[arin-ppml] Beneficial Owners

Ronald F. Guilmette rfg at tristatelogic.com
Thu Jul 12 15:43:32 EDT 2018

In message <E8F719E6-0EDC-42FC-A1D1-34FAA57BA20B at pch.net>, 
Bill Woodcock <woody at pch.net> wrote:

>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.

Thanks for the response, but to be clear, what I was asking about
was not on-site visits, but documentation, e.g. copies of government
issued identification documents for beneficial owners, as was mentioned
in the video.

I definitely don't think that on-site visits are something that ARIN
should be doing... too expensive and too time-consuming.  And there's
no requirement or reccomendation that incorporation agents do KYC to
that level either.  (That would be total overkill in either case.)

I'm really just (still) seeking an answer to the question I posed:

>> 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).

So, just to put this in more concrete terms, nobody here on this list
would be particularly shocked or surprised to learn that, in 2014, at
the very height of the former Iran sanctions regime, a Delaware LLC,
formed by an Iranian national, might have approached ARIN, requesting
some IPv4 space, which ARIN then duitfully supplied in the the form
of a /19 a /20, and a /24, correct?

And if the answer to that question is "Yes, that would not be particularly
surprising", then this would cause me to wonder further how, or if, the
ARIN legal department is able to insure ARIN's conformance to the
strictures of various international sanction regimes, both past and present,
in the absense of any effort to require documentation of the identities
of beneficial owners of entities to which ARIN allocates number resources.

I understand that some on this list, and elsewhere, may view these questions
as being rather silly and/or academic, but I personally would disagree
with that view, based in no small part on the now generally accepted
view that various bad actors outside the United States invested considerable
time and effort to covertly influence the 2016 U.S. election.

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