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IXICA is committed to protecting private health information.
IXICA understands the importance of protecting confidential information, particularly when it involves patient records and other sensitive healthcare documents. Our secure online fax service is designed to support HIPAA-compliant faxing when used with the appropriate service configuration, contractual arrangements and customer safeguards.
The service incorporates administrative, physical and technical safeguards designed to protect the confidentiality, integrity and availability of fax information. These include authenticated access, encrypted web connections, application security, firewalls and optional PGP encryption for supported email delivery.
HIPAA and Business Associate Arrangements
The Health Insurance Portability and Accountability Act (HIPAA) establishes requirements for protecting health information in applicable U.S. healthcare settings. A Business Associate is generally a person or organization that creates, receives, maintains or transmits protected health information on behalf of a covered entity or another Business Associate. Depending on the services provided and how they are used, IXICA may act as a Business Associate.
Customers intending to use IXICA’s online fax service for protected health information must confirm the appropriate service configuration and ensure that any required Business Associate Agreement is in place before transmitting that information.
This notice describes the safeguards supporting the service. It does not replace a required Business Associate Agreement or remove the customer’s responsibility to comply with the requirements applicable to its own operations.
User Authentication
Access to the online fax portal requires valid account credentials. Login information and communications between the user’s browser and the portal are protected through encrypted HTTPS connections.
Customers should keep their credentials confidential, restrict account access to authorized users and protect any email accounts used to send or receive faxes.
Application Security
Application-level access controls are designed to keep customer accounts separate and prevent unauthorized access to another customer’s fax documents or account information. These controls apply throughout an authenticated user session.
Organizational Safeguards
Access to the production environment supporting IXICA’s online fax service is restricted to authorized personnel whose responsibilities require it, including system administration, maintenance, monitoring and backup operations.
The fax-processing environment is protected by access restrictions intended to limit exposure of confidential information and prevent unauthorized access to the systems used to deliver the service.
Physical Safeguards
The production infrastructure supporting the service is housed in secure data centre facilities with 24-hour physical security, redundant electrical power and backup equipment.
These safeguards are designed to protect the equipment used to process customer faxes and support reliable service operation.
Network and Operating System Security
The fax platform uses multiple firewalls, intrusion-detection systems and security monitoring to help identify potential threats. Firewall logs are reviewed to support the detection of suspicious activity.
Access to production servers is restricted. Operating systems are maintained with security updates and hardened by disabling or removing unnecessary accounts, protocols and processes.
Reliability and Backup
The fax platform uses redundant networking, server and storage infrastructure to reduce the risk of service interruption.
Database replication and backup processes support service continuity and recovery. These measures are designed to reduce the impact of equipment failures and other operational disruptions.
Fax Retention and No-Storage Options
Where supported and enabled on the customer’s account, automatic-deletion settings allow fax content to be removed after delivery or retrieval. These settings help reduce the amount of sensitive information retained within the fax service.
Fax-content deletion and transmission-record retention are separate considerations. Customers should confirm the scope and timing of deletion, including any applicable backup retention, before relying on a no-storage configuration. Deleting content from the fax service does not delete copies already delivered to email inboxes, downloaded to devices or printed by recipients.
Optional PGP Email Encryption
Where available and enabled, PGP encryption provides an additional layer of protection for supported fax email notifications.
A PGP public key is configured for each applicable email address. Notifications are encrypted using that public key before delivery, and the recipient uses compatible software and the corresponding private key to decrypt them.
This protection applies to the configured email delivery. It should not be interpreted as a guarantee that every stage of a fax transmission, every recipient system or every stored copy is encrypted.
Tips for Safer Faxing
- Confirm the recipient and fax number. Before sending, verify that the destination number is correct and belongs to the intended recipient.
- Check the receiving environment. Ensure that the recipient has appropriate measures in place to prevent unauthorized access to electronic or printed fax documents.
- Use a confidentiality cover sheet. Clearly identify the sender and intended recipient. Include a confidentiality notice explaining that the fax is intended only for the named recipient and asking anyone who receives it in error to notify the sender. Avoid including unnecessary health information on the cover sheet.
Customer Responsibilities
Secure faxing depends on both the service’s safeguards and the customer’s practices. Customers remain responsible for assessing their risks, authorizing access, securing their devices and email systems, selecting appropriate retention settings and ensuring that staff handle confidential information appropriately.
The service’s security features support these responsibilities but do not, on their own, make an organization HIPAA-compliant.
For questions about IXICA’s online fax service, available security options or healthcare-related service requirements, please contact IXICA.
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What are SMS and voice call scams?
SMS scams, often called smishing, are fake text messages designed to make you click a link, call a number, download something, or share personal information. Voice call scams, often called vishing, use phone calls or voicemails to impersonate trusted people or organizations. Scammers may pretend to be your bank, tax agency, delivery company, government office, police, tech support, or even a family member. The Canadian Centre for Cyber Security describes smishing as phishing through text messages, and CISA warns that caller ID can be spoofed, meaning a call can appear to come from a trusted number even when it does not.
What are common warning signs?
Be careful if a message or call:
- Creates urgency: “Act now,” “Your account will be locked,” “You owe money today.”
- Asks you to click a link to “verify” your account.
- Requests passwords, PINs, one-time codes, SIN, SSN, banking details, or credit card numbers.
- Tells you to pay using gift cards, cryptocurrency, wire transfer, or payment apps.
- Threatens arrest, legal action, account suspension, or deportation.
- Claims to be a family member in trouble and asks for secrecy.
- Sounds slightly “off,” even if the number or voice seems familiar.
Can caller ID or text sender names be trusted?
No. Scammers can spoof phone numbers and sender names to make a call or text look like it came from a bank, tax agency, government department, or someone you know. Treat caller ID as a clue, not proof. CISA specifically warns that VoIP technology can allow caller identity to be spoofed.
What should I do if I receive a suspicious text?
Do not click links, reply, or call numbers provided in the message. Instead, go directly to the organization’s official website or app, or call the number printed on your bank card, statement, or official government website. Delete the message after reporting it if appropriate.
What should I do if I receive a suspicious call?
Hang up. Do not press buttons, confirm personal details, or stay on the line to “explain.” Call the organization back using a verified phone number from its official website, your bank card, or your account portal. For family emergency calls, hang up and contact the person directly using a number you already know.
Will banks or tax agencies ask for passwords or one-time codes?
Legitimate organizations may need to verify your identity, but they should not ask for your full password, full PIN, one-time security code, or remote access to your device. Never share one-time passcodes. A scammer can use them to break into your account in real time.
What about calls claiming to be from the CRA or IRS?
Be skeptical of unexpected tax-related calls, texts, or emails, especially if they threaten immediate arrest, demand unusual payment methods, or ask for sensitive information. The Canada Revenue Agency provides scam guidance and directs Canadians to report fraud to the Canadian Anti-Fraud Centre. In the U.S., suspected scams can be reported through the FTC’s fraud reporting site.
What if the caller sounds like a family member?
Scammers can impersonate relatives or friends, and AI-generated voices are making this easier. Use a family “safe word” or ask a question only the real person would know. Then hang up and call them back directly. Do not send money based only on a phone call, voicemail, or text.
What should I do if I clicked a link or shared information?
Act quickly:
- Change passwords for affected accounts.
- Contact your bank or credit card provider if financial information was involved.
- Enable multi-factor authentication where possible.
- Watch for unauthorized transactions.
- Report the scam.
- If your SIN or SSN was exposed, follow identity theft guidance from your government and credit bureaus.
Where should I report scams?
In Canada, report fraud or attempted fraud to the Canadian Anti-Fraud Centre. The CAFC encourages reporting even if you did not lose money.
In the United States, report fraud, scams, and unwanted calls to the Federal Trade Commission at ReportFraud.ftc.gov. The FTC uses reports to help investigate scams and provide next steps to victims.
What is the safest rule to remember?
Stop, verify, then act.
Do not trust a message, link, caller ID, or urgent request on its own. Use a trusted contact method you already know, and never let pressure force you into sharing information or sending money.
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Toll fraud is the unauthorized or fraudulent use of a phone system or voice service to place calls, usually to expensive destinations.
Modern IP-based phone systems, including PBX systems, SIP trunks, hosted phone systems, softphones, and voicemail platforms, can be targeted by attackers if they are not properly secured.
Fraudsters do not need physical access to your office, phones, or PBX. Most toll fraud is performed remotely over the internet by scanning for exposed systems, weak passwords, unsecured SIP credentials, vulnerable PBX software, open administration portals, or misconfigured calling features.
If your PBX, SIP account, extension, or voicemail system is compromised, unauthorized calls may be placed through your IXICA account. These calls can result in significant charges in a very short period of time.
Why do fraudsters target phone systems?
Fraudsters target phone systems because they can generate expensive call traffic without paying for it themselves.
A typical toll fraud incident works like this:
- The attacker gains access to a PBX, SIP account, extension, voicemail system, or admin portal.
- The attacker places calls to expensive destinations, premium routes, or revenue-sharing numbers.
- The calls are billed through the customer’s account.
- The customer is responsible for the charges.
- The fraudster or an associated party may benefit from the traffic.
Toll fraud often happens after hours, on weekends, or during holidays, when suspicious traffic may not be noticed right away.
How serious is telecom fraud?
Telecom fraud is a major global issue. The Communications Fraud Control Association, or CFCA, reported that telecom fraud losses reached an estimated $38.95 billion USD in 2023, representing approximately 2.5% of global telecommunications revenues.
PBX hacking, compromised SIP credentials, voicemail abuse, international revenue-share fraud, and unauthorized call forwarding are all common forms of telecom fraud.
Who is responsible for fraudulent calls?
As the account holder, you are responsible for all calls made through your account, including calls generated by a compromised PBX, SIP device, extension, voicemail system, softphone, or SIP credential.
IXICA’s network security team may use monitoring, fraud detection, and traffic controls to help identify or reduce suspicious activity where possible. However, no provider can guarantee that all fraud will be detected or stopped before charges occur.
Customer-side PBX security remains the customer’s responsibility.
IXICA’s Business Terms of Service are available at:
Can IXICA prevent all toll fraud?
No. No carrier or service provider can guarantee complete toll fraud prevention.
Fraud detection systems may help identify unusual traffic, but they are not a substitute for proper PBX security. In many cases, fraudulent calls may already have occurred before the traffic is detected.
The best protection is prevention, including strong passwords, firewall restrictions, updated software, secure SIP configuration, limited call permissions, and regular monitoring of call activity.
How do attackers usually gain access?
Common causes of toll fraud include:
- Weak SIP extension passwords
- Weak PBX administrator passwords
- Default usernames and passwords
- Exposed PBX web administration portals
- Exposed SSH, HTTP, HTTPS, SIP, or management ports
- Publicly reachable SIP registration without IP restrictions
- Old or unsupported PBX software
- Missing security patches
- Compromised remote extensions
- Insecure softphones
- Misconfigured firewalls
- Voicemail systems that allow outbound calling
- DISA or call-through features
- Stolen SIP credentials
- Malware on a computer used to manage the PBX
- Former employees or vendors retaining access
- Poorly secured call forwarding features
Most attacks are automated. Attackers scan the internet looking for vulnerable PBX systems and then attempt to exploit them.
What are the most important PBX security steps?
Customers should review PBX security with their IT provider or PBX administrator. The following best practices are strongly recommended.
Firewall and Network Security
- Place the PBX behind a properly configured firewall.
- Do not expose PBX administration portals directly to the public internet.
- Restrict web, SSH, and admin access to trusted IP addresses only.
- Allow SIP traffic only from required trusted IP addresses where possible.
- Use VPN access for remote administration.
- Monitor SIP traffic for scanning or brute-force attempts.
- Use tools such as fail2ban or equivalent intrusion-prevention tools where supported.
- Disable unused ports and services.
- Review firewall rules regularly.
A network-enabled PBX that is directly exposed to the internet is at much higher risk of compromise.
Password and Account Security
- Do not use default extension numbers as passwords.
- Do not use default PBX administrator passwords.
- Use strong, unique passwords for every SIP extension.
- Use strong, unique passwords for every administrator account.
- Avoid simple numeric passwords for voicemail.
- Do not make voicemail PINs the same as extension numbers.
- Require users to change voicemail PINs periodically.
- Remove unused extensions.
- Remove unused voicemail boxes.
- Disable generic or shared authorization codes.
- Deactivate accounts immediately when employees leave.
- Change passwords after staff changes, vendor changes, or suspected compromise.
Passwords should be long, random, and not based on names, extension numbers, company names, phone numbers, or dictionary words.
Calling Permission Controls
Each extension should only have the calling permissions it actually needs.
For example:
- Lobby phones may only need internal or local calling.
- Fax lines may not need long-distance access.
- Warehouse phones may not need international calling.
- Conference room phones may need restricted access.
- Remote extensions should have tighter controls.
- Executive and sales users may need broader access but should still be monitored.
Restricting calling permissions reduces the damage if an extension is compromised.
Should international calling be blocked?
If international calling is not required, it should be blocked.
If international calling is required, consider:
- Allowing only approved countries.
- Blocking all countries not used by the business.
- Requiring authorization codes for international calls.
- Limiting international access to specific extensions.
- Restricting international calling after hours.
- Setting call spending limits where available.
- Monitoring international call activity closely.
Do not leave international calling open by default unless there is a clear business need.
What PBX features create fraud risk?
Certain PBX features can create serious toll fraud exposure if they are not secured.
Review and restrict the following:
- DISA, meaning Direct Inward System Access
- Voicemail callback
- Call-through features
- Trunk-to-trunk transfer
- External call forwarding
- After-hours forwarding
- Remote extension registration
- Unrestricted outbound routes
- Shared authorization codes
- Old or hidden call forwarding rules
- Admin access from public IP addresses
If you do not use these features, disable them.
Why is voicemail a toll fraud risk?
Voicemail systems can be abused if they allow users to call out, return calls, or access external dialing features.
Attackers may try to guess voicemail PINs and then use voicemail menus to place outbound calls.
To reduce this risk:
- Disable outbound calling from voicemail unless required.
- Require strong voicemail PINs.
- Do not use the extension number as the voicemail PIN.
- Limit failed login attempts.
- Lock voicemail access after repeated failed attempts.
- Delete unused voicemail boxes.
- Change voicemail PINs when employees leave.
- Audit voicemail settings regularly.
What should be done when an employee leaves?
When an employee leaves the company, remove their access immediately.
This should include:
- Disabling their PBX extension if no longer needed.
- Changing or deleting their voicemail box.
- Removing PBX admin access.
- Removing VPN access.
- Removing softphone access.
- Removing email access tied to PBX administration.
- Changing shared passwords they may have known.
- Reviewing call forwarding rules.
- Reviewing authorization codes.
Employee offboarding should include phone system access, not just email and computer access.
What is social engineering?
Social engineering is when an attacker tricks someone into revealing confidential information or making a security change.
For example, an attacker may pretend to be:
- A carrier technician
- A PBX vendor
- A customer
- An employee
- A manager
- A support provider
- A telecom repair agent
They may ask for passwords, SIP credentials, admin access, call forwarding changes, or system details.
Staff should never provide PBX access, passwords, SIP credentials, customer information, or system details unless they are certain they are dealing with an authorized person.
What warning signs may indicate toll fraud?
Possible warning signs include:
- Unexpected international calls
- Calls to countries your business does not normally call
- Calls to Caribbean or high-cost
+1destinations - Calls outside business hours
- Many short calls in a row
- Many calls to the same destination
- A sudden increase in usage
- High simultaneous call volume
- Calls from extensions that should not be active
- Calls from unknown IP addresses
- Unusual call forwarding activity
- Reports that trunks or channels are busy unexpectedly
- Unusual failed login attempts
- Unknown extensions, routes, or forwarding rules in the PBX
If you see any of these signs, treat it as urgent.
What should I do if I suspect toll fraud?
If you suspect toll fraud, act immediately.
Recommended steps:
- Disable international calling if it is not required.
- Disable suspicious extensions.
- Reset all SIP passwords.
- Reset all PBX administrator passwords.
- Disable public PBX admin access.
- Review firewall rules.
- Block unknown IP addresses.
- Review call detail records.
- Review all outbound routes.
- Review voicemail callback and DISA features.
- Review call forwarding settings.
- Check for unknown users, extensions, trunks, and routes.
- Contact your IT provider or PBX administrator.
- Open a ticket with IXICA support.
Do not wait. Toll fraud can continue until the point of compromise is closed.
If my PBX was hacked, is changing the password enough?
Not always.
If the PBX web interface or operating system has been compromised, simply changing passwords may not be enough. Attackers may have added hidden users, forwarding rules, backdoors, scripts, or database changes.
In serious cases, the safest approach may be to rebuild the PBX from a trusted backup or reinstall the system, then apply all security updates and change all passwords.
If you suspect a full system compromise, consult a qualified PBX or security professional.
Are Canada and U.S. long-distance calls always included?
Most retail accounts provided by IXICA include Canada and U.S. long-distance calling, subject to the terms of the specific call plan.
However, some destinations that appear to be part of the same +1 dialing format may be excluded or rated differently.
A number beginning with 1 is not automatically included in standard Canada or continental U.S. calling. The North American Numbering Plan includes Canada, the United States, U.S. territories, and several Caribbean countries and territories under country code +1.
Which Canada and U.S. destinations may be rated differently?
Some Canada and U.S. destinations may not be included in standard Canada/U.S. retail calling plans or may carry higher rates.
Common examples include:
| Area Code | Destination |
|---|---|
| 808 | Hawaii |
| 867 | Yukon, Northwest Territories, and Nunavut |
| 907 | Alaska |
These destinations should not be assumed to rate the same as standard Canada or continental U.S. calls.
Why are Caribbean and territory numbers a toll fraud risk?
Many Caribbean countries and U.S. territories use the same +1-NPA-NXX-XXXX dialing format as Canada and the United States. This can make the numbers look like ordinary North American numbers.
However, many of these destinations are rated separately and may be excluded from standard Canada/U.S. included calling plans.
This creates a fraud risk because attackers may place high volumes of calls to expensive +1 destinations that appear domestic at first glance.
Common +1 destinations that may be rated differently
The following area codes may be rated differently from standard Canada or continental U.S. calling. Customers should confirm rates before allowing these destinations.
| Area Code | Destination |
|---|---|
| 242 | Bahamas |
| 246 | Barbados |
| 264 | Anguilla |
| 268 | Antigua and Barbuda |
| 284 | British Virgin Islands |
| 340 | U.S. Virgin Islands |
| 345 | Cayman Islands |
| 441 | Bermuda |
| 473 | Grenada |
| 649 | Turks and Caicos Islands |
| 664 | Montserrat |
| 670 | Northern Mariana Islands |
| 671 | Guam |
| 684 | American Samoa |
| 721 | Sint Maarten |
| 758 | Saint Lucia |
| 767 | Dominica |
| 784 | Saint Vincent and the Grenadines |
| 787 / 939 | Puerto Rico |
| 809 / 829 / 849 | Dominican Republic |
| 868 | Trinidad and Tobago |
| 869 | Saint Kitts and Nevis |
| 876 | Jamaica |
These should not be described as “non-NANPA” destinations. A better description is:
These are
+1numbering-plan destinations that may be rated differently from standard Canada and continental U.S. calling and may not be included in your call plan.
Should I block high-cost destinations?
If your business does not need to call certain destinations, you should restrict them.
At minimum, consider restricting:
- International calling
- Premium-rate destinations
- Caribbean
+1destinations - Alaska, Hawaii, and Canadian territories if not required
- Any country or area code not normally used by your business
- After-hours long-distance calling
- Long-distance access from extensions that do not need it
Blocking unnecessary destinations is one of the most effective ways to reduce toll fraud exposure.
What should I ask my IT provider or PBX administrator to review?
Ask your IT provider or PBX administrator to review:
- SIP password strength
- PBX admin password strength
- Firewall rules
- Public internet exposure
- Allowed SIP source IPs
- PBX software version and security patches
- International calling permissions
- Caribbean and high-cost destination permissions
- After-hours calling rules
- Maximum call duration settings
- Concurrent call limits
- Voicemail callback permissions
- DISA or call-through features
- Remote extension security
- Unknown extensions or users
- Unknown forwarding rules
- Trunk-to-trunk transfer settings
- Call detail records for unusual traffic
- Employee offboarding procedures
- Billing or usage notification settings
What information should I provide when opening a fraud-related ticket?
If you believe your account has been compromised or you see suspicious usage, please include:
- The affected SIP account
- The date and time the suspicious calls started
- Example destination numbers
- Example call times
- Any affected extensions
- Whether the PBX is hosted on-site or in the cloud
- Whether the PBX admin portal is reachable from the public internet
- Whether SIP access is restricted by IP
- Whether any passwords were recently changed
- Whether international calling is required
- Whether any employees or vendors recently left
- Any recent PBX, firewall, routing, or remote access changes
This information helps IXICA and your IT provider identify the likely source of compromise and reduce further exposure.
Summary
Toll fraud is the unauthorized use of your phone system or voice account to place calls, often to expensive destinations. It is usually performed remotely and can result in significant charges very quickly.
Customers are responsible for all calls made through their account, including calls caused by compromised PBX systems, extensions, SIP credentials, voicemail boxes, or insecure configurations.
IXICA may help detect and reduce suspicious activity where possible, but PBX security is ultimately the customer’s responsibility.
To reduce risk, secure your PBX, use strong passwords, restrict public access, block unnecessary destinations, limit calling permissions, disable risky features, and monitor call activity regularly.
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Purpose
This document provides a standardized framework for Resale and Wholesale providers to properly vet their customers, prevent fraudulent usage, and maintain compliance with industry regulations (FCC, ITG traceback requirements, STIR/SHAKEN ecosystem expectations).
1. Core Principle
As a Resale and Wholesale provider, you are an origin point of trust into the PSTN ecosystem.
You are responsible for ensuring:
- Your customers are legitimate
- Their call activity aligns with their stated business use
- Caller ID usage is accurate and authorized
Failure to enforce these controls can result in:
- Call blocking or spam labeling
- Upstream carrier suspension
- Regulatory exposure (ITG / FCC)
2. Mandatory Customer Verification (KYC)
2.1 Business Verification
Collect and validate:
- Legal business name
- Registration/incorporation number
- Country/state of registration
Verification steps:
- Confirm active status in government registry
- Ensure business age aligns with claimed scale
Red Flags:
- Recently incorporated entity with high call volume expectations
- No verifiable registration
2.2 Identity Verification
Collect for key individuals:
- Full name (owners, directors, primary contact)
- Corporate email address
Enhanced verification (high-risk customers):
- Government-issued ID
Red Flags:
- No professional presence (LinkedIn, website, etc.)
- Use of anonymous or generic identities
2.3 Address Verification
Require:
- Physical business address (no PO boxes)
Validate using:
- Google Maps / Street View
- Cross-reference with business filings and website
Red Flags:
- Virtual office or co-working space used for high-volume operations
2.4 Domain & Email Validation
Check:
- Domain ownership and age
- Email domain alignment with company name
Red Flags:
- Recently registered domain
- Use of free email services for business operations (e.g., Gmail)
3. Business Use Case Validation
You must clearly understand how your customer intends to use the service.
Required Information:
- Type of service (PBX, call center, notifications, etc.)
- Expected call volume (CPS, concurrent calls)
- Inbound vs outbound ratio
- Geographic destinations
Validation Logic:
| Use Case | Expected Behavior |
|---|---|
| SMB PBX | Low volume, local calling |
| Resale and Wholesale | Mixed inbound/outbound |
| Call center | High volume, outbound heavy |
| Notifications | Short duration, burst traffic |
Red Flag: Behavior that does not match declared use case
4. Caller ID (CLI) Control Policy
Requirements:
- Only allow authorized and verifiable caller IDs
Acceptable Sources:
- Numbers assigned by your upstream carrier
- Verified BYOC numbers (with proof of ownership)
Verification Methods:
- Letter of Authorization (LOA)
- Carrier portal screenshots
- Number lookup consistency (LRN/CNAM)
Strictly Prohibited:
- Arbitrary or dynamic caller ID spoofing
Impact:
- Non-compliance leads to STIR/SHAKEN attestation downgrade (B/C)
- Increased likelihood of call blocking
5. Payment & Financial Validation
Ensure payment legitimacy:
- Verified billing method
- Matching billing and business information
Red Flags:
- Prepaid-only high-volume usage
- Cryptocurrency-only payments
- Geographic mismatch between billing and operations
6. Risk-Based Customer Classification
Assign a risk level at onboarding:
Low Risk
- Established businesses
- Predictable traffic patterns
Medium Risk
- New Resale and Wholesale providers
- Resellers
High Risk
- Call centers
- Lead generation
- International outbound operations
Apply stricter controls as risk increases.
7. Pre-Activation Testing Phase
Before granting full access:
Apply Limits:
- Low CPS (e.g., 1–2 CPS)
- Restricted destinations
- Limited concurrent calls
Monitor:
- Call duration patterns
- Call success rates (ASR/ACD)
- CLI usage consistency
Purpose:
- Detect fraud before full-scale activation
8. Ongoing Monitoring (Continuous Compliance)
8.1 Traffic Monitoring
Track:
- Sudden spikes in call volume
- High short-duration call ratios
- Sequential dialing patterns
8.2 Destination Monitoring
Identify:
- High-risk destinations
- Toll-free abuse
- Repeated failed call attempts
8.3 Reputation Monitoring
Watch for:
- Traceback requests (ITG)
- Carrier complaints
- Spam labeling indicators
9. Enforcement & Mitigation Controls
Define automated thresholds and actions:
Enforcement Steps:
- Alert customer
- Rate limit traffic
- Block specific numbers or patterns
- Suspend services
- Terminate account
Immediate action is required for:
- Fraudulent robocalling
- CLI spoofing
- Regulatory complaints
10. Traceback (ITG) Readiness
You must be able to:
- Identify the originating end user
- Provide accurate call records
- Respond within 24 hours
Required Data Retention:
- Call Detail Records (CDRs)
- Customer identity records
- IP/trunk mappings
Failure to respond adequately may result in:
- Upstream carrier blocking
- Regulatory escalation
11. Contractual Requirements
Your customer agreements must include:
- Prohibition of spoofing
- Mandatory cooperation with traceback investigations
- Immediate suspension rights for abuse
12. Final Compliance Checklist
Before activating any customer:
- Business verified
- Identity verified
- Address validated
- Use case documented
- Caller ID ownership confirmed
- Payment method verified
- Risk level assigned
- Test phase completed
13. Multi-Tenant Resale Risk (Downstream Customers)
Resale and wholesale customers often operate multi-tenant environments, where they provide services to their own downstream customers. This introduces additional layers of risk that must be actively managed.
13.1 Downstream Customer Accountability
You must:
- Maintain records of all downstream customers
- Be able to map traffic to a specific end customer or tenant
- Provide this information upon request (e.g., traceback requests)
Unacceptable Practice:
- Allowing anonymous or untraceable end users
13.2 Downstream KYC Requirements
You are required to implement KYC procedures for your own customers, including:
- Business verification
- Identity validation
- Use case documentation
These controls should mirror the requirements outlined in this document.
13.3 Tenant-Level Controls
Implement per-tenant restrictions:
- Caller ID authorization per tenant
- Rate limits (CPS, concurrent calls)
- Destination restrictions where appropriate
This prevents a single bad actor from impacting your entire network.
13.4 Traffic Segmentation
Where possible:
- Separate tenants by trunk, IP, or logical routing
- Maintain visibility at the tenant level in CDRs
This enables faster identification and isolation of abusive traffic.
13.5 Abuse Handling and Escalation
You must be able to:
- Quickly identify the responsible downstream tenant
- Suspend or restrict that tenant without affecting others
Repeated abuse from downstream customers must result in:
- Stronger controls
- Potential termination of the tenant relationship
13.6 Traceback Readiness (Multi-Tenant Context)
In the event of an ITG traceback request, you must:
- Identify the specific downstream customer responsible
- Provide supporting call data
- Take immediate corrective action
Failure to identify the originating tenant is considered a compliance failure.
Summary
Effective fraud prevention requires a layered approach:
- Identity verification
- Business validation
- Technical enforcement
- Continuous monitoring
By implementing these controls, you ensure:
- Network integrity
- Regulatory compliance
- High call completion and trust levels
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