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"But those audits are notoriously superficial"

Will add that just having gone through an ICANN registrar audit (which by the way were specified and supposed to be done literally 10 or 12 years ago but never requested by ICANN) with a third party company hired (accounting firm) it's total compliance theater.

Add: "hired by ICANN after a bidding process". Same happened with data escrow which was just implemented a few years ago and is operated by Iron Mountain.



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