Legal advice was obtained after GLBSE closed. Prior to that, assets were held by VPS. Any business conducted after that point would have to be subject to the proposed rules and personal information requests. I would expect this to include dividends generated during the interim, but for assets being held before then, such a retroactively applied stipulation becomes a bait-and-switch scenario.
All payments while GLBSE was open were made. Like clockwork. GLBSE closing is the only reason I was unable to make payments. So, I am doing EXACTLY what you stated above.
That's what's being done now, yes. If we discard dividend payments to separate the assets before and after, there should be a clear delineation of what is subject to the updated legal guidance.
Let's say I had 10 shares prior to GLBSE closing. After the event, dividends accrue. The dividends that have accumulated since would unquestionably require personal information to release. Without that information, any payments since would be forfeit.
As for the initial investment to acquire 10 shares, that's where the bait-and-switch comes in because now new rules are being applied. A partial return of pre-GLBSE failure funds would be better than freezing them.
Since the concern seems to be about liabilities regarding sanctioned nations, would it be possible to log the IP and browser information that a request is made from to show it isn't being made from one of those locations? What are the legal ramifications of accepting funds from such locations in the first place?