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Secondly, It is important to note location of compliance in this structure, under the COO and not under the CEO. Then there is a third problem in this chart being that the COO and the gTLD president are the same person. If this chart is to be taken on its face, compliance reports to the COO who has a dual role of running the domain business which is unaccountable to the CEO. 

3. True Impact of Compliance Activity

While we have seen an increase in general compliance activity in recent years, the effects are marginal. The 24 registrars breached so far in 2015 represent about 0.46% of the domain market. The 5 registrars terminated so far in 2015 represent about 0.0043% of the domain market. One of the registrars only had 4 .COM domains and another only 38. The motivation for enforcement appears to be financial. Registrars with breaches have something in common, they owe fees to ICANN. Combine the two factors (tiny portfolios and debt) and compliance appears to be a bill collector for registrars who are not contributing enough to the pot. While ICANN must watch its bottom line and remove inefficient contracted parties, this seems to be the only trigger for enforcement. 

At-Large Accountability and Transparency Review

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