Voice termination services in the U.S. refer to the completion of phone calls to the final destination, often using VoIP technology. An AUP for voice termination ensures that the service is used for legitimate, legal purposes and prevents misuse, such as fraud, illegal telemarketing, or other harmful activities.

Prohibited Activities:

• Fraudulent or Unauthorized Use: Prohibiting activities like toll fraud, where calls are made to bypass regular billing systems, or the use of fake caller IDs to deceive the recipient.

• Spam and Robocalls: Any use of the service for unsolicited commercial communications, robocalling, or pre-recorded messages without consent, violating telemarketing laws (e.g., Do-Not-Call laws).

• Illegal Traffic or Calls: Prohibiting any use of the service for illegal activity, including fraudulent or scam calls.

• Call Blocking: Blocking or interfering with legitimate voice traffic is forbidden.

Compliance with Laws:

• Telecommunications Laws: Ensuring compliance with U.S. Federal Communications Commission (FCC) regulations and any relevant state-level rules.

• Truth in Caller ID Act: Ensuring that call IDs are not manipulated to deceive or defraud consumers.

• Federal Telemarketing Regulations: Ensuring that voice services comply with laws like the Telephone Consumer Protection Act (TCPA) and Telemarketing Sales Rule (TSR).

Consequences for Violations:

• Immediate suspension or termination of accounts that engage in prohibited activities.

• Penalties for violating regulatory requirements.

Know Your Customer (KYC)

KYC is a critical compliance practice for service providers to prevent fraud, money laundering, and other illicit activities. For voice termination services, KYC ensures that customers are legitimate and that their activities are transparent and legal.

KYC Requirements:

• Identity Verification: Service providers will require customers to submit proof of identity (e.g., government-issued ID, business registration documents) before accessing services.

• Business Information: If the customer is a business, information such as the business's name, address, and registration details should be collected.

• Usage Intent: Information about the intended use of voice services to ensure the traffic is lawful, such as verifying the business purpose (e.g., customer support, legitimate telemarketing, or international communication).

• Ongoing Monitoring: Service providers may need to monitor account activities regularly, especially for large-scale customers, to detect unusual patterns that could indicate fraud, such as unusually high international call volumes or irregular traffic patterns.

Consequences for Non-Compliance:

• If KYC verification is not provided, the service provider may suspend or deny service until proper verification is completed.

• If discrepancies or fraudulent activities are identified, services will be terminated immediately.

Stopping Bad Traffic

"Bad traffic" refers to illegitimate or malicious voice traffic that can lead to significant issues like fraud, network congestion, and poor service quality. In an AUP, mechanisms to prevent, identify, and block bad traffic are key to maintaining the integrity of the voice termination service.

Types of Bad Traffic:

• Fraudulent Calls: This includes toll fraud, where fraudsters use voice termination services to make unauthorized calls at the expense of the service provider.

• Robocalls: Automated calls that are made without consent, violating telemarketing regulations.

• SIM Box or Gateway Fraud: The use of devices to route international calls to bypass standard rates, resulting in fraudulent call termination.

Measures to Stop Bad Traffic:

• Traffic Analysis and Filtering: Service providers will employ traffic monitoring systems to detect patterns indicative of fraud, such as a high volume of calls from unverified sources or calls that seem to be originating from known fraudsters.

• Blacklist: Maintaining blacklists of known bad actors or fraudulent traffic sources.

• Real-Time Traffic Monitoring: Implementing real-time analytics to identify and block bad traffic immediately as it is detected.

• Call Authentication: Implementing security protocols, such as STIR/SHAKEN (a call authentication framework) to ensure that calls are legitimate and prevent caller ID spoofing.

• Rate Limiting: Preventing excessive or abnormal call volumes from specific accounts, particularly if not previously verified by KYC procedures.

Consequences for Bad Traffic:

• Suspension or Termination of Services: Any account involved in generating bad traffic, fraudulent activities, or violating the AUP will have their access revoked.

• Financial Penalties: Providers may impose fees for traffic that violates AUP guidelines or for failure to comply with KYC requirements.

• Reporting to Authorities: In cases of significant fraud or illegal activity, service providers may be obligated to report the violation to the relevant law enforcement agencies.

Example of Key Clauses in an AUP Document

Prohibited Use of Voice Termination Services:

• "The use of our voice termination services for fraudulent, unlawful, or abusive purposes, including but not limited to toll fraud, caller ID spoofing, robocalling, or unsolicited telemarketing, is strictly prohibited."

Know Your Customer (KYC) Compliance:

• "Customers must provide accurate and truthful identity verification information. Failure to comply with KYC requirements will result in the suspension or termination of services."

Traffic Monitoring and Blocking:

• "We employ advanced traffic monitoring systems to detect and prevent fraudulent and malicious activities, including the blocking of calls originating from unverified sources or patterns indicative of fraud. Customers whose accounts generate 'bad traffic' may be subject to immediate service termination."

Termination of Service:

• "We reserve the right to suspend or terminate your service without notice if we determine that you are using the service for unlawful or prohibited purposes, including the generation of bad traffic, failure to comply with KYC, or violation of federal or state regulations."