The importance of robocall mitigation

Two VoIP providers are in trouble with regulators and law enforcement for transiting robocalls. Robocall mitigation is not just a compliance thing—it can also help providers stay out of trouble. This article shows how.

You may have seen the recent news about the following VoIP providers:

  • Following the rules in the Gateway Provider Order, the FCC issued a Final Determination Order instructing providers to block all calls from One Eye LLC for failure to respond to the Enforcement Bureau’s Notification of Suspected Illegal Traffic and Initial Determination Order.
  • The U.S. Justice Department filed a civil enforcement action against XCast Labs, Inc. for allegedly violating the TSR (Telemarketing Sales Rule).

Gateway provider order

The Gateway Provider Order requires the following:

  • Gateway providers must block illegal traffic when notified by the Commission.
  • Downstream providers must block all traffic received directly from a gateway provider when notified by the Commission that the gateway provider failed to block.

Telemarketing Sales Rule

The TSR prohibits the following:

  • Deceptive or abusive telemarketing acts or practices
  • Calls to telephone numbers included in the Do-Not-Call database
  • Providing substantial assistance or support to any seller or telemarketer when the person providing substantial assistance or support knows or consciously avoids knowing that the seller or telemarketer is violating the TSR.

It’s that last part that can get a telecom services provider in trouble.

Robocall mitigation

An effective robocall mitigation program doesn’t just mitigate robocalls—it also mitigates compliance and legal risks. If you want to avoid trouble for illegal robocalls, then robocall mitigation is the answer.

How do you do that? By doing the following:

  1. Vet your customers and upstream providers.
  2. Monitor the calls they initiate or send to you and look for suspicious traffic.


The most specific vetting examples we’ve seen are in consent agreements that were agreed upon in court case settlements. Here’s a recent example.

The vetting procedures in this consent agreement example may seem rather strict. If you’re looking for vetting ideas, however, this list of requirements is a good place to start.

Call analytics

You can inspect Call Detail Records (CDRs) with reporting tools and look for suspicious patterns. CDRs are generated after calls are completed, so you must be diligent about following up to investigate suspicious traffic. If the Traceback Group, regulators, or law enforcement contacts you about suspicious calls, you want to be able to show that you act on the reports.

You can go one step better by implementing a call analytics solution that monitors traffic in real-time as each call is being set up. This provides very fast notification of suspicious traffic.

You even have the option to configure the analytics to block suspicious traffic during call setup. That way, you won’t have to worry about how you respond to robocall investigations—there won’t be very many.

New robocall mitigation requirements

The FCC recently strengthened its robocall mitigation requirements. All providers will have to perform robocall mitigation, develop a robocall mitigation plan that describes their program, and file a robocall mitigation certification with their plan in the Robocall Mitigation Database.

man looking at mobile phone

TransNexus solutions

TransNexus is a leader in developing innovative software to manage and protect telecommunications networks. The company has over 20 years’ experience in providing telecom software solutions including toll fraud prevention, robocall mitigation and prevention, TDoS prevention, analytics, routing, billing support, STIR/SHAKEN and SHAKEN certificate services.

Contact us today to learn more.

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