Look carriers, you all need KYC, monitoring and mitigation policies like YESTERDAY. Reach out to us and we can help you. We have helped a ton of companies with this!

Lots of you have been pinging me about this Identidad FCC issue. Apparently Identidad is a big deal in many circles. And they may be in some serious trouble. But here’s is what the FCC has said:

Identidad Advertising Development LLC
Andres Sanchez
Chief Executive Officer
848 Brickell Ave Suite 810
Miami, FL 33131
ssanchez@identidadtech.com

Re: Notification of Suspected Illegal Robocall Traffic

Dear Mr. Sanchez,

Identidad Advertising Development LLC (Identidad or Company) is a gateway provider1 and is apparently transmitting illegal robocalls from callers impersonating financial institutions. Both the Enforcement Bureau (Bureau) of the Federal Communications Commission (FCC) and the Federal Trade Commission previously warned Identidad of its obligations to mitigate illegal traffic emanating from overseas.2

This letter provides notice of important legal obligations and steps Identidad must take to address this apparently illegal traffic. Failure to comply with the steps outlined in this letter may result in downstream voice service providers permanently blocking all of Identidad’s traffic.

I. Background

A. The Nature of the Identified Traffic

USTelecom’s Industry Traceback Group (ITG)3 traced the sources of five calls, identified in Attachment A, placed to wireless numbers between August 8, 2024 and September 14, 2024. 

The calls impersonated financial institutions such as banks and credit card issuers and played variations of the following prerecorded message:

This is a transaction alert call from Visa and Mastercard support. There
has [sic] been two transactions done on your card for $299.00 on
Walmart and $3,950.00 on Western Union. If you have made these
transactions and accept the charges simply hang up. If you have not
made these transactions and you wish to report fraud please press 1
immediately.

Consumers who responded to similar calls under this robocall campaign assert that they were instructed to make payments or provide sensitive financial information:

Received a call from “chase bank” it wasn’t chase and they said I had
fraudulent activity so I called them back knowing they weren’t chase and
they tried to get me to send $2,000 to them [].6

YouMail, Inc. (YouMail) estimates that between July and September 2024, more than one million robocalls – similar to the five traced back to Identidad – were placed to call recipients.7 Robocalls that impersonate legitimate financial institutions and attempt to acquire personal information are particularly pernicious.8

These calls not only exploit the recipient’s fear of falling victim to financial fraud, they may also undermine attempts by legitimate financial institution to protect their customers.9

B. The Company Served as the Gateway Provider for the Identified Traffic

The ITG identified Identidad as the gateway provider responsible for the apparently illegal calls to wireless telephone numbers identified in Attachment A. 10 The ITG notified Identidad of these calls, including supporting data identifying each call.11 Identidad did not provide to the ITG evidence of consent for these calls or dispute that the calls were illegal. 12 Nor did Identidad assert that any exceptions to the rules prohibiting these calls applied.13

II. Apparent Violations

It is unlawful to make a call to a cell phone number using an artificial or prerecorded voice message absent an emergency purpose or prior express consent of the called party. 14 Here, the identified calls were all made using an artificial or prerecorded voice message and were placed to cell phone numbers.15 The Company has not provided any evidence of prior express consent, written or otherwise, or an emergency purpose.16 Accordingly, the calls were apparently illegal.17 The Company has not disputed that it served as the gateway provider for the calls.18

The Commission goes on to authorize permissive shutdown and advises mandatory shutdown may follow if calls are not cleaned up in 48 hours.

Notice, again, the role of YouMail and ITG working together here. When you receive a ticket from the ITG you need to take it seriously–especially when you are deemed to be the gateway or originating carrier– as Identidad was here.

Carriers need to be doing more than ever before to “KYC” and mitigate claims of suspected bad traffic on their networks. And while even intermediary carriers– like SmartBiz— are getting picked on recently, originating gateways should expect to be held accountable for bad traffic reaching American networks from overseas.