On 12 Jul 2018, at 6:44 PM, Ronald F. Guilmette <r...@tristatelogic.com> wrote:
> ...
> 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.

Ron - 

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 appropriate. 

Thanks,
/John

John Curran
President and CEO
ARIN

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