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APEX TELECO LLC
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Robocall Mitigation Program Plan and Compliance Attestation
- Company and Role
- Provider: APEX TELECO LLC
- Roles: Voice service provider and gateway provider
- FRN: 0037577814
- Regulatory anchor: 47 CFR § 64.6305; related FCC caller ID authentication and mitigation guidance
- Statement of Commitment
APEX maintains a persistent, multi-layered program designed to prevent illegal robocalls from originating on, or traversing, its network. The program blends authentication, analytics, due diligence, and decisive remediation. - Caller ID Authentication
- STIR/SHAKEN: Deployed on portions of APEX’s IP network; authenticated calls receive appropriate attestation where supported.
- Non-IP/unauthenticated paths: Subject to equivalent mitigation, including risk scoring, number validation, routing controls, and rate limiting.
- Expansion: Ongoing deployment aligned with infrastructure modernization and industry best practices.
- Controls and Procedures
Customer Vetting (KYC)
- Collect and verify government-issued identification (for individuals) or corporate formation documents and tax identifiers (for entities).
- Assess intended use case and expected traffic profile before activation.
Contractual and Policy Prohibitions - Customer agreements and APEX’s Use Policy bar illegal robocalling, spoofing, consent violations, and traffic inflation schemes; require cooperation with investigations and tracebacks.
Number Integrity - Confirm assignment or authorization for all calling numbers; conduct periodic audits and require proof upon request.
Monitoring and Analytics - Daily review of CDRs and signaling for indicators of unlawful or suspicious activity, such as:
- Excessive short-duration ratios or sudden spikes relative to baseline.
- Repetitive sequential dialing patterns, invalid or unassigned ANIs, or adverse reputation signals.
- Utilize third party analytics and reputation services to enhance detection.
Mitigation and Escalation - Initiate investigations promptly on alerts or complaints.
- Apply proportionate measures: warnings, traffic shaping, targeted or route-level blocking, number quarantine, suspension, or termination.
- Maintain case files of findings and actions; refine detection thresholds based on outcomes.
- Utilize third party analytics and reputation services to enhance detection.
- Traceback and Government Cooperation
- 24 hour response target to Industry Traceback Group, FCC, and law enforcement requests.
- Traceback contact: traceback@apexteleco.com
- Take immediate steps to halt identified illegal traffic and prevent recurrence.
- Governance, Training, and Records
- Oversight: APEX assigns compliance ownership to designated personnel empowered to direct operations teams.
- Training: Provisioning/support/NOC staff receive periodic instruction on detecting and handling illegal traffic.
- Records: Maintain KYC, number validation, analytics, and enforcement logs for a commercially reasonable period and as required by law.
- Attestation
APEX attests that all originated and transited calls are subject to this program and that APEX will continue to strengthen controls as regulations and industry guidance evolve.
