Federal Communications Commission Finishes Its “Spring Cleaning” Initiative, Taking Action Against Alliant

The Federal Communications Commission’s (Commission) Enforcement Bureau (Bureau) took its third and final enforcement action as part of its “Spring Cleaning” initiative by issuing a Public Notice informing all US-based voice service providers of a substantial amount of unlawful traffic transmitted by Alliant Financial (Alliant). In the associated cease-and-desist letter, the Bureau also instructed Alliant to immediately take steps, including blocking the illegal traffic if necessary, to prevent its network from continuing to be a source of illegal robocall traffic. The cease-and-desist letter instructed Alliant to mitigate the unlawful traffic on its networks by May 22, 2024, or implement effective measures to prevent new and renewing customers from using its network to transmit illegal calls by June 3, 2024. As of this writing, the Commission has not stated whether Alliant met the May 22 compliance deadline.

Should it fail to take either action by their respective deadlines, under the Commission’s rules, all US-based voice service providers may block or cease accepting all voice traffic from Alliant. Failure to take the required actions may also result in Alliant’s removal from the Robocall Mitigation Database (RMD). Removal from the RMD would require all intermediate and terminating voice service providers to cease accepting traffic from Alliant.

According to the Public Notice and accompanying News Release, beginning in late 2023 and continuing through February 2024, the USTelecom-led Industry Traceback Group conducted tracebacks on several calls placed to wireless numbers delivering prerecorded messages related to debt consolidation loans claiming to be 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 the names of unrelated, legitimate financial services companies, both of which have had to issue warnings to customers that their names are being used to make fraudulent calls. The Bureau also found that the numerous traceback calls were merely a subset of a larger campaign, in which some consumers were called multiple times, even after answering and asking to be removed.

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

Enforcement Bureau Designates Group of Repeat Robocallers as “Significant 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 Threat (C-CIST). This first-of-its-kind action resulted from Royal Tiger’s persistent origination and transmission of illegal robocalling traffic, including credit card interest rate scams, fake purchase order authorizations, and calls impersonating government entities, banks, and utility companies.

As explained in the accompanying Fact Sheet, the C-CIST classification, while not imposing any immediate penalties on Royal Tiger or requiring action from other providers, plays a crucial role in raising awareness of Royal Tiger and its associated entities and personnel. According to the Bureau, the C-CIST designation serves to “shine[] a very bright light on [serious and repeat offenders] for law enforcement, industry stakeholders, consumers, and businesses” to illuminate the threat those entities pose by operating in the shadows and behind shell companies. The heightened awareness is intended to help voice service, intermediate, and gateway providers strengthen and implement their Know Your Customer and Know Your Upstream Provider procedures. The Bureau will publicize 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 is comprised of PZ Telecom, PZ Illum, and One Eye LLC. All three companies have already been subject to enforcement action by the Bureau (noted below) as well as other sanctions from the Federal Trade Commission and Indiana Attorney General.

The Bureau also identified several clients of Royal Tiger that initiated some of the illegal traffic that was ultimately transmitted through Royal Tiger’s networks. The following list may be useful for implementing the required Know Your Customer processes:

• Mavtel Voip
• Clevertel
• Edoro Technologies
• Q2Serves
• Spinning Mantra Communications Pvt. Ltd.
• Cyber Futuristics Pvt. Ltd.
• Iqbri Telecom Pvt. Ltd.
• Globalite Collaboration Pvt. Ltd.
• RD INFOTECH
• AARV Services Pvt. Ltd.
• Coequence
• Go4Customer/CyFuture
• SAGA
• Max Solutions
• LINTECH SOLUTIONS

According to the News Release announcing the action, an individual, entity, or network of entities will be classified as a C-CIST when that party’s conduct “in either nature or scope — poses a significant threat to consumer trust in the integrity of communications information services.” The Bureau also made clear that it expects the telecommunications industry to play a role in monitoring for other potential C-CIST designees trying to transmit illegal robocalls on their networks. While the Bureau has not yet made clear the full panoply of tools it intends to use to keep C-CIST designees “out of US communications networks,” voice service providers should remain vigilant and take the time to evaluate their customer base and review and improve their Know Your Customer protocols as necessary.

Commission Issues Two NALS From Illegal Robocalling Scheme During New Hampshire Primary

During its May Meeting, the Commission adopted a Notice of Apparent Liability (NAL) against Lingo Telecom (Lingo) for allegedly transmitting illegally spoofed, deepfake robocalls with incorrect authentication information — labeling them with the highest level of caller ID attestation. This is the first enforcement action the Commission has taken against a voice service provider (in this case, an originating provider) for violating the Commission’s Know Your Customer requirements. The NAL found that Lingo failed to follow the Know Your Customer rules by applying the highest STIR/SHAKEN attestation — signifying trust in the caller ID information — to apparently illegal spoofed calls while failing to make any effort to verify the accuracy of the caller ID information. The NAL includes a $2 million monetary penalty. Lingo will have the opportunity to respond to the NAL before the Commission considers a Forfeiture Order, which formally imposes the fine.

In a related action, the Commission also adopted an NAL against Steve Kramer for allegedly making illegally spoofed robocalls using a deepfake, AI-generated voice clone to spread election misinformation during the New Hampshire presidential primary. The illegal calls contained the cloned voice of President Biden urging prospective voters not to participate in the primary. The NAL found that Kramer used Voice Broadcasting Corp., which used Life Corp.’s services to transmit the call through Lingo. The NAL proposes to impose a $6 million fine for Kramer’s violations of the Truth in Caller ID Act, which prohibits transmitting inaccurate caller ID information with the intent to defraud, cause harm, or wrongly obtain anything of value. Because the calls encouraged voters not to vote, the Commission determined that they were made with the intent to defraud 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 originating or transmitting this suspicious traffic. As of this writing, the Enforcement Bureau has not yet taken any other subsequent action against Lingo.