On August 21, 2024, Lingo Telecom, LLC (Lingo) entered a consent decree with the Federal Communications Commission (FCC) related the investigation into Lingo's alleged violations of the “STIR/SHAKEN” rules through Lingo's use of artificial intelligence (AI) to generate voice message. The STIR/SHAKEN is a framework that allows for the authentication and verification of caller identification (ID) information and is designed to protect consumers from illegal spoofed calls. The investigation was prompted by thousands of spoofed robocalls that used a deepfake generative artificial intelligence (AI) voice message to discourage potential voters from participating in the New Hampshire Democratic primary election in 2024. The robocalls carried a fake voice that mimicked the president of the United States and used a caller ID number that belonged to an uninvolved local political operative. Lingo Telecom was the alleged originating provider for some of these calls and signed them with “A-level attestations,” indicating that it had verified the caller ID information and the association with the telephone number. However, according to the FCC, Lingo Telecom did not independently ascertain whether the customers of its upstream provider, Life Corporation, could legitimately use the telephone number that appeared as the calling party for the robocalls.
The consent decree requires Lingo Telecom to implement a compliance plan and pay a $1,000,000 civil penalty in four installments. The compliance plan includes the following obligations: (a) designating a compliance officer with the authority and knowledge to oversee the plan; (b) developing and distributing a compliance manual that explains the STIR/SHAKEN rules and the operating procedures that Lingo Telecom must follow; (c) establishing and implementing a compliance training program for all covered employees; (d) reporting any noncompliance with the STIR/SHAKEN rules or the consent decree within 15 days of discovery; and (e) filing compliance reports with the FCC every 12 months until the termination date of the consent decree, 36 months after the effective date. The operating procedures, which are attached to the consent decree, specify the measures that Lingo Telecom must take to validate the telephone numbers and caller ID information of its customers and upstream providers, and to prevent the acceptance of payment in the form of cryptocurrency, gift cards, or cash for transmitting or originating calls.
The consent decree is intended to serve the public interest by ensuring Lingo Telecom's future compliance with the STIR/SHAKEN rules and by deterring other voice service providers from engaging in similar misconduct. The consent decree also reflects Lingo Telecom's cooperation with the investigation and its acknowledgment of the facts underlying the apparent violations. By entering into the consent decree, Lingo Telecom waives any rights to seek administrative or judicial reconsideration, review, appeal, or stay of the consent decree and the adopting order, and agrees to pay the civil penalty as a debt to the United States Treasury. The consent decree does not prevent the FCC from adjudicating complaints or investigating new evidence of noncompliance by Lingo Telecom with other laws.
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