[arin-ppml] Beneficial Owners

[Ronald F. Guilmette]

In message <187ccde1a89e4dd6af324108ff6c7417 at DG2MBX04-DOR.bell.corp.bce.ca>, 
"Roberts, Orin" <oroberts at bell.ca> wrote:

>I am assuming Ronald is aware of this.

Yes, I am aware of the extent of the ARIN region and the list of
coutries it includes is quite easy to find.  But thank you.

Anyway, while we are on the subject, let me just say that it is
in fact this "regionality" issue that was uppermost in my mind
when I started this thread.

There are, in my opinion, plenty of good reasons that ARIN should
be collecting and saving information on beneficial owners, not the
least of which is to assist law enforcement when and if that need
should arise, as well as insuring conformance to various international
sanction regimes.

But for me at least, at this moment, these things represent secondary
benefits and secondary considerations.

The primary thing that caused me to initiate this thread was the
realization, based on some recent research, that certain out-of-
region individuals, hiding behind both in-region and out-out-region
shell companies, had somehow managed to obtain ARIN-issued IPv4
address blocks, and were doing things with those blocks that I
personally consider rather entirely untowards, perhaps illegal,
and maybe even in violation of ARIN usage policies and/or contractual
commitments.

To be slightly more specific, I found that a Delaware LLC which
has ben issued an entire /19 by ARIN (in 2014) is in fact owned
and controled by a gentleman in Iran.  In addition to wondering
why ARIN is handing out "scarce" limited resources to clearly
out-of-region Iranians, I did and do wonder if this issuance was
entirely consistant with the  U.S./Iran sanctions that were in
place at the time.

More recently, anmd within the past 24 hours, I came upon what may
arguably be an even more curious case, this being the case of
a gentleman whose own Facebook page indicates that he is, at
present, a resident of Karachi, Pakistan.  This gentleman apparently
owns and runs a non-shell company, i.e. one that is actually being
used to conduct real business, but that company is incorporated
in the opaque jurisdiction of U.A.E., well known for its distinctive
corporate secrecy laws.  (Neither U.A.E. nor Pakistan atre in the
ARIN region, last time I checked.)

Every attwempt I have made so far indicates that this gentleman
has never incorporated any of his relevant business entities
anywhere in the Americas.  He does apparently make use of a P.O.
drop box in the State of Texas, but his company is not registered
in that state, nor in any other U.S. state, as far as I have been
able to determine.

Despite all this, ARIN saw fit to grant him an entire /17.

As I've said, in both of these cases, the IP space that ARIN has
granted to the companies of these two out-of-region gentlemen
have been used and/or are being used for purposes that are, in
my opinion, at best questionable.

I am, as many, most, or all of you already know, opposed to quite
a lot of different types of hanky panky on the Internet, especially
in cases where it significantly and negatively affects the use and
enjoyment of the Internet by others.  I actively oppose bad behavior
on the Internet without regard to which region or regions it arises
from, and it angers me whenever and whereever I see it.  But it seems
to me that it is adding insult to injury when out-of-region bad actors
somehow manage to finnagle their way into obtaining sizable swaths
of in-region resources, and then proceed to use those for less than
honorable purposes.

So, you know, if you want to boil it all down, I am frankly more than
a little miffed to see ARIN giving out "scarce" number resources to
out-of-region beneficial owners who are merely hiding behind shell
companies, but particularly when those out-of-region folks then turn
around and use those resources to commit network abuse, and perhaps even
violations of their ARIN contractual commitments, e.g. by filling
up large IPv4 CIDRs with just one single IP-hungry snowshoe spamming
operation.

So, my hope is a simple one:  That ARIN should henceforth save its
remaining precious and limited IPv4 resources and give those out to
deserving parties which LEGITIMATELY RESIDE WITHIN THE ARIN REGION,
and that it should not be quite so easily duped via the use of
shell companies on the part of out-of-region parties, be they "bad
actors" or otherwise.

I mean if there are loopholes big enough to drive a truck through,
e.g. with respect to the awarding of "scarce" IPv4 blocks, then
perhaps it is time to just dispense entirely with this fiction of
RIR regions and merge all five of the existing RIR into a single
world-wide number resource agency.

It seems to me that we should either do that or else ARIN should
stop giving out resources earmarked for this region to what are
clearly out-of-region players.  I mean don't they have their own
region, and shouldn't they be getting their resources from there?

I'm sorry if anyone is offended by either my views or my manner of
expressing them, but it hurts me to see Iranians and Pakistanis being
awarded scarce ARIN IPv4 address blocks while deserving institutions
and small businesses right here in North America go hungry for want
of those same resources.


Regards,
rfg