They would not have to "sell" the space, but simply sell the company,
whose assets include nothing but the space. In the case of LLC's, a
common manager for multiple LLC's with space might be driving the train,
and no "sale" occurs, but the common manager still manages to control
multiple /22's anyway if ARIN does not watch out for common managers.
Anyone today starting a new business that does NOT use IPv6 space along
with their IPv4 space is not doing things right. As long as they took
their assignment of both, and put both on the net, I think ARIN would be
hard pressed to claim they are not using it for proper purpose.
Does ARIN actually check the assignments that it makes for use. How about
corporations controled by others to get around the limits. As things get
more scarce in the IPv4 world, I suspect problems will get greater.
Albert Erdmann
Network Administrator
Paradise On Line Inc.
On Fri, 13 Jul 2018, Mike Burns wrote:
Dear Albert,
You can't sell transition space per the 8.3 and 8.4 transfer policies.
You could merge them with an 8.2 or series of 8.2 transfers.
What ARIN needs to be sure is that those who ask for 4.10 and 4.4 are
actually utilizing the addresses for that purpose. That's it.
ARIN was smart in my opinion to avoid creating a pool just for new
registrants, as other registries have done to their chagrin, as just what
you mention below happens. Especially in RIPE, new LIRs are spun up to
receive the /22 available to them, draining that reserve pool more quickly
than it should, and rewarding the gaming of policy.
Regards,
Mike
-----Original Message-----
From: ARIN-PPML [mailto:arin-ppml-boun...@arin.net] On Behalf Of
hostmas...@uneedus.com
Sent: Thursday, July 12, 2018 8:50 PM
To: ARIN-PPML List <arin-ppml@arin.net>
Subject: Re: [arin-ppml] Beneficial Owners
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 <69e64f3c-c9f7-4636-9350-c74de11a0...@arin.net>,
John Curran <jcur...@arin.net> 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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