While I do not doubt that there might be shell entities that are holding
numbering resources for less than honorable purposes, I was actually more
worried about people forming special purpose LLCs or Corps in order to
hold numbering resources for the purpose of later sale to others. By
forming a entity whose only asset is number resources, this would be an
easy way to "sell" the numbers obtained without the M&A checks and
balances, by simply selling the entire entity to another, or the central
controlling entity might simply use all the numbers itself.
While this might have been done earlier before the IPv4 pot ran out, at
that time the value of addresses might not have been high enough at that
time to justify the incorporation expenses. Currently the only block of
addresses that this idea could be directed at today is the block for IPv6
expansion.
I suggest that ARIN be watchful of possible activity in this regard. For
example, a company that wants more numbers than ARIN policy would allow
might go out and form a series of LLC's that they directly manage, each
applying for a /22 of IPv6 Transition space. Doing this might be cheaper
than going out into the market, and as things get tighter in the IPv4
marketplace, this might become tempting for someone.
As for ITAR regulations and the like, while encryption was once considered
in this realm, I do not think that ip addresses would be subject to ITAR,
so I doubt there is any real risk to ARIN.
Albert Erdmann
Network Administrator
Paradise On Line Inc.
On Thu, 12 Jul 2018, Ronald F. Guilmette wrote:
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
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