[arin-ppml] Beneficial Owners

Ronald F. Guilmette rfg at tristatelogic.com
Thu Jul 12 20:18:27 EDT 2018

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

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.


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