Not sure about that. Phishing scams make sure to hide their identity really well and while something like .com might require your personal information, I can imagine .ru allowing anonymous registration. Once you've got a domain, getting a certificate for it with Let's Encrypt happen in seconds with no personal information iirc. Even if you'd need to disclose something, you could just lie. Let's Encrypt is highly automatized and I doubt anyone would check the information for some random domain. Yeah that cert/domain will be taken down quickly, but they're incredibly cheap and easy to create.
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