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Contractual Compliance Conflict Risk Mitigation

When evaluating the compliance audit services providers, ICANN identified that most of the main Audit firms are new gTLD Applicants and also have relationships with many of the ICANN contracted registrars and registries. Therefore ICANN Contractual Compliance requested the providers to include in their proposal how they would address and mitigateany conflicts identified. The approach agreed withKPMG's is as follows:

  1. ICANN mandated that the audit service provider's team members selected for the audit program (auditors) cannot have current or past involvement with the new gTLD Program.
  2. - KPMG's Core Team is from their Contract Compliance Services group with supporting IT resources, none of who are or have been involved inthe new gTLD program.

  3. The audit services provider must have a robust mechanism to identify any relationships they have with any Registrars or Registries selected for audit:

    - KPMG leverages an internal application to identify any audit/tax or advisory relationships they may have with the Registrars/Registries selected. Where any relationships are identified, the type of relationship is communicated, in writing, to ICANN (Note this is limited to simply the type of relationship ie not the detailed services as this is confidential). ICANN will then discuss with KPMG to address any significant conflict risks involved and a mitigation plan will be designed to reduce any identified risk (for example excluding that individual from the audit of the specific registrar/registry). If nosatisfactory mitigation solution can be implemented, ICANN will perform the audit of the relevant Registrar/Registry. Note: at no time will KPMG directly contact any of the contracting parties, as ICANN is managing the Audit Program directly; KPMG is simply supporting validation of the documentation.

The items above are just two examples ICANN has taken to manage and mitigateany conflicts of interest, as well as utilizing a robust ethical wall to protect the integrity of the program. We are confident that the steps above help all contracted parties gain comfort in our highly secured and developed risk mitigation efforts involving KPMG. If you have any additional questions please direct them to

Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as"""" is not an IDN."