The Federal Communications Commission recently adopted certain final rules, policies, and proposed rules to “stem the tide of foreign-originated illegal robocalls.” The FCC Order targets so-called “gateway providers,” which are U.S.-based intermediate providers that receive calls directly from a foreign provider or its U.S.-based facilities before transmitting the calls downstream. Among other things, the Order requires gateway providers to block illegal traffic upon notification from the FCC, respond to robocall traceback requests within 24 hours, and implement “know your upstream provider” obligations. The Order’s proposed rules would extend most of the Order’s obligations to all forms of U.S.-based telecom providers.

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Photo of Marc S. Martin Marc S. Martin

Technology, media, and telecom law attorney Marc S. Martin provides regulatory, transactional, and strategic advice to developers, service providers, manufacturers, entrepreneurs, investors, and enterprise customers.

Photo of Brandon Thompson Brandon Thompson

Brandon Thompson has experience working closely with various bureaus, trade associations, and businesses to interpret and enforce the Telephone Consumer Protection Act of 1991 (TCPA), Truth in Caller ID Act, TRACED Act, and other rules and regulations of the Federal Communications Commission (FCC).

Brandon Thompson has experience working closely with various bureaus, trade associations, and businesses to interpret and enforce the Telephone Consumer Protection Act of 1991 (TCPA), Truth in Caller ID Act, TRACED Act, and other rules and regulations of the Federal Communications Commission (FCC). He has coordinated with state attorneys general, the U.S. Department of Justice (DOJ), and the Federal Trade Commission (FTC) on numerous federal enforcement actions.