In message <[email protected]>, John Curran <[email protected]> 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 >appropriate. 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. Regards, rfg _______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List ([email protected]). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact [email protected] if you experience any issues.
