On 7 Sep 2021, at 4:39 AM, arin-ppml 
<[email protected]<mailto:[email protected]>> wrote:
...
It is perfectly within ANY RIR’s policy if I distribute addresses to customers 
that are connected to me only via a GRE tunnel or other VPN. The only 
infrastructure required to support this would be a cloud-based VM that wouldn’t 
even need to be on my hardware. With that very thin fig leaf, I’ve met the test 
of connectivity that is required by some RIRs and I’m technically providing 
sufficient transit to meet the qualifications for address space.

Correct, but making the representation that you need to have number resources 
issued to provide VPN services when the actual intent is simply leasing would 
be a fraudulent representation.  In the ARIN region, I can state that resources 
known to be issued fraudulently are revoked.  (If the resources were issued and 
used for providing network services, but then business factors change and 
they’re no longer used for network services and instead now transferred or 
leased then that is not fraud - such usage is either specified allowed or not 
clearly prohibited [respectively] by the community-developed registry policy in 
this region.)

Whether you want this to be normal or not, the simple reality is that it is. 
There is a market for IPv4 address leasing and people will do it one way or 
another. While it can’t be used as justification for acquiring additional 
addresses (unless you throw a fig leaf on it as described above), that really 
doesn’t matter since 80% of RIRs are essentially out of IPv4 anyway.

Throwing “a fig leaf” on it in order to obtain number resources may have other 
repercussions in the ARIN region, as we refer cases of criminal fraud to law 
enforcement authorities.

Regards,
/John

John Curran
President and CEO
American Registry for Internet Numbers




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