It’s great to have Jason Welch on the TADSummit Podcast. He brings an impressive history and highly informed opinion on the reality of KYC, Know Your Customer. It’s easy to assume your opinion of KYC is definitive, Jason will help you understand the reality. There is no KYC.
Johnny has known Jason since he worked with Sam and Kenny Tawfik, here’s a link to Samer’s (Sam) bio. Sam and Kenny founded the Telco group (STi Prepaid), the original calling card company. They were a customer of Jason’s when he worked for Frontier / Global Crossing.
Jason began his career with Rochester Telecom on the Open Market Plan. Rochester Telecom work the with NYPSC (New York State Public Service Commission) which back in 1995 was enabling local competition, a template of what became the 1996 Telecom Act.
Jason worked on the reciprocal local telecom access agreements, contracts between telecommunications carriers that defined how they compensate each other for the cost of carrying traffic to and from their respective networks. Ensuring equal access and non-discriminatory interconnection.
Also during this time dial-up internet access was exploding, AOL was a customer of Time Warner creating a large imbalance of traffic towards TW from Rochester Tel / Frontier. The ratios of traffic became quite important in those agreements. There was quite some gaming between the carriers. Jason highlighted that regulation is the mother of innovation. We see it today in Deepseek, an AI driven to learning efficiency as AI chips were restricted in the Chinese market.
Jason supported Telco Group, meeting their OC48 connection requests. That’s 2.488 gigabits per second (Gbit/s) in the early ’00s, which was rare, and they filled them up with calling card voice traffic.
Jason makes a definitive statement, there is no such thing as KYC. There are lots of opinions, but federally the government has avoided making a regulatory definition. Passing the buck to private enterprise. Resulting in no clear bar, or a solid framework, or safe harbour. Yet the ability to fine companies it deems as inadequate.
There are imbalances between industries, the rules for voice are different to the rules for social media (Section 230). The intent is clear, stop scams and inappropriate calling / content. But the enforcement is applied differently between industries and countries. Remember when Telegram founder and CEO, Pavel Durov was arrested in France. As over Telegram were vast networks of human traffickers.
The Lingo case was a long standing customer, who had a customer that spoofed a number of a fake Biden call. Lingo was caught and fined. Across telecoms there is STIR/SHAKEN, robocall mitigation database, traceback, and KYC. Yet we all experience robocalling every day. It’s clearly not working.
STIR/SHAKEN needs IP interconnect ONLY to reduce the problem. The wholesaling of phone numbers adds complexity and enables spoofing. The lack of end to end identity management for communications is part of the problem. We accept driving licenses and passports for identity management. TSG Global’s TNID is attempting to provide a solution.
A solution needs legislation, regulation, clear bars, and enforcement. Currently it is left to private enterprise, without clear bars, just everyone’s opinion.
On the Telnyx situation, their KYC worked well with the exception of MarioCop’s targeting. Their bad traffic was a low % compared to peers. However, they were targeted. Check out the NAL response, and detailed NAL response document, https://telnyx.com/nal-response-press-release-s3-final.pdf.
In my opinion and Jason’s, Telnyx was setup. Mariocop (the criminal) targeted most ranking people in the FCC and their families. 365 unique phone numbers associated with Commission offices, staff, and former staff. including: Chairman Brendan Carr, Commissioner Nathan Simington, Former Chairman Ajit Pai, Chiefs of staff, legal and policy advisors in the offices of Chairman Carr, former Chairwoman Rosenworcel and former Chairman Pai, and Commissioners Simington, Gomez and Starks, The list goes on. This was not about spamming, it was about targeting Telnyx.
The FCC were victims, judge, and jury. I’d be pissed if my family was targeted. However the FCC should have recused themselves.
Telnyx’ reputation has been damaged. Telnyx’s CEO has received death threats, and Telnyx has lost customers, was suspended from its role as a supporting partner of the ITG, and was placed on probation by the i3Forum.
Sign-up / KYC is a balancing act. Telnyx sign-up is not easy, they’ve sponsored TADHack in the past, they use Sift Science. They avoid mobile numbers as burner phones are commonly used. Accepting BTC for a trial account is unusual, they changed that. But their processes worked up until this targeting against the FCC.
There was a press interview with David Casem, which was published last night and then withdrawn. Let’s see what happens. Paraphrasing Jason, there is no KYC, only your opinion.
