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The Federal Communications Commission (“FCC” or “Commission”) Thursday announced that it had imposed a $299,997,000 fine on an international network of companies that made more than five hundred billion illegal robocalls to more than 500 million phone numbers in in 2021. As delineated in our earlier client advisory, in June 2022, the FCC ordered all U.S.-based voice service providers (“VSPs”) to immediately investigate and stop carrying traffic made by or on behalf of Roy Cox, Jr., Aaron Michael Jones and their associated entities known collectively as the “Cox/Jones/Sumco Panama Operation.” Various originating VSPs were also allegedly involved in the scheme, and the Commission directed U.S.-based carriers to block traffic from those VSPs. Any VSP that chose not to block traffic from these entities were required to file detailed reports with the Commission stating why they did not take the required action.

This is the 11th robocall enforcement action prosecuted by the FCC this year. Previous actions include multi-million fines against illegal robocallers, cease-and-desist orders to VSPs suspected of enabling illegal robocalling, and orders to other carriers requiring them to block traffic from VSPs shown to have facilitated unlawful robocalling.  

The FCC has stated on numerous occasions that combating illegal robocalls is the agency’s top consumer protection priority. Accordingly, the Commission will continue to vigorously enforce its rules against the origination and carrying of illegal robocalls. The Commission has been brutal on robocall rule violators and has shown that it will not hesitate to impose very steep fines and other sanctions on them. Consequently, it is critical that all VSPs ensure that they are actively engaged in mitigating unlawful robocalls and taking required measures such as fully implementing STIR/SHAKEN when appropriate, filing robocall mitigation plans, and promptly responding to traceback requests.

NEED HELP WITH ROBOCALL MITIGATION, COMPLIANCE AND LITIGATION?

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.

CONTACT US NOW, WE ARE STANDING BY TO GUIDE YOUR COMPANY’S COMPLIANCE EFFORTS
Michael Donahue — Tel: 703-714-1319 / E-mail: mpd@CommLawGroup.com
Rob Jackson – Tel: 703-714-1316 / E-mail: rhj@CommLawGroup.com
Ron Quirk – Tel: 703-714-1305 / E-mail: req@CommLawGroup.com

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