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In a pivotal move for telecom regulation, the Federal Communications Commission (FCC) has taken significant action against Lingo Telecom, marking a new era in Know Your Customer (KYC) compliance. This decision not only addresses recent fraudulent activities but also expresses clear KYC guidelines that align closely with Numeracle’s Model KYC Policy.
On August 21, 2024, the FCC adopted a consent decree against Lingo Telecom, referencing the lack of established KYC policies as a core issue. The investigation revealed that Lingo falsely attested calls with STIR/SHAKEN A-Level Attestation without proper verification of caller identity and origination. This level of attestation, which should signify a high degree of trust in the certainty of the call’s origination, was inappropriately used to falsely validate and deliver illegally spoofed robocalls.
These robocalls, which targeted voters in the New Hampshire primary election, featured a deepfake AI-generated voice message wrongly attributed to President Biden. The message misled voters into thinking they should not participate in the upcoming primary election. The FCC’s Notice of Apparent Liability for Forfeiture (FCC 24-60) highlighted this misuse as a clear example of how advanced technologies can be exploited for malicious purposes, undermining both election integrity and consumer confidence in voice calls.
As a result of these violations, the FCC initially proposed a $2 million fine against Lingo Telecom. Ultimately, the company settled for a $1 million civil penalty and committed to a detailed compliance plan.
This settlement underscores the FCC’s commitment to deterring fraudulent practices in the telecom industry, and, for the first time, communicates its expectations of what a robust KYC framework should look like.
We're happy to report, these recommendations walk hand in hand with Numeracle’s KYC Model Standards.
The FCC’s action marks the first time a U.S. regulator has specifically outlined KYC requirements for the telecom industry. Prior to this, there was a lack of clear regulatory guidance on KYC practices. Numeracle stepped in to fill this void by developing a comprehensive Model KYC Policy that sets the benchmark for robust KYC procedures.
Numeracle’s Model KYC Policy for Service and Platform Providers provides a thorough framework for verifying and managing enterprise identities and the suggested supporting information. It includes rigorous verification processes, clear documentation requirements, and proactive monitoring to prevent misuse and fraud.
The alignment of the FCC’s new KYC guidelines with Numeracle’s standards highlights the effectiveness and relevance of our approach. In a line-by-line, side-by-side comparison, the FCC’s requirements support Numeracle’s recommendations with a unified vision.
For telecom service providers, implementing a KYC policy is not just about avoiding negative, and, in the case of Lingo Telecom, public enforcement—it's about proactive risk management and maintaining the integrity of communication services. The alignment between Numeracle’s standards and the FCC’s newly established guidelines provides a clear path for achieving regulatory compliance and protecting against fraud.
Numeracle offers its Model KYC Standards at no cost to service and platform providers who wish to enhance their compliance practices. By adopting these standards, companies can be proactive in meeting regulatory expectations and avoid knowingly or unknowingly facilitating illegal, unverified traffic.
As the telecom industry adapts to these more clearly expressed regulatory expectations, leveraging proven KYC practices will be essential. Numeracle remains committed to leading the way in KYC compliance, providing industry best practices that align with both regulatory expectations and operational needs.
“Up until this point, the FCC hadn’t defined what it meant by KYC. Numeracle filled the gap, and we’re proud to provide our KYC Model Standards to every organization out there who wants to stand beside us to protect legal communications.” -- Keith Buell, General Counsel and Head of Global Public Policy, Numeracle
For more information on how Numeracle’s KYC standards can protect your voice customers and the integrity of your communications platform, download our free plug and play KYC template, or contact us today.
