Today, the Federal Communications Commission’s (FCC) Enforcement Bureau (Bureau) has, for the first time, designated a group of repeat robocall offenders as a Consumer Communications Information Services Threat (C-CIST). The FCC has introduced the C-CIST classification to identify and mitigate threats from entities which engage in activities that severely undermine consumer trust in communication services. This classification aims to enhance the detection, prevention, and prosecutorial actions against such entities and bolster the capabilities of global anti-robocall partners by providing a method to identify these threats before they impact U.S. networks.

Leveraging the FCC’s recent actions against calls exploiting generative AI voice-cloning technology, the C-CIST designation serves as an additional mechanism for the Bureau to officially identify and address repeat offenders who exploit U.S. communication networks. These offenders often employ a variety of complex and opaque corporate structures, frequently changing addresses, and other strategies to avoid legal repercussions and continue their fraudulent operations. Additionally, the C-CIST classification will aid industry stakeholders by supplying essential information to improve their “Know Your Customer” (KYC) and (the newly minted) “Know Your Upstream Provider” (KYUP) policies and procedures.  For more information on KYC “best practices” we recommend visiting: Cloud Communications Alliance/Numeracle KYC Best Practices and Policies.

The Bureau classifies a party as a C-CIST when the party’s misconduct—in either nature or scope—poses a significant threat to consumer trust in the integrity of communications information services. The Bureau applies this classification to heighten awareness of these threat actors among domestic and international regulatory and law enforcement partners, as well as industry stakeholders.

Royal Tiger Group

The Royal Tiger group, the first officially designated C-CIST, is an international group of individuals and entities has been involved in widespread robocall scams, including those that impersonate legitimate institutions such as banks and government agencies. The operations have been linked to financial losses and significant breaches of consumer trust.

The group companies located in the United States are PZ Telecommunication LLC, Illum Telecommunication Limited, and One Eye LLC, all of which are led by an individual named “Prince Jashvantlal Anand” and his associate “Kaushal Bhavsar.”

The Royal Tiger group has persisted in transmitting illegal robocall traffic aimed at defrauding consumers, resulting in numerous enforcement actions by the Bureau, the Federal Trade Commission, and our law enforcement partners. In addition to these U.S. entities, Anand is associated with companies in the United Kingdom and India and appears to maintain residences in the United Arab Emirates and India. Anand has used the alias “Frank Murphy” in furtherance of Royal Tiger’s schemes. Bhavsar appears to maintain a residence in India and, according to FCC records, previously maintained a presence in Delaware through One Eye LLC.

The classification of Royal Tiger as a C-CIST carries substantial legal and regulatory implications. It not only subjects its associates to heightened scrutiny but also aligns with broader enforcement actions that could include fines, injunctions, and other penalties.

The FCC has emphasized the importance of industry cooperation in reporting suspicious activities linked to groups like Royal Tiger. Compliance with reporting requirements is crucial for maintaining the integrity of communication networks and protecting consumer interests.

Takeaways

1. Block Traffic from Royal Tiger Entities: Our clients are urged to review their client relationships and cease doing business with the entities identified by the Bureau as part of the Royal Tiger group. This includes blocking their traffic.
2. Enhanced Due Diligence: We recommend enhancing due diligence processes to avoid inadvertent associations with entities classified as C-CISTs in the future. This includes reviewing and monitoring their business relationships and implementing robust “Know Your Customer” (KYC) and “Know Your Upstream Provider” (KYUP) processes. It is also prudent for a provider to ask its immediate upstream providers whether they receive any traffic from any entities identified as C-CISTs (including Royal Tiger) or have investigated their upstream providers.
3. Regulatory Compliance: It is imperative for businesses to stay abreast of FCC regulations and ensure compliance with all applicable laws and guidelines. The C-CIST classification introduces new compliance considerations that must be integrated into corporate governance frameworks.
4. Risk Management: The potential legal and financial repercussions of being associated with a C-CIST classified entity necessitate a proactive approach to risk management. Companies should assess their exposure to such risks and consider appropriate mitigation strategies, including legal consultation and revising internal controls.
5. Cooperation with Law Enforcement: Businesses should establish protocols for cooperating with law enforcement and regulatory bodies in investigations related to illegal communications and fraud. This cooperation is vital for maintaining regulatory compliance and protecting the company’s reputation.
6. Enforcement Actions Monitoring: The FCC stated that any future C-CIST designations will be announced in the normal course of business on the FCC’s website. No “covered list” or database of C-CIST entities will be created at this time. This underscores the importance of monitoring the FCC’s enforcement actions and seeking advice from specialized telecom counsel to vet the prospective clients and mitigate legal exposure risks.

Conclusion

The FCC’s introduction of a C-CIST classification is a landmark development in the regulatory landscape of telecommunications and consumer protection. Businesses in the sector must take heed of the implications of this classification and adjust their compliance and risk management strategies accordingly.

NEED HELP WITH ROBOCALL MITIGATION, COMPLIANCE AND LITIGATION SUPPORT/DEFENSE AGAINST BUSINESS & LEGAL CHALLENGES?

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

Diana James – Tel: 703 663-6757 / E-mail: daj@CommLawGroup.com