Client Advisory | General Regulatory & Legal Advisory

Robocall Mitigation Webinar: How Voice Carriers Can Survive Imminent Regulatory Challenges, Law Enforcement Risks, and Killer Fines

Everybody hates robocalls, but no entity despises them more than the Federal Communications Commission. During the past two years the FCC has made robocall mitigation Priority One, and voice carriers of all shapes and sizes have been subject to more and more stringent compliance obligations, with strict penalties for carriers that violate the rules.

CCA and The CommLaw Group have teamed up to present a webinar on May 24, 2022 that will provide a roadmap to guide your company through the treacherous waters of STIR/SHAKEN and other robocall mitigation matters.

Our webinar will cover:

  • the imminent FCC implementation deadline, and which carriers are affected by it;
  • step-by-step instructions for full compliance;
  • what to do if your company cannot meet the deadline;
  • the severe consequences for non-compliance, and how to avoid them;
  • enforcement outside of the FCC; and
  • international robocall enforcement issues.

Imminent FCC Compliance Deadline: June 30, 2022

The FCC’s original deadline for full STIR/SHAKEN compliance was June 30, 2021. Large voice providers were required to upgrade the software platforms in the IP portions of their networks, obtain a “token” from a third party to prove they were “STIR/SHAKEN authorized” and get a certificate to prove compliance. The Commission granted smaller voice carriers a two-year extension for full STIR/SHAKEN compliance, as long as they filed a robocall mitigation plan “placeholder” by the original deadline. Last December, the FCC announced that the full STIR/SHAKEN deadline would be moved up to June 30, 2022 for a large subset of small voice carriers. Carriers who are not yet STIR.SHAKEN compliant should strive to begin the process as soon as possible or risk having their calls blocked, enforcement actions, and very substantial fines.

Compliance Beyond the FCC

The FCC is partnering up with state attorneys general to intensify enforcement efforts. The Commission and the AGs have agreed to share information and cooperate in prosecuting offenders. To compound the issue, some states have robocall mitigation rules that are stricter than those of the FCC. We will discuss the implications of these efforts and present strategies for dealing with them.

Civil lawsuits are also a possibility for entities that instigate and enable illegal robocalls. Last year Marriott filed a lawsuit in federal court against perpetrators responsible for illegal and fraudulent robocalls misusing Marriott’s name, in violation of state and federal laws. Avoiding civil liability is a key element of robocall mitigation.

International Robocall Enforcement

Robocall mitigation extends beyond the U.S. Many illegal robocalls originate in foreign countries. In its effort to stem foreign-originated illegal calls, the FCC will impose new obligations on U.S. gateway providers and bar U.S. carriers from accepting foreign originated calls using US numbers in caller ID unless the foreign providers register in the robocall mitigation database.

Webinar Registration Details

To register for this webinar, click here. For further information, please contact Ronald E. Quirk at (703) 714-1305 or


The CommLaw Group Can Help!

Given the complexity and evolving nature of the FCC’s rules, regulations and industry policies & procedures around Robocall Mitigation and Compliance issues (e.g., Stir/Shaken, TRACED Act, FCC Rules & Regulations, US Telecom Industry group, ATIS, NECA, VoIP Numbering Waivers, Know Your Customer and the private sector ecosystem), as well as the increased risk of business disputes, consumer protection enforcement by state attorneys general, and even civil litigation, and anticipating the potential torrent of client questions and concerns, The CommLaw Group formed a “Robocall Mitigation Response Team” to help clients (old and new) tackle their unique responsibilities.


  • Michael Donahue — Tel: 703-714-1319 / E-mail:
  • Rob Jackson – Tel: 703-714-1316 / E-mail:
  • Ron Quirk – Tel: 703-714-1305 / E-mail:


Related Resources

Related Insights and Advisories

Sign up for our email list to receive notifications regarding new advisories and news:

Ask An Attorney

Ask An Attorney