Analysis of FCC’s Release of Q3, 2023 Traceback Data

On December 29, 2023 the Federal Communications Commission (FCC) released Q3, 2023 traceback data. This information further reinforces the thrust of all previous evidence: that the best way to stop illegal robocalling is at the source with diligent enforcement actions against parties that make illegal robocalls. The Q3 2023 traceback data shows there is no single gateway responsible for allowing illegal robocalls into the United States.

This data also reveals other opportunities for potential future enforcement actions to reduce robocalling.

     Background

The Industry Traceback Group (ITG) is a consortium of US phone companies that collectively share information about scam robocalls in an effort to protect American consumers from fraud. ITG members provide funding to the trade association USTelecom to administer the online portal the ITG uses to trace suspected scam calls.

Since July 2021, complaints about unwanted calls made to the Federal Trade Commission (FTC) have declined 59%. This has largely been the result deterrence promulgated by traceback requests. Criminal groups that send robocalls have learned that calls can be traced to their location and reported to law enforcement.

During this same time, however, financial loss reported to the FTC resulting from fraud initiated by phone call increased 29% (see FVRO: Robocalling Trends). This has been the result of criminal groups in India avoiding detection though traceback by shifting from making large volumes of spoofed, outbound calls to distributing call back phone numbers through computer popup messages and e-mail.

All objective data indicates that every successful effort to reduce robocalls has been the result of an enforcement action or fear of an enforcement action.

• In 2016, IRS impersonation calls dropped 85% the day after Indian police raided six criminal call centers in Thane, India (see FVRO: How to Stop IRS Impersonation Calls).
• In 2017, robocalling was reduced 50% after the FCC filed civil actions against Adrian Abramovich for sending millions of “neighbor spoofed” vacation and timeshare offer calls (see FVRO: How to Stop Scam Vacation and Timeshare Calls).
• In 2018, a series of raids by local police in and around New Delhi based on tips from the Royal Canadian Mounted Police reduced Canadian Revenue Agency (CRA) impersonation calls 77% (see FVRO: How to Stop CRA Impersonation Calls).
• Beginning in December 2019, health and health insurance related robocalls declined 60% after the FTC obtained a Temporary Restraining Order against a Canadian VoIP provider called Globex Telecom (see FVRO: How to Stop Health Insurance Robocalls).
• Beginning in July 2021, car warranty robocalls declined 95% after the FTC opened an investigation into several telemarketing businesses. The FCC also issued notices to telecom carriers in July 2022 to disconnect a different group of businesses that had been sending car warranty robocalls (see FVRO: How to Stop Car Warranty Robocalls).

     Analysis

The Q3 ITG data contains 1,218 trace records from 972 suspected scam robocalls. These calls were carried by more than 215 voice service providers. Unlike the Q2 2023 data, the Q3 data includes more than more voice service provider for many suspected scam robocalls. The FCC released this in this format data so that both the suspected “Point of Entry” into the US and the suspected originators of calls were included.

It is important to note that the designation of “Point of Entry” (POE), “Originator” (ORG) or “International Originator” (IOR) are subjective determinations manually entered by ITG staff based on their best judgement. Without the cooperation of every phone company that transited a particular call, it may not always be clear where a call originated. For example, the Q3 data shows Deutsche Telekom as the International Originator of nine scam calls.

It is highly unlikely that Deutsche Telekom, the largest phone provider in Europe—and partially owned by the German Government—intentionally sent scam calls to American citizens. It is far more likely that Deutsche Telekom transited scam calls received from multiple, upstream wholesale customers and did not respond to trace requests due to stringent German privacy laws.

In addition, sometimes attempts are made to identify of the sources of calls past the US Point of Entry. Sometimes these attempts are not made. Sometimes ITG staff send trace requests for multiple calls associated with the same the apparent scam source on the same day. This is because call records cannot always be found for specific calls. In other cases, calls from the same source may come from different voice service providers. So it is good practice to trace multiple calls (usually five or ten) during the same trace attempt. Sometimes, however, on single calls from a single suspected source are traced.

In order to show a more accurate and representative picture of sources of scam calls, the below tables represent “Trace Attempts” where duplicate trace requests for the same source (or “Campaign Name”) through the same provider on the same day have been removed.

The Q3 data shows no one voice service provider accounted for a majority of traced calls entering the US. The top Point of Entry accounted for 8% of trace attempts. The top 10 Points of Entry accounted for 50% of trace attempts. 10 of the 15 points of entry are large, established carriers.

The Q3 data shows no one voice service provider accounted for a majority of robocalls. The top Originator or International Originator accounted for 5% of trace attempts. The top 10 Originators or International Originators accounted for 27% of trace attempts.

This information reveals other opportunities for potential future criminal investigations to reduce robocalling.

Of the top ten Originators:

• All registered with the FCC through the Robocall Mitigation Database;
• One registered as a foreign voice service provider;
• Seven registered as US voice service providers yet appear to be located outside the US; and
• Two appear to have registered by means of identity theft using the names and addresses of real people inside the US without those individuals’ knowledge or consent.