FCC Settles Case Against Provider That Transmitted Spoofed AI-Generated Robocalls for Election Interference in New Hampshire

The Federal Communications Commission reached a settlement to resolve its enforcement action against Lingo Telecom, a voice service provider that transmitted spoofed robocalls that used generative AI voice cloning technology to spread disinformation in connection with a presidential primary election in New Hampshire.  The calls were directed by a political consultant named Steve Kramer in an attempt to interfere in the 2024 New Hampshire primary election.  The company will pay a $1 million civil penalty and implement a historic compliance plan—the first of its kind secured by the FCC—that will require strict adherence to the FCC’s STIR/SHAKEN caller ID authentication rules, including requirements that the company abide by “Know Your Customer” (KYC) and “Know Your Upstream Provider” (KYUP) principles—which allows carriers to vet traffic and ensure it is trustworthy—and requirements that the company more thoroughly verify the accuracy of the information provided by its customers and upstream providers. Kramer was indicted in New Hampshire on state charges of felony voter suppression and misdemeanor impersonation of a candidate.  The New Hampshire Department of Justice, Office of the Attorney General is handling that case. In addition to the $1 million civil penalty, Lingo Telecom agrees to, among others, the following KYC and KYUP terms: 

• Applying an A-level attestation, which is the highest level of trust attributed to a phone number, only to a call where Lingo Telecom itself has provided the caller ID number to the party making the call;
• Verifying the identity and line of business of each customer and upstream provider by obtaining independent corroborating records; and
• Transmitting traffic only from upstream providers that have robust robocall mitigation mechanisms in place and are responsive to traceback requests.