Association Monegasque Des Banques

A. General Description of the Application
  1. TLD String(s) Requested.
  2. Category.
    General Purpose, Restricted Commercial.

    The Monaco Banking Association (“AMB”) requests the .fin TLD which targets a restricted registrant base (corporations and professionals operating in the finance sector), large end user group and is focused primarily on commercial uses. AMB’s application qualifies for the general purpose category, restricted commercial group.
  3. Sponsor, Registry Operator and Subcontractor.
    a. Sponsor. AMB proposes to form the Financial Internet Domain Association ("FIDA") as the Sponsoring Organization. AMB is a private, non-profit entity, incorporated in the principality of Monaco and has been in existence for over 50 years. The AMB claims to be the only professional and representative organization for bank and finance activities. The AMB's board is currently composed of eight members who are all Chief Executives in their respective banking institutions in Monaco. FIDA will also be organized under the laws of the principality of Monaco and its board will consist of eleven members. For a two-year interim period, these members will be selected by AMB and internationally recognized personalities of the financial world according to specified rules. The stated objective of the Association is "to promote the interests of the international financial community by supporting and regulating the activities of the internet domain ".finance" attributed by ICANN which domain is dedicated to the members of the financial community." AMD states it is not currently in a position to accurately describe the criteria a party must meet in order to register for a .fin TLD.
    b. Registry Operator. SAM Netbay ("Netbay") is a joint venture company. In exchange for an infusion of equity capital, new Netbay shares will be purchased by Eurfanet, certain individuals, and CSL. CSL is a Düsseldorf based Internet service provider founded in 1977. It is one of the CORE founders and has experience in running large database applications. CSL developed the registry software for CORE known as the shared registry system. Eurfanet is a Luxembourg holding company which owns 100% of Internet-fr SA and SAM Namebay ('Namebay"). Internet-fr is a French company founded in 1995 claiming significant expertise in the field of critical web hosting. Namebay is a Monaco based company claiming to specialize in domain name registration. It is also one of the CORE founders and is an ICANN accredited registrar for .com, .net and .org.
    c. Subcontractor. The connectivity providers for the co-locations have not yet been determined and the deposit for the data-escrow programming and testing will be carried out by CSL GmbH. Internet-fr will provide consulting for connectivity and selection of hosting providers.
  4. Registry-Registrar Model.
    Except for certain specified situations, AMB intends that registrants deal only through registrars. In order to become a registrar in the new TLD, AMB plans to require applicants to meet specified criteria, one of which is to be an ICANN accredited registrar.

B. Technical Review
  1. Summary Description of Proposal.
    AMB plans to set up and run a .fin TLD to support the financial industry. Other than particular care with some aspects of security and reliability, they seem to rely on best-existing-practices to run the TLD. They include some minor new services.
  2. Support of the Business Plan by the Technical Plan.
    a. Total Capacity. AMB anticipates around 250,000 registrations in four years, and seem adequately prepared to deal with that load. They use a single registry server, but provide three geographically distributed name servers, and plan to support thousands of registrars.
    b. Projected Growth Rate. AMB anticipates a fairly slow start, with around 50,000 registered names in the first two years. The major acceleration in registrations is suggested for year four. Given their limited set of participants, this seems realistic, and they seem prepared to cope with it.
    c. Startup Period. AMB does not expect a large, quick demand for names in their new domain. Again, their audience is claimed to be sufficiently limited that this expectation is realistic. They seem amply prepared for the startup they expect, and probably somewhat more than that.
    d. Fault Tolerance. AMB has good fault tolerance design throughout. The main registry relies on replicated hardware, and they have reasonable emergency plans based on the availability of a test system for emergency use. Their use of three geographically distributed name servers (each of which can consist of multiple machines, if necessary) provides good fault tolerance for that service. They plan to use sensible backup strategies that should minimize the risk of catastrophic loss. Given the target audience it would seem to be advisable to consider geographically duplicated registry operations.
    e. Security. AMB uses good state-of-the-practice security in many places, offering stronger security than is available today for their intended customers. This security includes use of reasonable cryptographic authentication between registrars and the registry, required acknowledgments of sensitive transactions, and isolation of the registry database machine behind a protected front-end machine. However, given the special security requirements of the financial community, especially if they are all in a single, easily identifiable domain, it would be worthwhile for the applicants to engage a security consulting firm to evaluate all aspects of their proposal and suggest improvements. A stronger auditing and monitoring capability might also be helpful.
  3. Summary of Relevant Experience.
    While AMB seems to have no experience running registries, their subcontractors have substantial experience with running registrars and with developing registry software. They list no relevant experience in fault tolerant computing, but seem familiar with basics of that field.
  4. Apparent Implementation Risks.
    There seem to be relatively few implementation risks. The technical goals are modest and the expertise and resources available seem adequate. The biggest risk is that isolating financial institutions in a single TLD might make that TLD a particularly attractive target for criminals, and thus great care should be taken in the security design of the system handling that domain. Note, however, that today the financial institutions to be served by this TLD use the existing name system, which is less secure than that proposed.
  5. Available of Human, Operational and Technical Resources to Cope with Unexpected Events.
    Relatively little in the proposal discusses handling surprises, except for considerable discussion of handling failures. If, for some reason, this TLD proves extraordinarily popular for registrations, the proposers might be unprepared to handle that popularity. The nature of their audience makes such popularity unlikely, however.
  6. Advancing the State of the Art.
    The technical plan includes minor but worthwhile improvements in security of TLDs.
  7. Other Comments.
    The proposal is limited in scope and well designed for its limited goals.

C. Business Review
  1. Applicant’s Representations.
    AMB supervises 45 banks and 24 financial institutions in Monaco. AMB’s objectives are to promote the interests of the international financial community by supporting and regulating the activities of the Internet domain .finance. The TLD is dedicated to the members of the financial community.

    Netbay is a joint venture between Eurafnet and CSL. Eurafnet is a holding company for Internet-fr and Namebay. Internet-fr offers web hosting and leased lines for IP access predominately in France. Namebay is an accredited registrar and is a member of CORE. CSL is an Internet service provider for companies only. CSL was formed in Germany in 1977, originally providing statistical analysis for market research companies. Database services were added in 1990 and Internet services in 1994.

    The registry operator’s mission is to provide the financial community with a clearly identified distinctive top level domain that will encompass the new fields of finance and represent the old economy financial institutions. Overall, this TLD will be marketed as a source of reputable financial companies. The registrants will have to provide proof of affiliation or certification by a national regulator related to the financial industry.

    The revenue model is a subscription model with a EUR100 price in the first and second years. In the third and fourth year, the price will decline to EUR70 and EUR50, respectively. Registrars will pay an initial fee of EUR5,000 with a renewal fee of EUR2,000. There will also be a 10% quality refund for registrars if no significant problem occurred during the last year of operation. The target market will be financial institutions and are estimated to be at least 1 million by the applicant. By year four, the applicant estimates that the total registrations will be approximately 255,000.
  2. ICANN’s Evaluation.
    The strength of this application lies in its targeted market niche and individuals associated with this venture have experience in this sector. The weaknesses of this application are (1) a weak marketing plan, and (2) weak basis for expected demand. An additional weakness of this application is the lack of representativeness of the group with respect to the international banking system. Overall, from a business plan perspective this application could lead to a successful new TLD given its limited objectives.

D. Summary of Public Comments
  1. Number of Comments.
  2. Support for the Application.
    .fin would be a good TLD alternative since no other financial TLD is proposed.
  3. Opposition to Application.
    A financial TLD should be proposed and run by a worldwide financial organization. One commentator found the projection of 1 million registrants to be “without basis.”

[1]Preferred TLD.