[arin-ppml] Beneficial Owners

Ronald F. Guilmette rfg at tristatelogic.com
Thu Jul 12 18:44:33 EDT 2018

In message <92CF0190-80CB-42FB-8B20-8CBC4AEDDD20 at pch.net>, 
Bill Woodcock <woody at pch.net> wrote:

>In other words, look at what KYC processes regulators require of their
>regulated entities in other industries, and do the same, before someone
>thinks to require it of us.
>I have neither an argument for or against that yet, need to think about
>it more, but a few points:
>    - Doing that in any _substantial_ way would add expense, since it
>will dissuade some bad actors, but would encourage others to falsify
>documents or otherwise give ARIN staff the run-around.

I would not deny that this new and additional task would increase the
level of vetting necesary to obtain number resources from ARIN, and
that thus, it would represent some additional workload for ARIN, above
and beyond the existing vetting process, such as it is.

That additional expense would however, in my opinion, be compensated for
by both a reduction in the potential for legal liability, for ARIN, and
also by a lessening of the quantity of number resources, in particular,
IPv4 addresses, that ARIN allocates to arguably undeserving out-of-region
entities employing in-region shell companies, thus leaving more of these
resources available for deserving in-region recipients.

>    - It doesn't appease your curiosity, since as I said before,
>the results of KYC documentation wouldn't be made public.

The satisfaction of my personal curiosity is not and should not rightly be
a primary concerm for ARIN.  And indeed, although additional transparency
would be a Good Thing, in my opinion, that must be judged as being entirely
secondary to the vastly more important goal of having ARIN itself (and
perhaps alone) knowing the real identities of its customers and/or the
beneficial owners thereof.

In the current fraught era, I am not at all persuaded that it is still
justifiable, legally, ethically, or otherwise, for ARIN to continue to
take an entirely laissez-faire approach to the identification of its
actual customers.  Awarding swaths of IP addresses to shell companies
controlled by opaque and invisible offshore actors hardly seems like the
most judicious manner in which to administer the address space.

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