[arin-ppml] Beneficial Owners
devonrb at gmail.com
Thu Jul 12 18:22:58 EDT 2018
I am making my first contribution to this list, but I have been following
some of these threads. I think this is a very important question that is
raised. The fact that all these bad actors are using the internet as the
vehicle to establish structures to conceal their nefarious activities, I
think will eventually impact the functions of ARIN, whether from a legal
perspective, an ethical or even moral perspective. We should develop this
On Thu, Jul 12, 2018 at 11:00 AM <arin-ppml-request at arin.net> wrote:
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> Today's Topics:
> 1. Beneficial Owners (Ronald F. Guilmette)
> 2. Re: Beneficial Owners (Bill Woodcock)
> Message: 1
> Date: Wed, 11 Jul 2018 22:57:44 -0700
> From: "Ronald F. Guilmette" <rfg at tristatelogic.com>
> To: arin-ppml at arin.net
> Subject: [arin-ppml] Beneficial Owners
> Message-ID: <50316.1531375064 at segfault.tristatelogic.com>
> I have what I think is a rather simple question. Not a policy proposal.
> Just a simple question for now, but I suspect that most or all of you
> will be easily able to infer where I am going with this.
> I watched a really rather interesting YouTube video recently:
> If you've ever taken any interest in the Panama Papers I, The Paradise
> Papers, The Panama Papers II, or if you've even ever been concerned
> about the activities of, say, the likes of Abu Bakr al-Baghdadi or
> Vladimir Putin, then I do recommend that you watch the video, which
> is rather eye opening.
> The video, and another small piece of information that came to me recently,
> have together made me deeply curious to know whether or not ARIN, as part
> of its day-to-day normal operations, requires the production of any
> specific documentation of, or information about the beneficial owners of
> corporate/LLC legal entities to which it assigns number resources.
> Does it? And if so, how may these records be accessed?
> Certainly I've never seen any such information within any WHOIS record.
> All I see there is corporate names, nominal snail-mailing addresses, and
> nominal phone numbers. I know from experience that the addresses and phone
> numbers present in ARIN WHOIS records are, on many occasions, connected
> only to lawyers, incorporation agents, or opaque UPS mailboxes, and
> this isn't the kind of information that interests me.
> If ARIN routinely collects documentation of the beneficial owners of the
> entities to which it assigns number resources, then I, for one, sure would
> like to know how to access that.
> On the other hand, if it doesn't...
> Well, we'll set that aside for the moment, and I'll just wait and hope for
> an answer to my basic question.
> I guess that another way of stating the question is: Is it trivially
> possible for persons or entities within, say, Russia, China, Iran, or
> North Korea to obtain a U.S. shell company and then proceed to leverage
> that in order to obtain number resources from ARIN?
> Message: 2
> Date: Thu, 12 Jul 2018 16:45:37 +1000
> From: Bill Woodcock <woody at pch.net>
> To: arin-ppml at arin.net
> Subject: Re: [arin-ppml] Beneficial Owners
> Message-ID: <E8F719E6-0EDC-42FC-A1D1-34FAA57BA20B at pch.net>
> Content-Type: text/plain; charset="utf-8"
> > On Jul 12, 2018, at 3:57 PM, Ronald F. Guilmette <rfg at tristatelogic.com>
> > I am deeply curious to know whether or not ARIN, as part
> > of its day-to-day normal operations, requires the production of any
> > specific documentation of, or information about the beneficial owners of
> > corporate/LLC legal entities to which it assigns number resources.
> So, speaking generically, this is called ?Know Your Customer? or KYC
> regulation, and is common in banking and other financial services
> industries, mostly in an attempt to regulate money laundering.
> > Does it?
> To my observation, ARIN does more than most organizations, but less than
> organizations that are actually mandated to perform KYC checks by
> regulatory agencies. ARIN does not, for instance, visit the premises of
> its customers to meet and positively identify their executives, which is a
> process I have to go through with respect to some banks, for instance. I
> will note that that?s not a cheap process for banks to implement, and the
> thing at stake there is money, rather than IP addresses.
> > And if so, how may these records be accessed?
> That may be going in a different direction, which may not be a reasonable
> one? banks that follow KYC processes to identify their customers are
> responsible to banking regulators if they?re audited, they don?t publish
> the information to the public.
> > Certainly I've never seen any such information within any WHOIS record.
> So if you want to unmask the owners of corporations, I think you have a
> lot of hurdles to get over? I don?t think you can use ARIN as a magical
> shortcut to financial transparency.
> > Is it trivially
> > possible for persons or entities within, say, Russia, China, Iran, or
> > North Korea to obtain a U.S. shell company and then proceed to leverage
> > that in order to obtain number resources from ARIN?
> I suppose that depends on your opinion of what constitutes triviality.
> There are two steps there: establish a US corporation (which is very easy,
> compared with other countries) and apply for ARIN resources (and you
> already know how difficult, or easy, that is).
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