How I Won an Appeal Against US Sanctions

Last Sunday September 4th, I discovered that the GitHub organization Digital Design Schoolin which I am one of the owners, was banned by GitHub with the wording “your account may be subject to US economic sanctions.”

After thinking about it and conferring with my friend, the founder of the Moscow Internet provider RiNet, Sergey Ryzhkov, whose account was banned at Citibank in London on the same day, I decided: we need to fight.

First I studied the page GitHub and Trade Control, where I found some interesting things. For example, it turns out that GitHub has received permission from the US Treasury Department’s Office of Foreign Assets Control (OFAC) to provide services to developers of open-source projects in Iran. It also appears that GitHub is campaigning for US authorities to ease restrictions on Crimea and Syria in honor of human progress and freedom of speech:

GitHub will continue advocating with US regulators for the greatest possible access to code collaboration services to developers in sanctioned regions, such as Syria and Crimea, including private repositories. We believe that offering those services advances human progress, international communication, and the enduring US foreign policy of promoting free speech and the free flow of information.

When I read this, I realized that I should not go around with a sour face, but help the progress of mankind and file an appeal against the DigitalDesignSchool ban, especially since this is my github organization.

Therefore, I clicked on the appeal button, where there were many questions about who is in the organization and what it does, and at the same time created a GitHub support ticket with the following text:

Hello: I got a message that my organization DigitalDesignSchool was flagged and hidden from the public.

I am the owner of this organization and I am a US citizen so I could not be under the sanctions.
I guessed this issue happened because the description of the organization references Skolkovo which is under sanctions.
However, the organization itself is not a part of Skolkovo. There was a seminar on which the presenters rented a room in Skolkovo.
So Skolkovo was used for marketing purposes and that was it.

When I tried to remove the Skolkovo reference from the account, I got a message “It appears this account may be subject to US economic sanctions. As a result, we are unable to provide services to the account. Please read about GitHub and Trade Controls for more information.”

Please review the status of the account. It has a set of basic Verilog examples used for seminars in many places – not only in Russia but also in Ukraine, Kazakhstan, Kyrgyzstan – worldwide. It is a pity if mentioning Skolkovo once because of a past seminar jeopardizes basic Verilog learning for many people.

Thank you
Yuri Panchul

At the same time, I started looking into alternatives to GitHub: GitLab, Gitee, and Bitbucket. Of these, Gitee, which is located in the People’s Republic of China, seemed to me the most promising. In the process of studying GitLab and Gitee, I discovered CI / CD features new to me using YAML (don’t make a hand-face, I’m a verilog writer, not DevOps), so I even benefited from the incident.

But for the time being, the GitHub support consulted with their lawyers and they decided to unban me. First I got this email:

GitHub and Trade Controls
From: GitHub Trade Appeals

Thank you for submitting additional information regarding the trade restrictions placed on your GitHub account. Based on the information you provided, we have enabled full service on your account.

We appreciate your patience and cooperation during this compliance process.

Please note that your organization and/or user account may be flagged again in the future if our system determines the organization is based out of, or the key individuals or membership of the organization shows sufficient ties to, a sanctioned jurisdiction, or if the organization otherwise appears to be restricted by US economic sanctions.

and then like this:

GitHub (GitHub Support)

Hey Yuri,

Thanks for reaching out to us with these details, and the details you shared through our appeals form. After a legal review we have lifted restrictions on this organization. You should now be able to resume normal GitHub use.

To avoid future difficulties I will recommend you remove any references to Skoltech now that you can access your profile again.

Thanks for your patience during this process.

Regards,
GitHub Support

I also realized that I was looking into the water when I created a separate github organization three weeks ago to create materials for events in Central Asia – Digital Design & Verification in Central Asia . These materials have already been used at the seminar “Business models and fundamentals of microelectronics technologies for Central Asia” in Bishkek. The workshop was organized by Siemens EDA and the American University of Central Asia. All videos of lectures and part of videos of laboratory exercises posted on the site ddvca.com.

Now my colleagues and I are planning similar seminars in other capitals of Central Asia and the countries of the former USSR in general. I may need assistance in preparing slides and new examples for themif anyone wants to participate and practice at the same time.

Addition: how to determine that this or that organization is under sanctions? (In this case, not a github organization, but an organization in real life). There is a link for this:

https://www.trade.gov/data-visualization/csl-search

For example, here are screenshots about sanctions against the Moscow Institute of Physics and Technology. We follow the link, enter MIPT and look:

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