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In a relentless pursuit of combatting illegal robocalls and fraudulent activities, the Federal Communications Commission (FCC) has issued firm reminders to seven gateway providers identified as potential accomplices in transmitting illegal traffic on behalf of overseas providers, posing a significant threat to the integrity and security of U.S. phone networks.
These warnings, issued on November 27, 2023, come as the result of the providers' implication in a substantial number of traceback requests received from USTelecom’s Industry Traceback Group (ITG). Shedding light on apparently illegal traffic facilitated by these gateways for overseas partners, these requests have thrust the providers into the unforgiving spotlight of regulatory attention. The gravity of the situation is further underscored by notices from the Federal Trade Commission (FTC), explicitly alerting each provider to their association with such illicit activities.
Notable companies caught in this dragnet include:
These companies have been starkly reminded of their legal obligations under the FCC's stringent rules. In particular, “All gateway providers must take reasonable and effective steps to ensure that any foreign originating provider or foreign intermediate provider from which it directly receives traffic is not using the gateway provider to carry or process a high volume of illegal traffic onto the U.S. network.” These steps include implementing stringent vetting processes for foreign partners, continuous monitoring to detect irregular traffic patterns, collaboration with industry traceback groups, adoption of call authentication protocols, and swift response to regulatory alerts.
Noncompliance can lead to a multitude of serious repercussions ranging from a blocking order, which significantly impedes a company's operational capabilities, to more enduring consequences such as monetary fines and legal ramifications. And perhaps most critically, a long-term and often irreversible consequence of nonadherence is the damage inflicted on a company's reputation.
Just ask One Eye, LLC—a cautionary tale etched in the annals of FCC enforcement.
In May 2023, One Eye LLC faced enforcement action by the FCC's Enforcement Bureau, marking the first-ever RoboBlocking order issued against a company—a precedent that shouldn’t be ignored. The Bureau ordered voice service providers to block and cease accepting traffic from One Eye LLC, an international gateway provider. This case serves as a grave reminder of the importance of regulatory compliance, transparency, accountability, and proactive risk management, but will it be enough of a deterrent for other gateway providers?
As the telecommunications landscape evolves, the industry must navigate the future with vigilance, learning from the mistakes of the past and embracing a culture of compliance that safeguards the integrity and security of the ecosystem. The choices made today will define the industry's trajectory, and the FCC's precedents serve as guideposts urging providers to tread carefully, uphold standards, and fortify the foundation of ethical and legal practices.
For providers looking to implement or enhance illegal robocall mitigation on your networks, download our KYC Model Standards Guide, a plug-and-play template to KYC management of communications entities.
