Draft Policy ARIN-2017-6: Improve Reciprocity Requirement for Inter-RIR Transfers

[ARIN]

On 15 June 2017, the ARIN Advisory Council (AC) advanced "ARIN-prop-241: 
Improve Reciprocity Requirement for Inter-RIR Transfers" to Draft Policy 
status.

Draft Policy ARIN-2017-6 is below and can be found at:
https://www.arin.net/policy/proposals/2017_6.html

You are encouraged to discuss all Draft Policies on PPML. The AC will 
evaluate the discussion in order to assess the conformance of this draft 
policy with ARIN's Principles of Internet number resource policy as 
stated in the Policy Development Process (PDP). Specifically, these 
principles are:

* Enabling Fair and Impartial Number Resource Administration
* Technically Sound
* Supported by the Community

The PDP can be found at:
https://www.arin.net/policy/pdp.html

Draft Policies and Proposals under discussion can be found at:
https://www.arin.net/policy/proposals/index.html

Regards,

Sean Hopkins
Policy Analyst
American Registry for Internet Numbers (ARIN)



Draft Policy ARIN-2017-6: Improve Reciprocity Requirement for Inter-RIR 
Transfers

Problem Statement:

Currently ARIN's requirement that inter-RIR transfer policies be 
reciprocal has a glaring hole in it in that RIRs which have NIRs and/or 
a two-hop RIR transfer process can be used to circumvent the intent of 
the requirement. Rather than eliminate the requirement, a better 
approach would be to close the loophole.

Policy statement:

Amend section 8.4 (included here for reference):

8.4. Inter-RIR Transfers to Specified Recipients

Inter-regional transfers may take place only via RIRs who agree to the 
transfer and share reciprocal, compatible, needs-based policies.

Conditions on source of the transfer:

The source entity must be the current rights holder of the IPv4 address 
resources recognized by the RIR responsible for the resources, and not 
be involved in any dispute as to the status of those resources.

Source entities outside of the ARIN region must meet any requirements 
defined by the RIR where the source entity holds the registration.

Source entities within the ARIN region must not have received a 
transfer, allocation, or assignment of IPv4 number resources from ARIN 
for the 12 months prior to the approval of a transfer request, unless 
either the source or recipient entity owns or controls the other, or 
both are under common ownership or control. This restriction does not 
include M&A transfers.

Address resources from a reserved pool (including those designated in 
Section 4.4 and 4.10) are not eligible for transfer.

Conditions on recipient of the transfer:

The conditions on a recipient outside of the ARIN region will be defined 
by the policies of the receiving RIR.

Recipients within the ARIN region must meet the transfer requirements as 
defined in section 8.5.

Recipients within the ARIN region will be subject to current ARIN policies.

Make the following change:

Add an additional bullet to "Conditions on recipient" which states:

+ Recipient RIR policy must not permit transfers to other RIRs or NIRs 
whose policies do not support bi-directional transfers.

Comments:

a. Timetable for implementation: Immediate