FCC chairwoman: Fines alone aren't enough (Robocalls)

'Fines alone aren't enough:' FCC threatens to blacklist voice providers for flouting robocall rules

[...]
“This is a new era. If a provider doesn’t meet its obligations under the law, it now faces expulsion from America’s phone networks. Fines alone aren’t enough,” FCC chairwoman Jessica Rosenworcel said in a statement accompanying the announcement. “Providers that don’t follow our rules and make it easy to scam consumers will now face swift consequences.”

It’s the first such enforcement action by the agency to reduce the growing problem of robocalls since call ID verification protocols known as “STIR/SHAKEN” went fully into effect this summer.
[...]

Why did we need to wait for STIR/SHAKEN to do this?

Mike

Because it's illegal for common carriers to block traffic otherwise.

Because it's illegal for common carriers to block traffic otherwise.

Wait, what? It's illegal to police their own users?

Mike

Why did we need to wait for STIR/SHAKEN to do this?

Because those pushing STIR/SHAKEN though the bacronym was so cool they just had to do it, even if it wasn't going to help... :-\

We're talking about blocking other carriers.

    > Because it's illegal for common carriers to block traffic otherwise.

    Wait, what? It's illegal to police their own users?

    Mike

The problem has always been solvable at the ingress provider. The problem was that there was zero to negative incentive to do that. You don't need an elaborate PKI to tell the ingress provider which prefixes customers are allow to assert. It's pretty analogous to when submission authentication was pretty nonexistent with email... there was no incentive to not be an open relay sewer. Unlike email spam, SIP signaling is pretty easy to determine whether it's spam. All it needed was somebody to force regulation which unlike email there was always jurisdiction with the FCC.

Mike

The issue isn’t which ‘prefixes’ I accept from my customers, but which ‘prefixes’ I accept from the people I peer with, because it’s entirely dynamic and without a doing a database dip on EVERY call, I have to assume that my peer or my peers customer or my peers peer is doing the right thing.

I can’t simply block traffic from a peer carrier, it’s not allowed, so there has to be some mechanism to mark that a prefix should be allowed, which is what Shaken/Stir does.

Shane

I think the point the other Mike was trying to make was that if everyone policed their customers, this wouldn’t be a problem. Since some don’t, something else needed to be tried.

Sorta like in the IP world, if everyone did BCP38/84, amplification attacks wouldn’t exist. Not everyone does, so…

Sorta like in the IP world, if everyone did BCP38/84, amplification attacks wouldn’t exist. Not everyone does, so…

Tragedy of the commons

Furthermore, those customers are paying to not be policed.

Is there any information on how much is from customers intent on fraud and how much is from compromised systems?

Phone spam pretty much always involves the knowledge and involvement of the provider. There are no phone providers who don't know when one of their customers are making millions of robocalls.

International toll fraud also always involves the collusion of corrupt small country telephone monopolies.

So unlike email spam, where there are a million ways to send a million emails a minute without someone being aware, phone spam is definitively collisional. (Is that a word?)

    The problem has always been solvable at the ingress provider. The
    problem was that there was zero to negative incentive to do that. You
    don't need an elaborate PKI to tell the ingress provider which prefixes
    customers are allow to assert. It's pretty analogous to when submission
    authentication was pretty nonexistent with email... there was no
    incentive to not be an open relay sewer. Unlike email spam, SIP
    signaling is pretty easy to determine whether it's spam. All it needed
    was somebody to force regulation which unlike email there was always
    jurisdiction with the FCC.

    Mike

collusion:

noun:
secret or illegal cooperation or conspiracy, especially in order to
cheat or deceive others.

Law:
illegal cooperation or conspiracy, especially between ostensible
opponents in a lawsuit.

Yup. Having worked for a small VoIP provider, your comment is exactly
on point.

I think the point the other Mike was trying to make was that if everyone policed their customers, this wouldn't be a problem. Since some don't, something else needed to be tried.

Exactly. And that doesn't require an elaborate PKI. Who is allowed to use what telephone numbers is an administrative issue for the ingress provider to police. It's the equivalent to gmail not allowing me to spoof whatever email address I want. The FCC could have required that ages ago.

Mike

Isn’t part of STIR/SHAKEN to make it easier to determine the ingress provider, or the provider of last blame?

Except the cost to do the data dips to determine the authorization isn’t “free”.

Analogies to email are always fraught.

How often do LEGITIMATE telco customers make hundreds if not thousands
of calls per hour w/o some explicit arrangement with their telco?

As they say, a telephone company is a vast, detailed billing system
with an added voice feature.

Quite unlike email where it's mostly fire and forget plus or minus
hitting a spam filter precisely because there is no billing, no
incentive. And no voice "snowshoeing".

I doubt robocalls are ever made with anything like spam
roboarmies.

With email it's like every single computer on the net with an IP
address has, in effect, a (potentially) fully functional "originating
switch" (again, some exceptions like port 25 blocking.) People have
run spambots from others' printers etc.

Phone spam pretty much always involves the knowledge and involvement of the provider. There are no phone providers who don't know when one of their customers are making millions of robocalls.

International toll fraud also always involves the collusion of corrupt small country telephone monopolies.

So unlike email spam, where there are a million ways to send a million emails a minute without someone being aware, phone spam is definitively collisional. (Is that a word?)

All the more reason why waiting for STIR/SHAKEN was unnecessary. And yes the telephony network is a lot easier than email to police.

Mike

What’s regulated or implemented is rarely the best course of action. Does this cause more good or harm?