[arin-ppml] Beneficial Owners

Bill Woodcock woody at pch.net
Thu Jul 12 02:45:37 EDT 2018

> On Jul 12, 2018, at 3:57 PM, Ronald F. Guilmette <rfg at tristatelogic.com> wrote:
> 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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