McLean, VA., Apr. 27, 2023 – Numeracle™ Inc. (“Numeracle” or the “Company”), the pioneer of Verified Identity™ and Entity Identity Management™ for communications, today announced the release of a KYC policy guide entitled “Model Standards for Know Your Customer” to serve as a template for voice service providers striving to keep illegal callers off their networks.
In support of the industry’s fight against illegal robocalls, the Federal Communications Commission (“FCC” or “the Commission”) instituted Know Your Customer (“KYC”) requirements for originating voice service providers in 2020. This concept will also be addressed in the Commission’s May Open Meeting in the form of an order imposing “Know Your Upstream Provider” obligations. As KYC requirements are expanded to include other types of providers such as gateway and intermediate providers, the need for KYC guidance has become increasingly important. Numeracle’s Model Standards address knowing both upstream end entities making calls and upstream service providers delivering calls from their customers or other service providers.
Numeracle was the pioneer in bringing KYC concepts to the telecommunications industry. “I first introduced the voice community to the concept of KYC in 2017, identifying how its success in mitigating fraud in the financial industry can and must be applied to the voice channel,” said Rebekah Johnson, founder and CEO, Numeracle. “Though adopted through rulemaking in the years since, the Commission has declined to specify exactly what is meant by the Know Your Customer requirement. This has caused thousands of service providers in the U.S. to struggle to come up with effective policies, leaving themselves vulnerable to becoming a conduit for illegal calls and the target of the next enforcement action. Numeracle is proud to be the first to step up and provide concrete guidelines for immediate KYC implementation.”
Numeracle’s “Model Standards for Know Your Customer" provide a detailed guide to understanding and applying KYC, allowing for flexibility to meet the needs of various types of providers with different services. This policy framework can also serve as a model for legislators and regulators looking to impose requirements in their jurisdictions. It can also be used to aid enforcement agencies in determining whether a voice service provider suspected of facilitating illegal calls has complied with the general KYC mandate set forth.
“As the first to introduce the concept of Know Your Customer to the voice community, we have instituted and abided by our own strict KYC requirements to obtain Numeracle services since day one,” said Sarah Delphey, Vice President of Trust Solutions, Numeracle. “While Numeracle is not a voice service provider, we face many of the same challenges to verify the identities of entities seeking to communicate lawfully with their customers. Today, on behalf of the entire communications ecosystem, we look forward to extending our expertise in KYC implementation with the release of the industry’s first step-by-step policy framework.”
Ongoing enforcement by state and federal authorities has also added demonstrable urgency with calls to action to implement KYC policies. The FCC shut down traffic from voice provider PhoneBurner, who was found to be facilitating mortgage scam calls on behalf of MV Realty. As stated by FCC Enforcement Bureau Chief Loyaan Egal, “’Know Your Customer’ (KYC) principles should be at the forefront of all communications service providers’ business practices.”
Ignoring KYC doesn’t only put voice providers at risk of federal enforcement action. The formation of a nationwide Anti-Robocall Litigation Task Force of 50 attorneys general in 2022 represents another focused group of stakeholders at the state level. Created “to hold companies accountable when they turn a blind eye to the robocallers they’re letting on to their networks,” the creation and bipartisan participation of this task force sends another clear message. Take the steps to identify and block bad actors from your networks using KYC, or find yourself the target of the next anti-robocall lawsuit.
Numeracle has filed its Model Standards for Know Your Customer in the FCC’s public records, and it is available for download at numeracle.com/KYC-policy-guide.
For more information on KYC best practices and the importance of establishing Know Your Customer policies across the communications industry, visit Numeracle’s KYC podcast library on the subject or contact us for a consultation.