So jus ta couple of days ago I had the CEO of YouMail (Alex Quilici) and the CEO of Telnyx (David Casem) on stage at the Law Conference of Champions talking American telecom. It was an incredibly well-received panel with tons of comments and questions.
One of the items we touched upon was ITG responses by carriers– the requirement to respond to traceback inquiries within 24 hours.
The requirement has been on the books for a couple of years now without any enforcement activity on it– until last month when SK Teleco became the first company to face a potential shutdown order due to a failure to respond to ITG tickets.
In IN THE MATTER OF SK TELECO LLC, 2026 WL 1210685 (F.C.C.), EB-TCD-24-00036937, EB Docket No. 22-174 DA 26-384 Released: April 20, 2026 Adopted: April 20, 2026 the Commission determined as follows:
By this Initial Determination Order, the Enforcement Bureau (Bureau) issues its initial determination that SK Teleco LLC (SK Teleco or Company) has not complied with section 64.1200(n)(1) of the Federal Communications Commission’s (Commission or FCC) rules, which require all voice service providers to respond to a traceback request within 24 hours of receipt of that request.
This Initial Determination Order follows the Bureau’s December 2, 2025 Notification of Suspected Illegal Traffic and Robocall Mitigation Database Filing Deficiencies (SK Teleco Notice or Notice), which identified suspected illegal traffic that the Company was originating and instructed SK Teleco to investigate the traffic, block the traffic unless it determined that it had not originated the traffic or the traffic was not illegal, and provide a report to the Bureau within 14 days. 2 The Notice also required SK Teleco to respond fully to 16 traceback requests from USTelecom’s Industry Traceback Group (ITG). 3 SK Teleco responded to the Notice on December 3, 2025, and December 10, 2025, but the Company did not provide a sufficient response to the Notice. 4
As a result, SK Teleco is not in compliance with section 64.1200(n) of the Commission’s rules. 5 Pursuant to section 64.1200(n)(2)(ii) of the Commission’s rules, SK Teleco now has 14 days to respond to this Initial Determination Order with a final response to the Bureau’s apparent finding and to demonstrate compliance with the Commission’s rules. 6
If SK Teleco fails to provide an adequate response within 14 days or continues to originate or allow onto the U.S. network substantially similar illegal traffic, the Bureau will issue a Final Determination Order. 7 Any provider immediately downstream from SK Teleco will then be required to block and cease accepting all traffic received directly from SK Teleco beginning 30 calendar days after release of the Final Determination Order.
That last piece is important. If SK Teleco doesn’t come into compliance the Commission may issue a “shutdown order” effectively banning intermediary or terminating carriers from accepting traffic from it.
I.E. R.I.P. SK Teleco.
Couple of take aways for carriers here:
- Remember the ITG now has tremendous power and you MUST respond to traceback requests within 24 hours;
- CPaaS solutions and voice service providers should make sure they have clear lines of sight to client/customer consent records so that they can obtain those records quickly where they are the point of entry;
- All carriers should now have WRITTEN policies around KYC, auditing and ITG response. If you don’t call Troutman Amin, LLP immediately and we can help you out.
Feels weird to not promote LCOC at the end of this post… soon enough, I suppose.
Much love.
Chat soon.