[arin-ppml] Beneficial Owners

[hostmaster at uneedus.com]

While I do not doubt that there might be shell entities that are holding 
numbering resources for less than honorable purposes, I was actually more 
worried about people forming special purpose LLCs or Corps in order to 
hold numbering resources for the purpose of later sale to others.  By 
forming a entity whose only asset is number resources, this would be an 
easy way to "sell" the numbers obtained without the M&A checks and 
balances, by simply selling the entire entity to another, or the central 
controlling entity might simply use all the numbers itself.

While this might have been done earlier before the IPv4 pot ran out, at 
that time the value of addresses might not have been high enough at that 
time to justify the incorporation expenses.  Currently the only block of 
addresses that this idea could be directed at today is the block for IPv6 
expansion.

I suggest that ARIN be watchful of possible activity in this regard.  For 
example, a company that wants more numbers than ARIN policy would allow 
might go out and form a series of LLC's that they directly manage, each 
applying for a /22 of IPv6 Transition space.  Doing this might be cheaper 
than going out into the market, and as things get tighter in the IPv4 
marketplace, this might become tempting for someone.

As for ITAR regulations and the like, while encryption was once considered 
in this realm, I do not think that ip addresses would be subject to ITAR, 
so I doubt there is any real risk to ARIN.

Albert Erdmann
Network Administrator
Paradise On Line Inc.

On Thu, 12 Jul 2018, Ronald F. Guilmette wrote:

>
> In message <69E64F3C-C9F7-4636-9350-C74DE11A0D36 at arin.net>,
> John Curran <jcurran at arin.net> wrote:
>
>> ARIN actually does quite a bit to insure that we're aware of the parties
>> we're dealing with, and that includes verification of the legal entities
>> involved and their pertinent bona fides.   ARIN reviews transactions for
>> potential conflict with applicable law, and has in the past declined to
>> process transactions that are unclear in that regard and referred parties
>> to US Treasury/OFAC to obtain appropriate clarity or licensing as
>> appropriate.
>
> Thank you John.
>
> I am aware, and was aware, that ARIN does indeed require documentation
> of the valid registration of, and legal existance of non-person legal
> entities to which it assigns number resources.  That is quite certainly
> a good thing, and a proper thing, and I think that ARIN is doing an
> admirable job of performing that level of vetting.  But I think you
> must agree that this does not really address the issue I've raised.
>
> In the case of non-person non-publically-traded legal entities, some
> of which may perhaps qualify as what might be called "shell companies",
> what documentation, if any, do current ARIN procedures require with
> respect to the identities of actual beneficial owners?
>
> If the answer is "none", then you should be neither shy nor in the least
> embarassed to say that.  As I have been reminded, many times, by both
> you and others, ARIN does pretty much all and only what it is mandated
> to do by the community, and according to the clear edicts of the public
> policy manual.  If ARIN is not currently requesting documentation of the
> identities of the beneficial owners of shell companies, then it is because
> the community has neither requested nor instructed it to do so, and in
> that case you are to be commended for your characteristic restraint, and
> for your admirable and consistant adherence to the limits of your mandate.
>
>
> Regards,
> rfg
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