Re: [arin-ppml] Beneficial Owners

[Ronald F. Guilmette]

In message <023101d41d0a$3374d440$9a5e7cc0$@iptrading.com>, 
"Mike Burns"  wrote:

>Whereas I am sure you will get firm agreement from everybody in this
>community regarding the abuse of address space, your language leads to
>conflating the concept of ARIN-"awarded" space and purchased space that can
>be registered anywhere in North America, Europe, the Middle East, or Asia. 

I hope not, by which I mean that I hope that I haven't either conflated
the two -or- that I have seemed to be all all against the notion of IP
address block transfers, e.g. via private brokerage arrangement, because
I am very much in favor of a free and open market for IPv4 space for
one simple reason:  My own personal efforts have for many years concentrated 
on the problem of so-called "snowshoe" spamming, where the spammers use
lots of different domain names and lost of different IP addresses to
evade filters.

This approach to spamming is nowadays employed by 100% of all serious
professional spammers, and their are two fuels that have driven the
explosion of snowshoe spamming over the past several years, the first
being cheap domain names... about which nothing can really be done,
I think... and the second is cheap IP addresses.  It is my belief
that to the extent that IP addresses go the highest bidder, they will,
in general, -not- fall into the hands of snowshoe spammers, whose business
model only works when there are tons and tons of IPv4 addresses lying
around that can be had... and burned through... quite cheaply.

>What difference does it make if an Iranian or Pakistani citizen created a
>Delaware corp and purchased ARIN space and kept it registered in ARIN,
>versus transferring it to a RIPE or APNIC account in Iran or Pakistan? 
>
>The addresses can be used nefariously regardless of registry.  ARIN is not
>issuing space out of any free pool, so the sizes (/19, /17, whatever) are
>not really relevant...

You're right, of course.  If I am abused from RIPE space or APNIC space or
AFRINIC space of LACNIC space then the abuse I suffer is neither better
nor worse that if I was abused instead from ARIN space.  So I don't
really have a good response.  Call it a kind of IP xenophobia on my part.
I've just come to have higher expectations with respect to ARIN resources
than those issued by other regions.  And indeed, those higher expectations
-are- fulilled in most instances.  I think John and his crew do a rather
better job of running a tight ship than other RIRs do, and as a result,
over the years there has been rather less funny business relating to ARIN
resources.  And in what may be a perverted sort of way, that's what makes
the situtaions I've alluded to stick out... like the proverbial sore thumbs...
all the more.  Because they are cases of funny business taking place in
relation to ARIN resources, and when I pull back the curtains I see folks
from other regions behind it all.

I have an emotional response in such cases, and arguably that's just stupid,
and I really shouldn't.  But nontheless, sometimes I really do think... in
the heat of battle... that I'd like to build a wall and get RIPE to pay for
it. :-)  I freely admit that this is not a terribly enlightened viewpoint
but nontheless I do not apologize for it.

>And what incentive is there for the creation of an American corporation and
>the receipt of ARIN space, versus purchasing ARIN/RIPE/APNIC space and
>registering it wherever you wish?

Damn good question  I don't know.

I'll stop dancing around in generalities now and talk specifics and maybe
you can tell me why these folks came to ARIN as opposed to some other RIR.

This mail is already long enough, so I'll present the relevant specifics in
a separate list post to follow this one.


Regards,
rfg
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[arin-ppml] Revised - Draft Policy ARIN-2018-4: Clarification on IPv6 Sub-Assignments

[ARIN]

The following has been revised:

* Draft Policy ARIN-2018-4: Clarification on IPv6 Sub-Assignments

Revised text is below and can be found at:
https://www.arin.net/policy/proposals/2018_4.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-2018-4: Clarification on IPv6 Sub-Assignments

Problem Statement:

When the policy was drafted, the concept of assignments/sub-assignments 
did not consider the use of IP addresses in hotspots, or the use of IP 
addresses by guests or employees in Bring Your Own Device (BYOD) and 
many other similar cases.


Additionally, the IETF has recently approved the use of a unique /64 
prefix per interface/host (RFC8273) instead of a unique address. This, 
for example, allows users to connect to a hotspot, receive a /64 such 
that they are "isolated" from other users (for reasons of security, 
regulatory requirements, etc.) and they can also use multiple virtual 
machines on their devices with a unique address for each one (within the 
same /64).


Section 2.5 (Definitions/Allocate and Assign), explicitly prohibits such 
assignments, stating that "Assignments... are not to be sub-assigned to 
other parties".


This proposal clarifies this situation in this regard and better define 
the concept, particularly considering new uses of IPv6 (RFC8273), by 
means of a new paragraph.


Note that the proposal text also incorporates changes made under an 
Editorial Change currently awaiting Board of Trustees review, available 
here: https://www.arin.net/policy/proposals/2017_11.html


Policy Statement:

Actual Text, Section 2.5:

•Assign - To assign means to delegate address space to an ISP or 
end-user, for specific use within the Internet infrastructure they 
operate. Assignments must only be made for specific purposes documented 
by specific organizations and are not to be sub-assigned to other parties.


New Text:

•   Assignment - Address space delegated to an organization directly by 
ARIN for the exclusive use of the recipient organization. A temporary 
assignment of address space provided to third parties shall not be 
considered an assignment.


Comments

Timetable for implementation:

Immediate

Anything else:

Situation in other regions:

This situation, has already been corrected in RIPE, and the policy was 
updated in a similar way, even if right now there is a small discrepancy 
between the policy text that reached consensus and the RIPE NCC Impact 
Analysis. A new policy proposal has been submitted to amend that, and 
the text is the same as presented by this proposal at ARIN. Same text 
has also been submitted to AfriNIC, LACNIC and APNIC.

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Re: [arin-ppml] Beneficial Owners

[Mike Burns]

Ron wrote:
But I certainly do not ask or expect ARIN to take on the "Internet Police"
role with respect to those separate issues.  I can and do however bemoan the
fact that the two blocks in question were issued AT ALL... apparently to two
fundamentally out-of-region players.

I bemoan these awards of valuable IPv4 real estate and for the reasons I've
already stated... reasons which don't clearly implicate any acts of "fraud"
per se, at least not under the laws of the relevant country
(U.S.) or those of the relevant U.S. states in question.

Bottom line?  If goofballs from outside of ARIN's North American and
Caribbean geographical region feel the need to get chunks of IPv4 space and
then preceed to use those to screw up the Internet, then I for one would
greatly prefer it if they were at least forced to obtain their
IPv4 space from either legitimate broker transactions or preferably from
their own Regional Internet Registries.


Hi Ron,

Whereas I am sure you will get firm agreement from everybody in this
community regarding the abuse of address space, your language leads to
conflating the concept of ARIN-"awarded" space and purchased space that can
be registered anywhere in North America, Europe, the Middle East, or Asia. 

What difference does it make if an Iranian or Pakistani citizen created a
Delaware corp and purchased ARIN space and kept it registered in ARIN,
versus transferring it to a RIPE or APNIC account in Iran or Pakistan? 

The addresses can be used nefariously regardless of registry.  ARIN is not
issuing space out of any free pool, so the sizes (/19, /17, whatever) are
not really relevant. (Unless your issue is abuse of 4.4 and 4.10?)

And what incentive is there for the creation of an American corporation and
the receipt of ARIN space, versus purchasing ARIN/RIPE/APNIC space and
registering it wherever you wish?

I am not understanding the core of the problem here. There is no fraud, no
"award", ARIN will not issue to OFAC entities, and everybody has to purchase
their addresses now, can register them where they want, and can use them
where they want. What is the difference to anybody if the nefarious
foreigners keep the registration in ARIN? It's just more dues for us. And in
ARIN the buyer has to justify, and it seems like it would be harder for
nefarious users to do that justification in ARIN than to simply purchase
RIPE addresses and avoid the necessary disclosures.

Regards,
Mike








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Re: [arin-ppml] Beneficial Owners

[Brian Jones]

> On Jul 16, 2018, at 5:36 AM, Ronald F. Guilmette  
> wrote:
> 
> Bottom line?  If goofballs from outside of ARIN's North American and
> Caribbean geographical region feel the need to get chunks of IPv4 space
> and then preceed to use those to screw up the Internet, then I for one
> would greatly prefer it if they were at least forced to obtain their
> IPv4 space from either legitimate broker transactions or preferably
> from their own Regional Internet Registries.

A huge +1.

--
Brian E Jones


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Re: [arin-ppml] Beneficial Owners

[Ronald F. Guilmette]

In message <7fa40add-2dc1-4e04-bb68-2e7e5920c...@arin.net>, 
John Curran  wrote:

>ARIN has significantly tightened our review of requester's location
>(particularly with regard to potential OFAC concerns) over the last two
>years, as it came to our attention that parties were getting more creative
>in this regard.

That's music to my ears John!  And that statement alone goes a long way
towards allaying my concerns.

>If you feel that ARIN has issued resources based on fraudulent information,
>please report it  and we will
>investigate.

Thanks, but I perhaps have not been clear.  Let me try again.

To the best of my knowledge it is not an inherently "fradulent" act
for a person or other legal entity resident outside of the ARIN region
to create a Delaware, Nevada, or Wyoming corporation or LLC, perhaps
even with so-called "nominee" officers/directors.

Likewise and similarly, to the best of my knowledge it is not an inherently
"fradulent" act for any such corporation or LLC to then request number
resources from ARIN.

In short, I have no "fraud" per se to report.

Nontheless, as I have already expressed, I cannot help being dismayed
by my recently obtained knowledge that a certain Iranian gentleman,
by way of a Delaware, Nevada, or Wyoming corp/LLC, obtained an ARIN-
issued /19 or by my also recently obtained knowledge that a certain
Pakistani gentleman having -no- apparent legally constituted business
within the ARIN region, nontheless somehow obtained an entire ARIN-
issued /17.

The fact that the two blocks in question were subsequently used for
what I personally feel are less than honorable purposes is only what
happeened to bring these blocks to my attention.  But I certainly do
not ask or expect ARIN to take on the "Internet Police" role with
respect to those separate issues.  I can and do however bemoan the
fact that the two blocks in question were issued AT ALL... apparently
to two fundamentally out-of-region players.

I bemoan these awards of valuable IPv4 real estate and for the reasons
I've already stated... reasons which don't clearly implicate any acts
of "fraud" per se, at least not under the laws of the relevant country
(U.S.) or those of the relevant U.S. states in question.

Bottom line?  If goofballs from outside of ARIN's North American and
Caribbean geographical region feel the need to get chunks of IPv4 space
and then preceed to use those to screw up the Internet, then I for one
would greatly prefer it if they were at least forced to obtain their
IPv4 space from either legitimate broker transactions or preferably
from their own Regional Internet Registries.
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