[arin-ppml] ARIN Draft Policy 2014-2 Improving 8.4 Anti-Flip Language

[Bill Darte]

At the Advisory Council's meeting of Feb 20, discussion about Draft Policy
2014-2 concluded that there is a real issue with transfer restrictions of
address blocks between RIR jurisdictions for organizations having received
a different block of addresses from ARIN within the last 12 months (per
existing policy).

The current Draft Policy language is as follows with only the last sentence
being added from what is current ARIN policy:
"Source entities within the ARIN region must not have received a transfer,
allocation, or assignment of IPv4 number resources from ARIN for the 12
months prior to the approval of a transfer request. This restriction does
not include M&A transfers. Restrictions related to recent receipt of blocks
shall not apply to inter-RIR transfers within the same organization and its
subsidiaries."

The last sentence of this language was added to mitigate the problems
related by the author in the problem statement and from experience. The
author supported this change, however, some concern has been expressed on
the PPML and within the AC about the possibility of 'rinse and repeat'
abuse associated with the ease of establishing new subsidiaries and using
those transfers to get around the restrictions of the existing transfer
policy.

Three alternatives were primarily discussed and I wish to elicit feedback
from the community relative to each.

1. Use the existing last sentence as is and ask ARIN staff to be
particularly watchful for seeming abuse and to bring such back to the
community through regular Policy Experience Reports.  There was discussion
about this option suggesting that by the time abuse was recognized and
reported, and given limited existing free pool stocks and the extended
policy development cycle....this option may be moot.

2. Remove the clause 'and its subsidiaries' or modify it in such a way as
to mitigate the risk of a laundering of addresses through fraudulent
transfers, but this may still potentially limit the utility to
organizations who may have complex organizational structures in use
internationally.

3. Take an alternative tack and simply restrict transfers on a per-block
rather than a per-organization basis. e.g. 'No block acquired within the
past 24 months would be eligible for transfer.' (The time frame is of
course an arbitrary number at this point.)

If you believe this Draft Policy is improved most significantly by one of
the above alternatives, or through another alternative you can pose....I,
and the community would benefit from your input. Thanks,

Bill Darte
Policy Shepherd for 2014-2 and
Advisory Council member
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <https://lists.arin.net/pipermail/arin-ppml/attachments/20140221/77d17c87/attachment.htm>