible f
or the abuse, either directly or indirectly (through a customer, from whom they are possibly receiving financial compens
ation for the service), instead of falling on the victim. Bear in mind that this will keep the problem from escalating a
nd will save time and legal costs for both parties involved if the matter is taken to court.

The current (ASN) policy is not clear regarding the obligation to register an abuse contact (abuse-c) or its specific fo
rmat, nor as to whether this applies to other WHOIS records.

As a result, some organizations that have received resources from LACNIC may not have this contact information on record
for their resources, and there are even cases of LIRs/ISPs, end users or others that use a non-existent email address o
r one that is not actively monitored.

Because these contacts are not validated, cases of abuse cannot be effectively reported. This creates security issues an
d costs for the victims.

To solve this problem, a simple, periodic verification of abuse contacts is proposed that will avoid unnecessary costs t
o third parties.

The proposal guarantees that the cost of processing an abuse falls on the recipient of the resource who is responsible f
or the abuse, either directly or indirectly (through a customer, from whom they are possibly receiving financial compens
ation for the service), instead of falling on the victim. Bear in mind that this will keep the problem from escalating a
nd will save time and legal costs for both parties involved if the matter is taken to court.

Current text: N/A

New text:

12.1. Description of “abuse-c” and “abuse-mailbox”

Email messages sent to the “abuse-mailbox” must require manual intervention by the recipient at some time and may not be
filtered, as in certain cases this might prevent the reception of abuse reports. For example, a spam report that includ
es the spam message itself or URLs or content typically classified as spam.

The “abuse-mailbox” may initially return an automatic reply, for example, assigning a ticket number, applying classifica
tion procedures, requesting further information, etc. However, it may not require the use of a form, as this would mean
that each entity that needs to report cases of abuse (a task that is typically automated) would be forced to develop a s
pecific interface for each resource recipient to which it must submit its reports. This would not be viable, as it would
place the cost of processing the abuses on those who submit the claims and are therefore the victims of the abuse, not
on those who (directly or indirectly) cause the abuse.

It is reasonable for the person reporting the abuse to submit sufficient information in the first report (logs, a copy o
f the spam message or its full headers, or equivalent information as applicable for each type of abuse). Likewise, it is
reasonable for the initial auto-reply email to specify that the claim will not be processed unless such information has
been submitted, thus offering the sender the opportunity to repeat the submission and include relevant evidence. This a
llows automatic reporting, for example, via fail2ban, SpamCop or other reporting services, keeping costs at a minimum fo
r both parties involved. Usually, once a ticket number has been assigned, it is to be expected that the same number will
be maintained in all communications (typically as part of the subject).

12.3. Purpose of “abuse-c”/ “abuse-mailbox” validation

The procedure is to be developed by LACNIC and must meet the following objectives:

1) It must guarantee its functionality and allow the helpdesks that deal with the abuse reports to verify that the va
lidation actually originated from LACNIC and not from other sources (involving security risks, avoiding, for example, a
single “direct” URL for validation).

2) A fully automated process should be avoided.

3) It should confirm that the person performing the validation:

• understands the procedure and the LACNIC policies in force;

• regularly monitors the “abuse-mailbox”;

• takes measures in connection thereto;

• responds to the abuse report.

4) An “Initial” validation period of fifteen (15) days.

5) If this validation fails, “escalate” to the original recipient of the resources (LIR, end user, etc.) for an addit
ional period of fifteen (15) days.

The validation periods may be modified at LACNIC's discretion, informing the community of the reasons for doing so.

(By way of recommendation, a detailed procedure is included in this policy proposal under “Additional Information”)

12.4. Validation of “abuse-c”/“abuse-mailbox”

LACNIC will periodically validate compliance with the policy, at least twice a year and whenever “abuse-c” attributes ar
e created or modified.

The validation frequency may be modified at LACNIC's discretion, informing the community of the reasons for doing so.

12.5. Failure to comply

Failure of an organization to comply with this section occurs if it has not been validated during the “initial” or the “
additional” validation periods. This will result in the blocking of MiLACNIC and equivalent measures in the systems of t
he NIRs for all the resources associated with the organization. Strictly contractual and payment-related matters will be
excepted, as will the possibility of updating the abuse-c/abuse-mailbox contacts so that they may be automatically re-v
alidated to allow MiLACNIC to be unblocked.

Any attempt to access MiLACNIC (or the equivalent systems of the NIRs) while the system remains blocked will display a w
arning message including the text of this policy. Before the system allows the person to continue, this message must be
“read” in full and confirmed by selecting a checkbox or other similar mechanism. As technology evolves, other equivalent
mechanisms may be adopted.

If the failure to comply continues, LACNIC will act in accordance with its relevant policies and procedures.

12.6. Escalation to LACNIC

Fraudulent behavior (for example, an “abuse-mailbox” that only replies to emails from LACNIC or to emails having a speci
fic subject or body) or failure to comply with the remaining aspects of this policy (ignoring or incorrectly managing ca
ses of abuse) may be reported to LACNIC for re-validation according to 12.4.

Current text:

N/A

New text:

12.1. Description of “abuse-c” and “abuse-mailbox”

The “abuse-mailbox”:

• Must require intervention by the recipient.

• Must not require the use of a form to report abuse.

• Must guarantee that abuse reports, logs, headers, examples, etc. relating to the case of abuse are received.

12.3. Purpose of “abuse-c”/ “abuse-mailbox” validation

The procedure, to be developed by LACNIC, must meet the following objectives:

1) A simple process that guarantees its functionality and the fulfillment of its purpose.

2) It should confirm that the person performing the validation:

• understands the procedure and the LACNIC policies in force;

• regularly monitors the “abuse-mailbox”;

• takes measures in connection thereto;

• responds to the abuse report.

3) Include an “Initial” validation period of fifteen (15) days.

4) If this validation fails, “escalate”, by any possible means, to the rest of the available contacts within an addit
ional period of fifteen (15) days.

12.4. Validation of “abuse-c”/“abuse-mailbox”

LACNIC will periodically validate compliance with the policy, at least twice a year and whenever “abuse-c” attributes ar
e created or modified.

Failure of an organization to comply with this section occurs if it has not been validated during the “initial” or the “
additional” validation periods.

12.5. Escalation to LACNIC

Fraudulent behavior (for example, an “abuse-mailbox” that only replies to emails from LACNIC or to emails having a speci
fic subject or body) or failure to comply with the remaining aspects of this policy (ignoring or improper attention to c
ases of abuse) may be reported to LACNIC for re-validation according to 12.4.

Current text: N/A

New text:

12.1. Description of “abuse-c” and “abuse-mailbox”

Email messages sent to the “abuse-mailbox” must require manual intervention by the recipient at some time and may not be
filtered, as in certain cases this might prevent the reception of abuse reports. For example, a spam report that includ
es the spam message itself or URLs or content typically classified as spam.

The “abuse-mailbox” may initially return an automatic reply, for example, assigning a ticket number, applying classifica
tion procedures, requesting further information, etc. However, it may not require the use of a form, as this would mean
that each entity that needs to report cases of abuse (a task that is typically automated) would be forced to develop a s
pecific interface for each resource recipient to which it must submit its reports. This would not be viable, as it would
place the cost of processing the abuses on those who submit the claims and are therefore the victims of the abuse, not
on those who (directly or indirectly) cause the abuse.

It is reasonable for the person reporting the abuse to submit sufficient information in the first report (logs, a copy o
f the spam message or its full headers, or equivalent information as applicable for each type of abuse). Likewise, it is
reasonable for the initial auto-reply email to specify that the claim will not be processed unless such information has
been submitted, thus offering the sender the opportunity to repeat the submission and include relevant evidence. This a
llows automatic reporting, for example, via fail2ban, SpamCop or other reporting services, keeping costs at a minimum fo
r both parties involved. Usually, once a ticket number has been assigned, it is to be expected that the same number will
be maintained in all communications (typically as part of the subject).

12.3. Purpose of “abuse-c”/ “abuse-mailbox” validation

The procedure is to be developed by LACNIC and must meet the following objectives:

1) It must guarantee its functionality and allow the helpdesks that deal with the abuse reports to verify that the va
lidation actually originated from LACNIC and not from other sources (involving security risks, avoiding, for example, a
single “direct” URL for validation).

2) A fully automated process should be avoided.

3) It should confirm that the person performing the validation:

• understands the procedure and the LACNIC policies in force;

• regularly monitors the “abuse-mailbox”;

• takes measures in connection thereto;

• responds to the abuse report.

4) An “Initial” validation period of fifteen (15) days.

5) If this validation fails, “escalate” to the original recipient of the resources (LIR, end user, etc.) for an addit
ional period of fifteen (15) days.

The validation periods may be modified at LACNIC's discretion, informing the community of the reasons for doing so.

(By way of recommendation, a detailed procedure is included in this policy proposal under “Additional Information”)

12.4. Validation of “abuse-c”/“abuse-mailbox”

LACNIC will periodically validate compliance with the policy, at least twice a year and whenever “abuse-c” attributes ar
e created or modified.

The validation frequency may be modified at LACNIC's discretion, informing the community of the reasons for doing so.

12.5. Failure to comply

Failure of an organization to comply with this section occurs if it has not been validated during the “initial” or the “
additional” validation periods. This will result in the blocking of MiLACNIC and equivalent measures in the systems of t
he NIRs for all the resources associated with the organization. Strictly contractual and payment-related matters will be
excepted, as will the possibility of updating the abuse-c/abuse-mailbox contacts so that they may be automatically re-v
alidated to allow MiLACNIC to be unblocked.

Any attempt to access MiLACNIC (or the equivalent systems of the NIRs) while the system remains blocked will display a w
arning message including the text of this policy. Before the system allows the person to continue, this message must be
“read” in full and confirmed by selecting a checkbox or other similar mechanism. As technology evolves, other equivalent
mechanisms may be adopted.

If the failure to comply continues, LACNIC will act in accordance with its relevant policies and procedures.

12.6. Escalation to LACNIC

Fraudulent behavior (for example, an “abuse-mailbox” that only replies to emails from LACNIC or to emails having a speci
fic subject or body) or failure to comply with the remaining aspects of this policy (ignoring or incorrectly managing ca
ses of abuse) may be reported to LACNIC for re-validation according to 12.4.

Current text:

N/A

New text:

12.1. Description of “abuse-c” and “abuse-mailbox”

The “abuse-mailbox”:

• Must require intervention by the recipient.

• Must not require the use of a form to report abuse.

• Must guarantee that abuse reports, logs, headers, examples, etc. relating to the case of abuse are received.

12.3. Purpose of “abuse-c”/ “abuse-mailbox” validation

The procedure, to be developed by LACNIC, must meet the following objectives:

1) A simple process that guarantees its functionality and the fulfillment of its purpose.

2) It should confirm that the person performing the validation:

• understands the procedure and the LACNIC policies in force;

• regularly monitors the “abuse-mailbox”;

• takes measures in connection thereto;

• responds to the abuse report.

3) Include an “Initial” validation period of fifteen (15) days.

4) If this validation fails, “escalate”, by any possible means, to the rest of the available contacts within an addit
ional period of fifteen (15) days.

12.4. Validation of “abuse-c”/“abuse-mailbox”

LACNIC will periodically validate compliance with the policy, at least twice a year and whenever “abuse-c” attributes ar
e created or modified.

Failure of an organization to comply with this section occurs if it has not been validated during the “initial” or the “
additional” validation periods.

12.5. Escalation to LACNIC

Fraudulent behavior (for example, an “abuse-mailbox” that only replies to emails from LACNIC or to emails having a speci
fic subject or body) or failure to comply with the remaining aspects of this policy (ignoring or improper attention to c
ases of abuse) may be reported to LACNIC for re-validation according to 12.4.

Note (not to be included in the Policy Manual):

Current Section “12. Appendixes” would become Section “A. Appendixes” and be located at the end of the Policy Manual. In
addition, the entire Manual would be updated to reflect this change of numbering. Then, as the Manual continues to grow
, renumbering would not be necessary when a new section is added. The text of this proposal would therefore be included
in the Policy Manual as Section 12 or any other number deemed appropriate by the staff at the time of its implementation
, once consensus has been reached.

The following text is an example of a validation procedure based on typical helpdesk practices which, for example, does
not require clicking on an html link sent via email to prevent phishing or other malicious actions. While this text is n
ot part of the policy, we recommend its consideration, as it is the result of the discussions on abuse-c policies that h
ave taken place among the global community.

1) LACNIC automatically initiates the validation by sending TWO consecutive emails to the “abuse-mailbox”.

2) These emails will contain plain text only (thus hiding any URLs intended as phishing or other types of attacks).

3) At the discretion of LACNIC, in general or in specific cases (for example, for confirmation in cases of escalation
under 12.6), LACNIC may use domains other than lacnic.* and even modify the subject and body of the message in order to
increase the efficiency of said validations.

4) The first email will contain the URL where the validation is to be performed (“validacion.lacnic.net”) and may con
tain information about the procedure, a brief summary of this policy, etc.

5) The second email will contain a unique alphanumeric validation code.

6) The recipient responsible for the “abuse-mailbox” must go to the URL and paste the code they received in the second e
mail in the form.

7) This URL must be designed in such a way that it prevents the use of an automated process (for example, “captcha”).
In addition, it must contain a text that confirms that the person performing the validation understands the procedure a
nd the policy, that they regularly monitor the “abuse-mailbox”, that appropriate measures are taken to solve reported ca
ses of abuse, and that the abuse report receives a response, with a checkbox that must be accepted in order to proceed.

8) The alphanumeric code will be valid for a maximum of 15 days.

9) If the code is not entered within this period, the system will mark the “abuse-c” as “temporarily invalid” and wil
l alert LACNIC staff so that they can initiate a personalized follow-up with the resource's recipient.

10) If no reply is received confirming that the situation has been corrected, after an additional period of 15 days,
the “abuse-c” will be marked as permanently “invalid”.

11) The validation process will be repeated automatically (items 1 to 7 above). If satisfactory, the “abuse-c” will b
e marked as “valid”; otherwise, it will be considered in breach of the policy.

12) LACNIC will have mechanisms in place (a form, an email address and possibly others in the future) to facilitate t
he escalation in cases where reporting a breach of this policy is desired. This will allow re-validation (12.4) and LACN
IC's intervention in applying the policies, procedures and contractual requirements in force.

Note (not to be included in the Policy Manual): Current Section “12. Appendixes” would become Section “A. Appendixes” an
d be located at the end of the Policy Manual. In addition, the entire Manual would be updated to reflect this change of
numbering. Then, as the Manual continues to grow, renumbering would not be necessary when a new section is added. The te
xt of this proposal would therefore be included in the Policy Manual as Section 12 or any other number deemed appropriat
e by the staff at the time of its implementation , once consensus has been reached.

LACNIC may modify the “initial” and “escalated” validation periods if it sees fit, provided that the community is inform
ed of the reasons for such changes. For example, these periods might be extended during the initial implementation phase
and then progressively adjusted as a higher portion of contacts is verified.

Similarly, the frequency of the periodic verification may be modified by LACNIC if it sees fit, also informing the commu
nity of the reasons for doing so. For example, the first year a single validation might be carried out to facilitate com
pliance with the policy, and then number of validations might be progressively increased, perhaps conducting them quarte
rly, to improve the quality of the contacts.

The following text is an example of a validation procedure based on typical helpdesk practices which, for example, does
not require clicking on an html link sent via email to prevent phishing or other malicious actions. While this text is n
ot part of the policy, we recommend its consideration, as it is the result of the discussions on abuse-c policies that h
ave taken place among the global community.

(See previous version of the proposal, the form only allows a limited number of characters)