<div dir="ltr">my understanding from this thread so far is that<div>1. Companies have easier options if they are seeking to be nefarious they can purchase and register through RIPE.</div><div>2. Any arbitrary or hasty change in present policies, could seriously and negatively affect the fortunes of bona fide corporations, LLC and Individual Investors.</div><div>3. There is already a mechanism within ARIN that can refer supicious activities to the appropriate monitoring body.</div><div>4. There are built in limitations (safeguards?) within the various IPv pools that could conceivably be vulnerable.</div><div>5. There is a legal risk that would have to be evaluated if any changes to policy are to be contemplated.</div><div>6 There is an expense burden unquantified at the moment that would have to be balanced against the status quo.</div><div>7 .One vulnerable area for nefarious speculators would be the block for IPv6 expansion, we need to keep a close eye out for this possibility.</div><div><br></div><div>This suggests that we should probably take some time to investigate some more, without commiting to changes that might not be necessary. I feel sure the expertise is within this list to identify any weakneses or challenges that may pose a future threat to the integrity of ARIN.</div><div>Devon</div><div><br></div><br><div class="gmail_quote"><div dir="ltr">On Fri, Jul 13, 2018 at 12:26 PM <<a href="mailto:arin-ppml-request@arin.net">arin-ppml-request@arin.net</a>> wrote:<br></div><blockquote class="gmail_quote" style="margin:0 0 0 .8ex;border-left:1px #ccc solid;padding-left:1ex">Send ARIN-PPML mailing list submissions to<br>
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Today's Topics:<br>
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1. Re: Beneficial Owners (Peter Harrison)<br>
<br>
<br>
----------------------------------------------------------------------<br>
<br>
Message: 1<br>
Date: Fri, 13 Jul 2018 10:24:57 -0700<br>
From: Peter Harrison <<a href="mailto:peter@colovore.com" target="_blank">peter@colovore.com</a>><br>
To: ARIN-PPML List <<a href="mailto:arin-ppml@arin.net" target="_blank">arin-ppml@arin.net</a>><br>
Subject: Re: [arin-ppml] Beneficial Owners<br>
Message-ID:<br>
<CAN61F1zrfddm=<a href="mailto:vspGXnFDuthUbxvvLbsn_pOEqHZAOwxaSFDgw@mail.gmail.com" target="_blank">vspGXnFDuthUbxvvLbsn_pOEqHZAOwxaSFDgw@mail.gmail.com</a>><br>
Content-Type: text/plain; charset="utf-8"<br>
<br>
There is certainly opportunity for abuse of the current system, but<br>
consider the case for companies not wanting to disclose "beneficial owners"<br>
for good cause.<br>
<br>
Startup companies may not want to reveal their investors who could be<br>
taking a bet on new Internet technologies and services to get a head start<br>
on their competitors.<br>
<br>
Legitimate companies may create shell companies for the same purpose in<br>
cases where internal teams are doing the R&D on new products and services<br>
yet to be announced. Using an IP block allocated to a parent would be a<br>
dead giveaway.<br>
<br>
Similarly investors in small companies, such as individuals or families,<br>
who don?t want to draw attention to their wealth for personal security<br>
reasons may not want this disclosure. There is heightened awareness of this<br>
in some ARIN member countries and territories.<br>
<br>
Private investors also often invest in competing or related firms to hedge<br>
on ideas that prevail. Disclosures could be challenging here too.<br>
<br>
These are very real economic consequences. It is more than just a<br>
bureaucratic tax for members to bear. There are other issues to review<br>
within the ARIN region when considering the extra-regional implications.<br>
<br>
It's not my area of specialty, but I'd think that international corporate<br>
law forensics and financial transparency are governed by the policies (like<br>
OFAC) of member states? and territories? governments and their agencies.<br>
ARIN seems to respect these and rightfully errs on the side of caution when<br>
in doubt. Then there is the question of addressing how each jurisdiction<br>
defines "beneficial owners".<br>
<br>
It is a genuine concern, but the case to preemptively expand the mandate to<br>
disclose "beneficial owners" could be counterproductive to the membership.<br>
<br>
<br>
<br>
Peter<br>
<br>
On Fri, Jul 13, 2018 at 8:42 AM, Mike Burns <<a href="mailto:mike@iptrading.com" target="_blank">mike@iptrading.com</a>> wrote:<br>
<br>
> HI Albert,<br>
><br>
> I am not clearly understanding the issues you are raising.<br>
><br>
> If it is an issue of spinning up LLCs to loot the 4.10 and 4.4 pools,<br>
> because you believe people will acquire those addresses by falsely claiming<br>
> they will be utilized for transition, then that is a simple matter for ARIN<br>
> to determine at the point of allocation. If you are worried that people<br>
> will fake that to get the addresses and then use them for purposes other<br>
> than transition, it's not a big deal. 4.10 in particular is limited to a<br>
> /24<br>
> and 4.4 requires demonstration that the recipient is an exchange point.<br>
><br>
> If it is an issue of foreigners acquiring ARIN space who might be covered<br>
> under some sanctions regime, John Curran has mentioned they check the OFAC<br>
> list and wouldn't engage with an entity under sanctions. Remember there is<br>
> a far simpler work-around for those people. Buy RIPE addresses and register<br>
> them in RIPE.<br>
><br>
> As far as your contention that businesses require both IPv4 and IPv6,<br>
> that's<br>
> belied by my experience. Many new ARIN members are signing up just to<br>
> receive IPv4 transfers. In many cases these are enterprises who would<br>
> normally have received IPv4 from their upstreams, who can no longer provide<br>
> them. So they create an ARIN ORG-ID and receive IPv4 via transfer.<br>
><br>
> IPv4 may be getting a little scarcer, but surely that would be reflected in<br>
> the price. And while prices are rising, they are doing so at a pretty<br>
> regular rate which does not indicate severe supply issues. I will say<br>
> there<br>
> are supply issues at the large block sizes, but I don't think those buyers<br>
> are likely to engage in the shenanigans you fear, as they are large<br>
> corporations by default, willing to pay close to $20 million for a /12.<br>
><br>
> What do you mean by "corporations controlled by others to get around the<br>
> limits." What limits? The limit on address space used in the ARIN region?<br>
> That is not much of a functional limit, as buyers can utilize RIPE space<br>
> anywhere, and not even have to justify their need in the purchase. Plus<br>
> they<br>
> only need to use a /22 here anyway.<br>
><br>
> If "nefarious" corporations want to get around limits, they just open a<br>
> RIPE<br>
> account and buy whatever they want, and use their addresses wherever they<br>
> want. Why would they bother with ARIN when RIPE offers a free /22 to every<br>
> new LIR, no questions asked?<br>
><br>
> As far as your belief that ARIN failing to poke more deeply into its<br>
> member's businesses would create more legal risk, I think the poking around<br>
> would create more risk, as it would motivate those denied by ARIN due to<br>
> the<br>
> increased scrutiny to use legal recourse against ARIN's more nuanced<br>
> decisions. At the very least it would add to ARIN's expenses, and as a<br>
> paying member I would like to understand what risks and downsides you find<br>
> in current policy/procedures that would be worth the additional expense?<br>
><br>
> Regards,<br>
> Mike<br>
><br>
><br>
><br>
><br>
><br>
> -----Original Message-----<br>
> From: ARIN-PPML [mailto:<a href="mailto:arin-ppml-bounces@arin.net" target="_blank">arin-ppml-bounces@arin.net</a>] On Behalf Of<br>
> <a href="mailto:hostmaster@uneedus.com" target="_blank">hostmaster@uneedus.com</a><br>
> Sent: Friday, July 13, 2018 11:01 AM<br>
> To: 'ARIN-PPML List' <<a href="mailto:arin-ppml@arin.net" target="_blank">arin-ppml@arin.net</a>><br>
> Subject: Re: [arin-ppml] Beneficial Owners<br>
><br>
> They would not have to "sell" the space, but simply sell the company, whose<br>
> assets include nothing but the space. In the case of LLC's, a common<br>
> manager for multiple LLC's with space might be driving the train, and no<br>
> "sale" occurs, but the common manager still manages to control multiple<br>
> /22's anyway if ARIN does not watch out for common managers.<br>
><br>
> Anyone today starting a new business that does NOT use IPv6 space along<br>
> with<br>
> their IPv4 space is not doing things right. As long as they took their<br>
> assignment of both, and put both on the net, I think ARIN would be hard<br>
> pressed to claim they are not using it for proper purpose.<br>
><br>
> Does ARIN actually check the assignments that it makes for use. How about<br>
> corporations controled by others to get around the limits. As things get<br>
> more scarce in the IPv4 world, I suspect problems will get greater.<br>
><br>
> Albert Erdmann<br>
> Network Administrator<br>
> Paradise On Line Inc.<br>
><br>
> On Fri, 13 Jul 2018, Mike Burns wrote:<br>
><br>
> > Dear Albert,<br>
> ><br>
> > You can't sell transition space per the 8.3 and 8.4 transfer policies.<br>
> > You could merge them with an 8.2 or series of 8.2 transfers.<br>
> > What ARIN needs to be sure is that those who ask for 4.10 and 4.4 are<br>
> > actually utilizing the addresses for that purpose. That's it.<br>
> ><br>
> > ARIN was smart in my opinion to avoid creating a pool just for new<br>
> > registrants, as other registries have done to their chagrin, as just<br>
> > what you mention below happens. Especially in RIPE, new LIRs are spun<br>
> > up to receive the /22 available to them, draining that reserve pool<br>
> > more quickly than it should, and rewarding the gaming of policy.<br>
> ><br>
> > Regards,<br>
> > Mike<br>
> ><br>
> ><br>
> > -----Original Message-----<br>
> > From: ARIN-PPML [mailto:<a href="mailto:arin-ppml-bounces@arin.net" target="_blank">arin-ppml-bounces@arin.net</a>] On Behalf Of<br>
> > <a href="mailto:hostmaster@uneedus.com" target="_blank">hostmaster@uneedus.com</a><br>
> > Sent: Thursday, July 12, 2018 8:50 PM<br>
> > To: ARIN-PPML List <<a href="mailto:arin-ppml@arin.net" target="_blank">arin-ppml@arin.net</a>><br>
> > Subject: Re: [arin-ppml] Beneficial Owners<br>
> ><br>
> > While I do not doubt that there might be shell entities that are<br>
> > holding numbering resources for less than honorable purposes, I was<br>
> > actually more worried about people forming special purpose LLCs or<br>
> > Corps in order to hold numbering resources for the purpose of later<br>
> > sale to others. By forming a entity whose only asset is number<br>
> > resources, this would be an easy way to "sell" the numbers obtained<br>
> > without the M&A checks and balances, by simply selling the entire<br>
> > entity to another, or the central controlling entity might simply use all<br>
> the numbers itself.<br>
> ><br>
> > While this might have been done earlier before the IPv4 pot ran out,<br>
> > at that time the value of addresses might not have been high enough at<br>
> > that time to justify the incorporation expenses. Currently the only<br>
> > block of addresses that this idea could be directed at today is the block<br>
> for IPv6 expansion.<br>
> ><br>
> > I suggest that ARIN be watchful of possible activity in this regard.<br>
> > For example, a company that wants more numbers than ARIN policy would<br>
> > allow might go out and form a series of LLC's that they directly<br>
> > manage, each applying for a /22 of IPv6 Transition space. Doing this<br>
> > might be cheaper than going out into the market, and as things get<br>
> > tighter in the IPv4 marketplace, this might become tempting for someone.<br>
> ><br>
> > As for ITAR regulations and the like, while encryption was once<br>
> > considered in this realm, I do not think that ip addresses would be<br>
> > subject to ITAR, so I doubt there is any real risk to ARIN.<br>
> ><br>
> > Albert Erdmann<br>
> > Network Administrator<br>
> > Paradise On Line Inc.<br>
> ><br>
> > On Thu, 12 Jul 2018, Ronald F. Guilmette wrote:<br>
> ><br>
> >><br>
> >> In message <<a href="mailto:69E64F3C-C9F7-4636-9350-C74DE11A0D36@arin.net" target="_blank">69E64F3C-C9F7-4636-9350-C74DE11A0D36@arin.net</a>>,<br>
> >> John Curran <<a href="mailto:jcurran@arin.net" target="_blank">jcurran@arin.net</a>> wrote:<br>
> >><br>
> >>> ARIN actually does quite a bit to insure that we're aware of the<br>
> >>> parties we're dealing with, and that includes verification of the<br>
> >>> legal<br>
> > entities<br>
> >>> involved and their pertinent bona fides. ARIN reviews transactions<br>
> for<br>
> >>> potential conflict with applicable law, and has in the past declined<br>
> >>> to process transactions that are unclear in that regard and referred<br>
> >>> parties to US Treasury/OFAC to obtain appropriate clarity or<br>
> >>> licensing as appropriate.<br>
> >><br>
> >> Thank you John.<br>
> >><br>
> >> I am aware, and was aware, that ARIN does indeed require<br>
> >> documentation of the valid registration of, and legal existance of<br>
> >> non-person legal entities to which it assigns number resources. That<br>
> >> is quite certainly a good thing, and a proper thing, and I think that<br>
> >> ARIN is doing an admirable job of performing that level of vetting.<br>
> >> But I think you must agree that this does not really address the<br>
> >> issue I've<br>
> > raised.<br>
> >><br>
> >> In the case of non-person non-publically-traded legal entities, some<br>
> >> of which may perhaps qualify as what might be called "shell<br>
> >> companies", what documentation, if any, do current ARIN procedures<br>
> >> require with respect to the identities of actual beneficial owners?<br>
> >><br>
> >> If the answer is "none", then you should be neither shy nor in the<br>
> >> least embarassed to say that. As I have been reminded, many times,<br>
> >> by both you and others, ARIN does pretty much all and only what it is<br>
> >> mandated to do by the community, and according to the clear edicts of<br>
> >> the public policy manual. If ARIN is not currently requesting<br>
> >> documentation of the identities of the beneficial owners of shell<br>
> >> companies, then it is because the community has neither requested nor<br>
> >> instructed it to do so, and in that case you are to be commended for<br>
> >> your characteristic restraint, and for your admirable and consistant<br>
> > adherence to the limits of your mandate.<br>
> >><br>
> >><br>
> >> Regards,<br>
> >> rfg<br>
> >> _______________________________________________<br>
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</blockquote></div><br clear="all"><div><br></div>-- <br><div dir="ltr" class="gmail_signature" data-smartmail="gmail_signature"><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div><div dir="ltr"><div>Devon Blake</div><div>ICT and Development Consultant<br>22c Sullivan Ave <br>Kgn 8<br>,Phone: Office 876-649-9704, Mobile, digi 876-483-2632, flow 876-519-6266</div><div>linkedin:<a href="https://www.linkedin.com/in/deblade" target="_blank">https://www.linkedin.com/in/deblade</a></div><div>website:<a href="http://www.myintellicenter.com" target="_blank">www.myintellicenter.com</a><br><br>To be kind, To be helpful, To network<br><b><i>Earthwise ... For Life!</i></b><br><div style="padding:0px;margin-left:0px;margin-top:0px;overflow:hidden;word-wrap:break-word;color:black;font-size:10px;text-align:left;line-height:130%"></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div></div>