Telephone and SMS compliance regulations updated

Federal Communications Commission Ends Spring Cleaning Initiative with Action Against Alliant

The Office of Enforcement of the Federal Communications Commission (Commission) has taken the third and final enforcement action under its Spring Cleaning Initiative by issuing a public notice informing all U.S.-based voice service providers of a significant amount of illegal traffic transmitted over Alliant Financial (Alliant). In a related cease and desist letter, the Bureau also directed Alliant to take immediate steps, including blocking the illegal traffic as necessary, to prevent its network from continuing to serve as a source of illegal robocall traffic. The cease-and-desist letter directed Alliant to reduce illicit traffic on its networks by May 22, 2024, or to implement effective measures to prevent new and renewing customers from using its networks to forward illicit calls by June 3, 2024. From that point on, the Commission has written no stated whether Alliant had met the May 22 deadline.

If the Commission fails to act within the prescribed period under the rules, all U.S.-based voice service providers power block or stop accepting all voice traffic from Alliant. Failure to take the required action may also result in Alliant being removed from the Robocall Mitigation Database (RMD). Removal from the RMD would require all intermediate and final voice service providers to stop accepting traffic from Alliant.

According to a public notice and accompanying press release, beginning in late 2023 and continuing through February 2024, the USTelecom-led Industry Traceback Group traced several calls to wireless numbers, delivering recorded messages related to debt consolidation loans, allegedly originating from “One Street Financial”, “Main Street Financial” and “Alliant Financial”. The bureau notes that the latter two names are problematic because they are similar to those of unrelated, legitimate financial services companies that had to warn customers that their names were being used to make fraudulent phone calls. The Bureau also determined that the numerous callbacks were just part of a larger campaign in which some consumers were called repeatedly, even after being answered and asked to be removed.

This latest action was taken in coordination with the Consumer Financial Protection Bureau and the Department of Veterans Affairs because many financial programs disproportionately target and harm veterans, service members and their families.

The Bureau of Law Enforcement considers a cluster of repetitive phone calls a “serious threat” to communications services

In a landmark move, the Bureau issued an enforcement advisory classifying a group of voice service providers and their personnel, known as Royal Tiger, as a Consumer Communications Information Services (C-CIST) threat. This first-of-its-kind action resulted from Royal Tiger’s continued generation and transmission of illicit robocall traffic, including credit card interest fraud, fraudulent order authorizations, and calls impersonating government, bank, and utility companies.

As explained in the attached fact sheet, the C-CIST classification, while not imposing any immediate penalties on Royal Tiger or requiring action by other suppliers, plays a key role in raising awareness of Royal Tiger and its associated entities and personnel. According to the Bureau, the C-CIST designation is intended to “shine a very bright light on (serious and repeat offenders) law enforcement, industry stakeholders, consumers and businesses” to highlight the threat these entities pose by operating shadow companies and shell companies. The increased awareness is intended to help voice, intermediate and gateway providers strengthen and implement Know Your Customer and Know Your Upstream Provider procedures. The office will publish a list of entities with the C-CIST designation on its website.

Royal Tiger is led by Prince Jashvantlal Anand and Kaushal Bhavsar. In the United States, Royal Tiger consists of PZ Telecom, PZ Illum and One Eye LLC. The bureau has already placed all three companies under enforcement actions (listed below), as well as other sanctions imposed by the Federal Trade Commission and the Indiana Attorney General.

The office also identified several Royal Tiger customers who initiated some of the illicit traffic that ultimately was routed through Royal Tiger networks. The following list may be useful in implementing the required Know Your Customer processes:

• Mavtel Voip
• Intelligent
• Edora Technologies
• Q2 Serves
• Spinning Mantra Communications Pvt. Sp. z o. o
• Cyber ​​​​Futuristics Sp. Sp. z o. o
• Iqbri Telecom Sp. Sp. z o. o
• Globalite Collaboration Pvt. Sp. z o. o
• RD INFOTECH
• AARV Services Sp. Sp. z o. o
• Coefficient
• Go4Customer/CyFuture
• SAGA
• Maximum solutions
• LINTECH SOLUTIONS

According to the press release announcing the action, an individual, entity or network of entities will be classified as a C-CIST if that party’s conduct “in its nature or scope – poses a significant threat to consumer confidence in the integrity of the communications information” of the service.” The office also made clear that it expects the telecommunications industry to play a role in monitoring other potential C-CIST designees attempting to transmit illegal robocalls on their networks. While the Bureau has not yet explained the full set of tools it intends to use to keep C-CIST designees “off U.S. communications networks,” voice service providers should remain vigilant and take the time to evaluate their customer base and review and correct as needed. needs “Know your customer” protocols.

Commission Issues Two NALS Orders Related to Illegal Telephone Scheme at a New Hampshire Elementary School

At its May meeting, the Commission adopted a Notice of Clear Liability (NAL) for Lingo Telecom (Lingo) for allegedly transmitting illegally spoofed fraudulent robocalls with incorrect authentication information, labeling them with the highest level of caller ID credentials. This is the first enforcement action taken by the Commission against a voice service provider (in this case, the originating provider) for breaching the Commission’s Know Your Customer requirements. NAL found that Lingo failed to comply with its “Know Your Customer” principles by applying the highest STIR/SHAKEN credential – signifying trust in caller ID information – for apparently illegal spoofed calls, while making no effort to verify the accuracy of the caller ID information. NAL anticipates a fine of $2 million. Lingo will have the opportunity to respond to NAL before the Commission considers the forfeiture order that formally imposes the fine.

In a related action, the Commission also adopted an NAL complaint against Steve Kramer for allegedly illegally placing spoofed robocalls using a false AI-generated voice clone to spread election disinformation during the New Hampshire presidential primary. The illegal phone calls included a cloned voice of President Biden urging potential voters not to participate in the primary elections. NAL found that Kramer used the services of Voice Broadcasting Corp., which used the services of Life Corp. to transmit the call via Lingo. NAL is proposing a $6 million fine for Kramer’s violation of the Truth in Caller ID Act, which prohibits transmitting incorrect caller ID information with the intent to defraud, harm, or illegally obtain anything of value. Because the calls encouraged voters not to vote, the Commission determined that they were intended to deceive and/or cause harm.

These NALs are related to the Commission’s investigation and previous enforcement action against Lingo in February, in which it sent a cease and desist letter ordering the provider to stop initiating or transmitting this suspicious traffic. As of this writing, the Enforcement Bureau has not yet taken any further action against Lingo.