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Russia Sanctions Add Shock Internet Censorship Twist for UK ISPs UPDATE2

Saturday, April 30th, 2022 (8:17 am) - Score 9,000
IP Address vector concept

Broadband and mobile providers were on Friday subjected to a shock twist after the Government – without consultation – amended the Russian sanctions legislation to require that – “a person who provides an internet access service must take reasonable steps to prevent a user of the service in the [UK] from accessing … an internet service provided by a designated person.”

On the surface, the wording of this surprisingly broad amendment to The Russia (Sanctions) (EU Exit) Regulations 2019 seems straightforward, and a “designated person” would appear to be anybody that the Secretary of State deems to fall within the scope of this sanction (i.e. somebody that has been sanctioned by the UK gov). Fair enough, you may think.

NOTE: Hopefully, no explanation is required to understand the many reasons why sanctions are currently being imposed against Russia.

However, an additional explanatory note later confuses this by attempting to clarify that ISPs “must take reasonable steps to prevent users of the service in the [UK] from accessing websites provided by a designated person. This will likely take the form of URL blocking.” Except, that’s not what the legislation itself says, which is broader and defines an “internet service” as a “service that is made available by means of the internet.

At this point we’re going to try and avoid a lengthier explanation by doing a simplified summary of the key points of contention with all this. We’d also recommend reading Neil Brown’s excellent blog post on this via law firm decoded.legal for a wider explanation of the problems. But to simplify..

Simple Summary of the Key Problems

➤ How are internet providers expected to be able to tell what “internet services” are even “provided by a designated person“? We’re not sure, but the government might be able to produce a block list of some sort (e.g. website domains or IP addresses / ranges) to help fill in the blanks. We expect more guidance on this to be published soon.

➤ The question of which internet providers are in-scope of this change is a big one. The sanction doesn’t seem to distinguish between consumers and businesses, instead catching “a person who provides an internet access service“, which could seemingly include everything from big broadband ISPs to personal Wi-Fi hotspots on your Smartphone, possibly even VPN providers or your home broadband router etc. It’s unntenably broad.

➤ Not all ISPs have developed or implemented network-level blocking (censorship) tools, particularly smaller providers without the budget needed for such filtering systems. But in having said that, the obligation to take “reasonable steps” (i.e. it’s not an absolute) means that providers could probably get away with just a basic DNS level block or similar, assuming they’re told what they need to block in the first place.

➤ Any blocks imposed at ISP level can be easily circumvented by those with only a basic bit of IT knowledge (third-party DNS, VPN, Proxy Servers etc.). This is not the ISPs fault, it’s just how the internet was designed.

The UK telecoms regulator, Ofcom, is required to oversee all this and monitor compliance. No doubt ISPs will have A LOT of questions for them. But providers that fail to comply with the new sanction (or a related information gathering request) could face a financial penalty of up to £1m. So, hard luck if you just setup a personal WiFi hotspot on your mobile phone, but whoops.. did you forget to check the latest Russian sanctions list and ensure you’re implementing all the right blocks? It would be funny, if it wasn’t actual legislation.

Adrian Kennard, Boss of ISP Andrews & Arnold (AAISP), said (blog):

“I can’t stress this enough, we have never had any order to block anything or any previous legal requirement to do so, really. It is, in my opinion, not “reasonable” to expect us (for no payment at all, or otherwise) to magically implement such a measure, especially to do so between Laid before Parliament at 5.00 p.m. on 27th April 2022 and coming into force 29th April 2022, really. Or even (as it will cost a lot) later.

What could we do?

At a push we could block some domains on our DNS servers, but customer do not have to use them, so that would not be effective in meeting the requirement. And weirdly the providers of public DNS, like 8.8.8.8 and 1.1.1.1 are not subject to this order – why?

Indeed, if we had some way to block some routing to some IPs (and remembering we must not “over block” to meet net neutrality laws), customers are allowed to, and often do, use VPNs, so again, it would not actually be effective.

I am not sure we could “reasonably” take any technical measures.

So what do we do?

Well, step one is we ask OFCOM for the list of services, and see what we get. That is it for now. I expect no list, to be honest, which sort of solves the problem.”

Adrian also suggested that ISPs could perhaps become compliant simply by “[asking] customers nicely” not to access such services, which might be enough to be deemed a “reasonable” step. It’s at least no less absurd than expecting anybody who provides an internet service – personal or otherwise – to comply with the new legislation. Assuming, that is, the provider can confidently first identify precisely what services the government actually wants to be blocked.

UPDATE 12:29pm

The following is an extract from a related message that was sent to network operators by DCMS (Government), which adds a bit more context.

DCMS Statement

The exact restriction will depend on the service provided, with full details outlined in the Statutory Instrument and accompanying Explanatory Memorandum. Most pertinent to your organisation are the requirements for fixed and wireless broadband providers, who must take reasonable steps to prevent users of their service in the United Kingdom from accessing websites provided by a designated person.

This will likely take the form of URL or DNS blocking. The restrictions will apply to persons designated by the UK Government and we expect the designations to be announced imminently. The Explanatory Memorandum also sets Ofcom as the specified body responsible for overseeing compliance with the measure, who will contact you separately.

We appreciate that you may require support in order to ensure the sanction measures are implemented as smoothly and efficiently as possible.

UPDATE 6th May 2022

Ofcom and the UK Sanctions List appear to have confirmed that the first block list domains are for rt.com, sputniknews.com and rossiyasegodnya.com. Most ISPs will be implementing this via a basic DNS level block, which is usually the simplest approach.

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By Mark Jackson
Mark is a professional technology writer, IT consultant and computer engineer from Dorset (England), he also founded ISPreview in 1999 and enjoys analysing the latest telecoms and broadband developments. Find me on Twitter, , Facebook and Linkedin.
Leave a Comment
41 Responses
  1. Chris Sayers says:

    Good grief Mark, how did you summaries this, my head hurts just reading it!

  2. Optimist says:

    I expect this will affect those who are still using Kaspersky AV. I uninstalled it soon after the war started.

    1. Tech3475 says:

      If they do, I’m curious if/how refunds will be handled i.e. you’re partially through an active subscription or you have a spare key but it’s outside the normal return window.

      I’d imagine the latter might be easier (under 1 year) but the former may be SOL.

  3. Truthsayer says:

    Western governments look at how successful the Chinese Communist party was at crushing dissent and salivate to implement their measures one by one

    Central bank digital currencies are no longer a conspiracy

    1. Yatta! says:

      Sterling has been a digital currency for decades, only existing in databases with only a small fraction of it having a physical representation in the form of cash.

      Almost entirely all currencies are fiat currencies where they’re only backed-up by government ‘promises’ anyway, so I don’t know what you’re so concerned about in that regard… unless you’re attempting to cash hide income?

    2. Yatta! says:

      ^”hide cash” not “cash hide”, had a brain fart.

    3. Truthsayer says:

      Fiat is bad and central banks abusing their money printing is what is prob the main reason for the inflation

      But CBDCs are an entirely different authoritarian beast. Think WeChat in china but even more dystopian. Suddenly govt is free to hand out cash that can only be used in certain govt approved shops. Full power to seize funds. Penalties tied to vaxx status/who you voted for/if you own a car

    4. Anonyomouse says:

      “unless you’re attempting to cash hide income?”

      Im sure our great chancellor Rishi Sunak and pals would be on the case immediately if anyone dared tried hide money of any description or tried to avoid tax and come down with full force upon them…. Oh opps errr hold on.

    5. Summer Is not here says:

      @Anonyomouse

      You have been busy replaying to ever negative comment written against the Russians.

    6. Anonyomouse says:

      “@Anonyomouse

      You have been busy replaying to ever negative comment written against the Russians.”

      I think you will find the response in this thread was about hiding money and who else does it.

  4. Me says:

    We are turning into a country of xenophobes against Russians.. People should be allowed to chose if they wish to use Russian services or websites.

    1. Mike says:

      Freedom of speech is racist so you can’t have that anymore.

    2. Darren Reid says:

      It’s not xenophobic. It’s trying to cause economic harm as we can’t cause military harm.

    3. Billy says:

      The UK government has been blatantly Russophobic all of my life. And their propaganda machine never stops. Even when Gavin told the Russians to, “shut up and go away”; Despite looking like a complete tool whilst doing it, was part of this chronic anti-Russian campaign HM Government engages in. The Russians don’t help of course, sailing their ships in the North Sea like it was some kind of international waterway, and flying their planes through air within our 200 mile exclusive economic zone. It is annoying when we have to scramble 3 or 4 fighter aircraft to go and keep an eye on our air, at great expense I might add, and at the same time, the air ambulance is reliant on sponsored walks and tombolos to afford to operate.

    4. Just Remember says:

      @Billy

      Considering whats happening in Ukraine seems like the UK government were right all along.

    5. Me says:

      @Darren Reid, it IS xenophobic when Wimbledon bans all Russian tennis players who won’t publicly object to the Ukraine invasion, in fact it’s worst then that as it’s forcing players to put their lives in danger by doing such a thing, just to play there chosen sport. It’s disgraceful bullying hypocritical behaviour by the British.

    6. Anonyomouse says:

      “It’s not xenophobic. It’s trying to cause economic harm as we can’t cause military harm.”

      SO pretty much compulsory service like the Russians and Chinese have only minus the gun as that would also cause moral outrage.

      Lets get real here for a second shall we. If any organisation cared about the “blood” money earned through business operating in or through Russian, then i am sure all the big business that has withdrawn operations out there would be chipping in the billions they earned in blood money from Russian operations over the years and giving it to the Ukraines and West to fight the good fight against them. Maccie Ds the great American glorious can start, less happy meals and more help for the Ukraines, give them the billions you earned from the nasty commie/dictator (insert media headline abusive word) country.

  5. jet14 says:

    The west are the biggest hypocrites!!! What about the millions killed by Nato America and UK in Iraq, Syria and Afghanistan and the rest of the world,
    This is dirty tactics to go after Russia.

    1. Maybe Not says:

      I’m guessing you don’t consider yourself to be British with that attitude.

    2. Anonyomouse says:

      “I’m guessing you don’t consider yourself to be British with that attitude.”

      Quite what those in power in any country do and what it has to do with your defining your nationality, i have no idea.

      Unless you are saying every British person was in favour of bombing Iraq and every Russian person is it favour of attacking Ukraine. That must be an interesting thought process.

    3. Alan says:

      Well said jet14, the hypocrisy by the west stinks. NATO did to Iraq what Russia is doing to Ukraine.

    4. Me says:

      NATO, well specifically the US and U.K. illegally entered Iraq with its forces based on made up intelligence, anyone remember the hyper gun the British government tried to sell you on? That long pipe that was made in Britain for a fun time fire shells thousands of miles or some such, that later turns out to be total BS. Yes the hypocrisy is quite palpable, I believe that the contracts for the rebuilding of Iraq after it was bombed by the West was awarded to Western companies, again not surprising.
      And todays news, again perhaps unsurprising, is that they’ve found components made in Europe and the U.K. inside Russian weapons and systems they’ve captured.
      As they say bull excrement walks money talks, always has always will.

  6. Sarc Asm says:

    Omg sssaaaaammmmmmmmeeeeee as me bro! Hate the internet, i just use wifi

  7. Oggy says:

    Completely unworkable and bypassed in a couple of clicks.

  8. Disgruntled of Dankshire says:

    What about
    1. Software that will not function unless it can phone home to check the license?
    2. Web sites, built by so called experts (hahaha), more like script kiddies, which will not function unless they can access other sites, and no script will not help as the rest of the application depends on the curse called javascript.

  9. Pete Church says:

    VPN baby.Giggerdy.

  10. An Engineer says:

    Well you wouldn’t have been able to write that message unless British and Polish engineers built the WW2 Bombes, these were evolved by US, British and other engineers into modern computers like the one you wrote those words on.

    As this evolution was ongoing a bunch were connected together via DARPAnet which introduced the technologies that transported your words to ISPR.

    Then in 1989 the British computer scientist Tim Berners-Lee invented the markup protocol used to handle your message, so that ISPR knew what to do with the words you sent, and allowed others to read them.

    Whether this was to anyone’s benefit is debatable.

    1. Anonyomouse says:

      “Well you wouldn’t have been able to write that message unless British and Polish engineers built the WW2 Bombes, these were evolved by US, British and other engineers into modern computers like the one you wrote those words on.”

      Ooooo if war and bombs equals forward progress in technology then maybe we should hope Russian hurrys up and Nukes Ukraine like we did the Japs in WW2. Just imagine the technology the world will have so much sooner if we speed that process along. We can also ohelp, we better get back out in the Middle East and get some more minerals for the next industrial revolution while we are at it. (Oh and YES im being sarcastic incase anyone was actually thinking i was being serious).

      “As this evolution was ongoing a bunch were connected together via DARPAnet which introduced the technologies that transported your words to ISPR.

      Then in 1989 the British computer scientist Tim Berners-Lee invented the markup protocol used to handle your message, so that ISPR knew what to do with the words you sent, and allowed others to read them.

      Whether this was to anyone’s benefit is debatable.”

      And now that wonderful communication system that was developed and later given to the people, they want to take away. Or worse yet dictate what you say and the thoughts you have, while using it. The sounds suspiciously like what they have accused countries like China of for Years. Funny that eh?

  11. An Engineer says:

    The Online Safety Bill is going to be painful for Mark.

    Just taking samples from 2 of the top 3 stories there’re comments that could be considered ableism, racism and religious discrimination alongside robust appeasement of Russia and a comment that looks alarmingly like a wordy version of ‘death to the West’.

    Between that bill and things like this I expect we’ll get a Golden Shield of our own, the Red, White and Blue Shield, in pretty short order. Most of the infrastructure for it is in place.

    1. Me says:

      The government has definitely killed freedom of speech on the internet, exactly what they want to do, they don’t want people having opinions and being able to read actual facts around government actions or big business, they want to manipulate and hide those facts. But they can’t get around VPN’s and I doubt their bill will even be considered by foreign forums.

    2. Mike says:

      @Me

      I hope foreign firms ignore them so the government is forced to either backoff or block them, perhaps then the population will start to take notice of what’s going on.

    3. Anonyomouse says:

      “I hope foreign firms ignore them so the government is forced to either backoff or block them, perhaps then the population will start to take notice of what’s going on.”

      In this modern era of cancel culture and finger pointing i highly doubt they will. The state sponsored BBC just for starters will ram it down our throats how bad xyz organisation is if they do not comply and the sheeple can follow with the outrage.

  12. John says:

    I miss reading and watching RT. It does make you wonder the level of lies our government and state propagandist media is telling us, when they can’t even take the chance of a small number seeing RT.

    1. John says:

      You could always move to Ukraine if you don’t believe the west.

    2. Anonyomouse says:

      “You could always move to Ukraine if you don’t believe the west.”

      Ah the great media debate and which is truthful or which is not.

      RT the organisation our media goes to great lengths to make clear is “STATE” spnosored Russian Media at every glance.

      Ran by whoever is in charge of Russia over the decades, poisoning minds against the west.

      The BBC the organisation which is also state sponsored, but doesn’t want to advertise the inconvenient fact in every breath (not very Brtitish to do that). A great British institution not biased in any way shape or form. An organisation which would never send round a goon to your doorstep if you dared not pay your state sponsorship fee to them, that stuff only happens in the dictatorship countries.

      It is a good job we have such a wholesome broadcast corporation reporting the facts and protecting the children from evil in the world rather than harming them….. Opps ignore that last bit.

      Don’t know about others but i will avoid them both if you do not mind. Switching off if far easier than moving house.

    3. Phil says:

      RT.Com not blocked by every ISP, just the main players.

      I find RT.COM more balanced on world news items than the BBC. If you compared the number of fines OFCOM have issued to RT and the BBC, then the BBC have had more fines for their news reporting than RT, and you can bet OFCOM were watching RT like a hawk!

      Each side is going to be biased to a greater or less degree, and we need to see from both sides in order to stand a chance of working out where those biases might be.

      It has been quite clear since the pandemic and censorship surrounding that, that our media is censored and following the “state” narrative, and my trust of the news outlets in the UK is rock bottom.

  13. Steebs says:

    I have to ask, honestly, What is the point. Look back in time, with the days of Pirate bay, when all ISP’s were instructed that they had to block access to that and many other file sharing sites. How successful was that? From information I was able to garner, the use of file sharing sites didn’t really drop off in the long term, people just used VPN’s and Proxy sites to get around the block.

    This “law” and I use that term loosely, has been ill thought out and doesn’t give anyone except large operators, with the necessary equipment already in place, the ability to act on it. Making it a “law” rather than a requirement was about as useful as the paper it’s written on.

    Please do not get me wrong, I think isolating Russia from the world is a great way of furthering the existing embargos, but perhaps rather that trying to do this further up the OSI, how about simply doing it at Layer One! It’s long been said that in the event of global war, undersea cables would be the first to be severed, thereby electronically isolating countries from one another. Look at what Russia did to the Ukraine infractucture in order to limit communication. They did it with bombs and missiles rather than command line interfaces.

    What’s good for the goose, is good for the gander!

    My apologies to anyone who is offended by my views, but they are just that; MY views.

    1. Anonyomouse says:

      “I have to ask, honestly, What is the point.”

      There is no point, its political finger wagging to make it look like something is being done while people die. That is the reality.

      Controlling who talks to someone else in xyz country or it now appears to be controlling who is online to buy/import a bottle of Vodka from the red curtain for your fave family drunk member is going to save Ukraine.

      Cancel it all throw a hissy fit and sulk it will save everyone.

    2. Summer Is not here says:

      @Anonyomouse

      You have been busy replaying to ever negative comment written against the Russians.

    3. Anonyomouse says:

      “@Anonyomouse

      You have been busy replaying to ever negative comment written against the Russians.”

      And you have been busy copying and pasting a response to me, so your point is what? Is it to cancel a persons opinions and views?

  14. SomersetBob says:

    Nadine at her finest!

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