A previous article discussed the April 4, 2024 Federal Communications Commission (FCC) announcement regarding a "Spring Cleaning" initiative highlighting a series of robocall enforcement actions in collaboration with other federal agencies. A little more than a month later, the FCC has followed through on that initiative with the introduction of a new robocall tool to combat threat actors who weaponize the U.S. communications networks to perpetuate illegal schemes against consumers.
The “tool” is actually novel designation for entities and individuals who persistently conduct robocall campaigns that defraud consumers: they will henceforth be classified as a Consumer Communications Information Services Threat (C-CIST).
Based on the FCC’s description, not just any fraudster will be designated as a C-CIST. Instead, that designation will be exclusively reserved for criminals and criminal organizations that cause the most harm to consumers, and/or pose a significant threat to consumer trust in the integrity of communications information services. Such threat actors frequently employ multiple companies, convoluted corporate structures, shifting addresses, and other tactics to evade consequences for their illegal activities.
According to the FCC, the C-CIST classification tool will allow it to better coordinate with the agency’s regulatory and law enforcement partners both in the US and abroad and will also provide industry stakeholders with information to enhance their “Know Your Customer” and “Know Your Upstream Provider” processes.
FCC Names its First C-CIST Robocall Investigation
In a public notice released on May 13, 2024, the FCC issued its first C-CIST designation against a group of individuals and entities it dubbed “Royal Tiger,” a sprawling web of entities and individuals operating in India, the United Kingdom, the United Arab Emirates, and the United States.
The U.S. companies that comprise Royal Tiger are PZ Telecommunication LLC, Illum Telecommunication Limited, and One Eye LLC, all of which are allegedly operated by someone with the Bond villainesque name of Prince Jashvantlal Anand and his associate/henchman Kaushal Bhavsar. In addition to the U.S. companies, Prince Anand apparently operates companies in the U.K. and India, and maintains residences in the United Arab Emirates and India. Anand has also used the more prosaic alias “Frank Murphy” in furtherance of Royal Tiger’s schemes.
According to the FCC, Royal Tiger earned the dubious honor of being named the first C-CIST by persistently transmitting illegal robocall traffic aimed at defrauding consumers, resulting in numerous enforcement actions by the FCC, the Federal Trade Commission (FTC), and other law enforcement agencies. Many of the fraudulent calls Royal Tiger placed impersonated government agencies, banks, and utility companies. Such calls are particularly harmful because they can result in substantial financial loss and erode public trust in the telecommunications network.
How the C-CIST Designation Will be Used
Going forward, the FCC will classify individuals or entities as a C-CIST to help ensure that they are readily detected and blocked from perpetuating further unlawful schemes that harm consumers and compromise communications information services. The designation will also provide industry stakeholders—the first line of defense against harmful traffic—with information to fortify their “Know Your Customer” and “Know Your Upstream Provider” processes.
