[arin-ppml] Draft Policy ARIN-2019-5: Validation of Abuse-mailbox

[Michael Peddemors]

Still would like to see that idea I put forth about ARIN actually having
a public ticketing system, for when the public reports inaccurate data.

This way a public record can be seen to how long tickets remain
unresolved, and a bit of public shaming on this.

I think this would do more than most policies.

Just tried to email an large carrier (noPTR issues) so emailed the
contact on record..

OrgTechHandle: IPMAN-ARIN
OrgTechName:   IP MANAGE
OrgTechPhone:  +1-647-747-3294
OrgTechEmail:  ipmanage at rogers.wave.ca
OrgTechRef:    https://rdap.arin.net/registry/entity/IPMAN-ARIN

<ipmanage at rogers.wave.ca>:
Remote host 66.185.87.233 does not like recipient ipmanage at rogers.wave.ca
Remote host said: 550 5.1.1 <ipmanage at rogers.wave.ca>: Recipient address
rejected: User unknown in virtual mailbox table



On 2019-03-26 12:52 p.m., ARIN wrote:
> On 21 March 2019, the ARIN Advisory Council (AC) accepted
> "ARIN-prop-264: Validation of Abuse-mailbox" as a Draft Policy.
> 
> The Draft Policy text is below and can be found at:
> https://www.arin.net/participate/policy/drafts/2019_5/
> 
> You are encouraged to discuss all Draft Policies on PPML. The AC will
> evaluate the discussion in order to assess the conformance of this draft
> policy with ARIN's Principles of Internet number resource policy as
> stated in the Policy Development Process (PDP). Specifically, these
> principles are:
> 
> * Enabling Fair and Impartial Number Resource Administration
> * Technically Sound
> * Supported by the Community
> 
> The PDP can be found at:
> https://www.arin.net/participate/policy/pdp/
> 
> Draft Policies and Proposals under discussion can be found at:
> https://www.arin.net/participate/policy/drafts/
> 
> Regards,
> 
> Sean Hopkins
> Policy Analyst
> American Registry for Internet Numbers (ARIN)
> 
> 
> 
> Draft Policy ARIN-2019-5: Validation of Abuse-mailbox
> 
> Problem Statement:
> 
> The current policy, “3.6. Annual Validation of ARIN’s Public Whois Point
> of Contact Data” does not provide sufficient validation of the actual
> availability of the abuse mailbox.
> 
> As a result, some resource-holders (LIRs and end-users) might not keep
> this contact information up to date, or might use a non-responsive
> mailbox, which could be full or not actively monitored, or even
> responding only to ARIN emails.
> 
> In practice, this contact becomes ineffective to report abuse and
> generally gives rise to security issues and costs for the victims.
> 
> Furthermore, POCs are verified only every year and provides a too much
> relaxed response time (60 days).
> 
> Finally, the proposal is aiming to have a standard abuse-c/abuse-mailbox
> as a pointer to the actual abuse POC, in order to facilitate tools
> across regions.
> 
> This proposal aims to solve those issues and ensure the existence of a
> proper abuse-c POC and the process for its utilisation.
> 
> a. Arguments Supporting the Proposal
> 
> The Internet community is based on collaboration. However, in many cases
> this is not enough and we need to be able to contact those
> resource-holders (LIRs or end-users) that may be experiencing a problem
> in their networks and are unaware of the situation.
> 
> This proposal solves this problem by means of a simple, periodic
> verification, and establishes the basic rules for performing such
> verification and thus avoids unnecessary costs to third parties that
> need to contact the persons responsible for solving the abuses of a
> specific network.
> 
> The proposal guarantees that the cost of processing the abuse falls on
> the resource-holder causing the abuse (or its customers, from whom they
> receive financial compensation for the service), instead of falling on
> the victim, as would be the case if they had to resort to a legal claim
> in an extreme case, thus avoiding costs (investigation and in the
> worst-case lawyers, solicitors, etc.) and saving time for both parties.
> 
> Having an equivalent policy in different regions, has the advantage of
> improving overall response to abuse cases, reduces the cost for handling
> them, and facilitates the work for all the people involved in the
> operation of Internet.
> 
> b. Arguments Opposing the Proposal
> 
> ARIN members have to verify and update (if required) their abuse-c
> objects periodically.
> 
> Policy Statement:
> 
> Proposed
> 
> 1.0 Abuse Contact Information
> 
> The “abuse-c:” will reference a role object holding abuse contact
> information. The positioning of the “abuse-c:” attributes will make use
> of the hierarchical nature of the resource data to minimize the workload
> on resource holders. Internet number resources need to have an
> “abuse-c:” attribute. The “abuse-c:” will be mandatory for all aut-nums.
> Due the hierarchical nature of IP address objects, at least every direct
> allocated inetnum and inet6num needs to have an “abuse-c:”. Inherited
> objects might have their own “abuse-c:” attribute or they will be
> covered by the higher-level objects. The role objects used for abuse
> contact information will be required to contain a single
> “abuse-mailbox:” attribute which is intended for receiving automatic and
> manual reports about abusive behavior originating in the resource
> holders’ networks. The “abuse-mailbox:” attribute must be available in
> an unrestricted way via whois, APIs and future techniques. ARIN will
> validate the “abuse-mailbox:” attribute at least every six months, as
> per the procedure stated in this policy. Where the attribute is deemed
> incorrect, it will follow up in compliance with relevant ARIN policies
> and procedures. As per current practice, other “e-mail:” attributes can
> be included for any other purposes.
> 
> 2.0 About the “abuse-mailbox”
> 
> Emails sent to “abuse-mailbox” must require manual intervention by the
> recipient at some point, and may not be filtered, because in certain
> cases this might prevent receiving abuse reports, for example in a spam
> case where the abuse report could include the spam message itself or
> URLs or content usually classified as spam. The “abuse-mailbox” may
> initially send an automatic reply, for example assigning a ticket
> number, applying classification procedures, requesting further
> information, etc. However, it should not require that the abuse reporter
> fills a form, as this will imply that each entity that needs to report
> abuse cases (a task that is typically automated), would be forced to
> develop a specific interface for each resource-holder in the world that
> mandates filling forms, which is neither feasible nor logical, as it
> would place the cost of processing the abuse on those who submit the
> claim and are therefore victims of the abuse, instead of being paid for
> by those whose clients cause the abuse (and from whom they obtain
> income). By way of information, it is worth noting that it is reasonable
> to expect that the abuse reporting procedure sends, with the initial
> abuse report, the logs, a copy of the spam message (attaching an example
> of the spam email or its full headers), or equivalent evidence
> (depending on the abuse type). Likewise, it is reasonable to expect that
> the initial auto-reply email could specify that the claim will not be
> processed unless such evidence has been submitted, thus allowing the
> sender an opportunity to repeat the submission and include relevant
> evidence. This allows automatic reporting, for example, via fail2ban,
> SpamCop or others, keeping costs at a minimum for both parties involved.
> 
> 3.0 Objectives of “abuse-mailbox” validation
> 
> The procedure, which will be developed by the ARIN, must meet the
> following objectives: 1. A simple process that guarantees its
> functionality and allows the helpdesks that deal with abuse reports to
> verify that validation requests actually come from the ARIN and not from
> third parties (which might involve security risks), avoiding, for
> example, a single “direct” URL for validation. 2. Avoid exclusively
> automated processing. 3. Confirm that the person performing the
> validation understands the procedure and the policy, that they regularly
> monitor the “abuse-mailbox”, that measures are taken, and that the abuse
> report receives a response. 4. Validation period of no longer than 15
> days. 5. If validation fails, escalate to the LIR and set a new
> validation period not to exceed 15 days. The “initial” and “escalation”
> validation periods may be modified by the ARIN, if deemed appropriate,
> informing the community about the motivation. For example, it could be
> longer for the first validation, once this policy is implemented, and
> shortened afterwards once the percentage of failures decreases, so the
> quality of the contacts increases and consequently a decrease in the
> average abuse response times could be expected. (By way of example, a
> detailed procedure is included in this policy proposal under
> “Comments/Example of the validation procedure”) 4.0 Validation of
> “abuse-mailbox”
> 
> ARIN will validate compliance with the items above, both when the
> “abuse-c:” and/or “abuse-mailbox:” attributes are created or updated, as
> well as periodically, not less than once every six months, and whenever
> ARIN sees fit. At the discretion of ARIN, in general or in specific
> cases (for example, for confirmation in cases of escalation under 5.),
> ARIN may use domains other than arin., and even modify the subject and
> body of the message, in order to perform said validations more
> effectively. Lack of compliance will initially lead to the blocking of
> that account’s access to the invalid resources at ARIN Online, except
> for the abuse-c/abuse-mailbox update and payments. The account blocking
> will be released upon re-validation of the abuse-c/ abuse-mailbox,
> triggered automatically by the update of the abuse-c/abuse-mailbox.
> During the blocking of that account to the invalid resources, each time
> is accessed, will show a warning message including this policy text, and
> to continue it will be necessary to confirm by means of a check-box,
> that the message has been read in full. ARIN will do a more exhaustive
> follow-up, in accordance with the relevant ARIN policies, procedures or
> contractual requirements. The frequency of the periodic validation could
> be modified if ARIN deems this appropriate and informs the community of
> its reasons. For example, a single validation could be done in the first
> year, to facilitate adherence to the policy, and then the number of
> annual validations could progressively increase, reaching even quarterly
> ones, with the aim of improving the quality of the contacts.
> 
> 5.0 Escalation to ARIN
> 
> To avoid fraudulent behavior (for example, an “abuse-mailbox” that only
> replies to ARIN emails or to messages with a specific subject or
> content), or failure to comply with the remaining aspects of this policy
> (incorrect or lack of response to cases of abuse), a mailbox will be
> available (for example, “escalation-abuse at arin.net”), to escalate such
> situations. This would allow for a re-validation (according to section
> 4. above) and even intervention by ARIN and, where appropriate, the
> application of the relevant policies, procedures or contractual
> requirements.
> 
> Comments:
> 
> Timetable for implementation: Immediate
> 
> Anything Else
> 
> Situation in other regions:
> 
> A similar proposal has been accepted in APNIC (being implemented) and is
> under discussion in the LACNIC and AFRINIC regions. It has also been
> submitted to RIPE (still not published).
> 
> Example of the validation procedure.
> 
> 1. ARIN initiates the validation automatically, sending TWO consecutive
> emails to the “abuse-mailbox”.
> 
> 2. These emails will be sent containing plain text only.
> 
> 3. The first email will contain the URL where the validation is to be
> performed (“validation.arin.net”) and may contain information about the
> procedure, a brief summary of this policy, etc.
> 
> 4. The second email will contain a unique alphanumeric validation code.
> 
> 5. The person in charge of the “abuse-mailbox” must go to the URL and
> paste the code received in the second email in the form.
> 
> 6. 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 and the policy, that they regularly monitor
> the “abuse-mailbox”, that measures are taken to solve reported cases of
> abuse, and that the abuse report receives a response, with a “checkbox”
> that must be accepted in order to proceed.
> 
> 7. The alphanumeric code will only be valid for a maximum of 15 working
> days.
> 
> 8. If the code is not entered within that time, the system will mark the
> “abuse-c” as “temporarily invalid” and will alert ARIN staff so that
> they can initiate a personalized follow-up with the LIR.
> 
> 9. If no reply is received confirming that the situation has been
> corrected, after an additional period of three business days, the
> “abuse-c” will be permanently marked as “invalid”.
> 
> 10. Once the issue has been resolved, the validation process will be
> repeated automatically (items 1 to 7 above). If satisfactory, the
> “abuse-c” will be marked as “valid”; otherwise it will be considered in
> breach of the policy.
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