[arin-ppml] Beneficial Owners

[Mike Burns]

Dear Albert,

You can't sell transition space per the 8.3 and 8.4 transfer policies.
You could merge them with an 8.2 or series of 8.2 transfers.
What ARIN needs to be sure is that those who ask for 4.10 and 4.4 are
actually utilizing the addresses for that purpose. That's it.

ARIN was smart in my opinion to avoid creating a pool just for new
registrants, as other registries have done to their chagrin, as just what
you mention below happens. Especially in RIPE, new LIRs are spun up to
receive the /22 available to them, draining that reserve pool more quickly
than it should, and rewarding the gaming of policy.

Regards,
Mike


-----Original Message-----
From: ARIN-PPML [mailto:arin-ppml-bounces at arin.net] On Behalf Of
hostmaster at uneedus.com
Sent: Thursday, July 12, 2018 8:50 PM
To: ARIN-PPML List <arin-ppml at arin.net>
Subject: Re: [arin-ppml] Beneficial Owners

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
> _______________________________________________
> ARIN-PPML
> You are receiving this message because you are subscribed to the ARIN 
> Public Policy Mailing List (ARIN-PPML at arin.net).
> Unsubscribe or manage your mailing list subscription at:
> https://lists.arin.net/mailman/listinfo/arin-ppml
> Please contact info at arin.net if you experience any issues.
>
_______________________________________________
ARIN-PPML
You are receiving this message because you are subscribed to the ARIN Public
Policy Mailing List (ARIN-PPML at arin.net).
Unsubscribe or manage your mailing list subscription at:
https://lists.arin.net/mailman/listinfo/arin-ppml
Please contact info at arin.net if you experience any issues.