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Acceptable Use Policy (AUP)

Company: United States Telecommunications Corporation (USTelco)

Address: 300 New Jersey Avenue NW, Suite 300, Washington, DC 20001

Issued by: Office of the Chief Compliance Officer

Effective Date: April 10, 2025

Applies to: All VoIP, SIP, SMS, UCaaS, CCaaS, and BYOC clients, partners, and suppliers (collectively, “Clients” or “Customers”)

Contact: [email protected]

1. Purpose

This Acceptable Use Policy (“AUP”) sets forth the rules and obligations governing the use of USTelco’s voice and messaging services by Clients. USTelco is committed to combating illegal robocalls, spam texts, and other abusive communications in compliance with applicable laws and industry standards. The purpose of this AUP is to ensure that all use of USTelco’s Voice over IP (VoIP), Session Initiation Protocol (SIP) trunking, Short Message Service (SMS), Unified Communications as a Service (UCaaS), Contact Center as a Service (CCaaS), and Bring Your Own Carrier (BYOC) services is lawful, authorized, and consistent with Federal Communications Commission (FCC) regulations, including USTelco’s own Robocall Mitigation Plan and mandates under the Telephone Consumer Protection Act (TCPA), the Truth in Caller ID Act, and other relevant rules.

This Policy is issued by USTelco’s Office of the Chief Compliance Officer and is effective as of April 10, 2025. It applies to all Clients, partners, and suppliers utilizing USTelco’s telecommunications services. All Clients are required to review this AUP and adhere to its terms as a condition of their Master Service Agreement (MSA) or Carrier Service Agreement (CSA) with USTelco. USTelco’s goal is to facilitate secure, reliable, and legal communications, and this AUP explains permitted uses, prohibited conduct, compliance requirements, and enforcement mechanisms designed to achieve that goal. USTelco reserves the right to update or modify this AUP as needed to address evolving legal requirements or network security concerns (see Section 7, Changes to the AUP). By using USTelco’s services, Clients acknowledge and agree to be bound by the terms of this AUP.

2. Permitted Use

USTelco’s services are to be used only for legitimate, lawful communications in accordance with the Client’s service agreement and all applicable laws and regulations. Permitted use of the voice and SMS services includes, for example, business and organizational communications such as:

  • Informational and Transactional Calls or Texts: Routine calls or messages to customers or members who have provided their contact information for specific purposes (e.g. appointment reminders, account notifications, two-factor authentication codes, customer support calls). These communications must be made with any required consent and in a manner that complies with privacy and telemarketing laws.
  • Marketing or Promotional Communications (with Consent): Telemarketing calls or marketing text campaigns are allowed only to recipients who have given prior express written consent where required by law (for instance, consent under the TCPA for automated or pre-recorded calls to cellular phones). All such campaigns must honor opt-out requests and comply with Do-Not-Call rules.
  • Emergency or Critical Notifications: When properly authorized, Clients may use the services for important public service announcements or emergency alerts (e.g. school closing alerts, critical safety information), provided these are delivered in compliance with applicable laws and with appropriate recipient consent or as otherwise permitted by law.

All use of USTelco’s network must conform to industry best practices and standards of fairness, decency, and transparency. Clients are expected to adhere to the CTIA Messaging Principles and Best Practices for text messaging and to use voice services in a manner that would not surprise or deceive call recipients. Caller identification information must be truthful, and any required identifying disclosures in calls or messages (such as identifying the caller’s business name in a pre-recorded message) must be provided.

Use of the services in any manner that is inconsistent with the intended purpose of the service or that violates the terms of this AUP or the Client’s MSA/CSA is not permitted. If there is any uncertainty as to whether a particular use is allowed, Clients should seek guidance from USTelco (at [email protected]) before proceeding. In all cases, lawful and responsible use of USTelco’s voice and messaging services is required.

3. Prohibited Use

Clients and their end users are strictly prohibited from using USTelco’s services in any way that is illegal, abusive, fraudulent, or in violation of this Policy. Prohibited uses include, but are not limited to, the activities described below. These prohibitions apply both to voice call traffic and SMS/MMS messaging traffic, as applicable.

3.1 Prohibited Call Traffic

Clients shall not use USTelco’s voice services to originate, transmit, or facilitate any voice calls that fall into any of the following categories:

  • Illegal Robocalls & Unlawful Telemarketing: Any call that violates the Telephone Consumer Protection Act (TCPA) or other telemarketing laws and regulations. This includes calls made using an automatic telephone dialing system or an artificial/prerecorded voice without obtaining the requisite prior consent from the called party, as well as any telemarketing call to a residential or wireless number on the National Do Not Call Registry without an applicable exception. Calls must comply with all federal and state Do Not Call (DNC) list restrictions, calling time limitations (e.g. no marketing calls outside permitted hours), and identification requirements mandated by the FCC and Federal Trade Commission (FTC).
  • Caller ID Spoofing and Misrepresentation: It is strictly prohibited to falsify or misrepresent caller identification information with the intent to defraud, cause harm, or wrongfully obtain anything of value. Clients may not transmit any call with an inaccurate or misleading caller ID (spoofing) for unlawful purposes. All calls must comply with the Truth in Caller ID Act and FCC regulations (47 C.F.R. § 64.1600 et seq.) which prohibit spoofing of caller ID information in a harmful or fraudulent manner. Using a number as caller ID that the Client does not own or have legitimate authority to use is expressly forbidden. USTelco implements STIR/SHAKEN caller ID authentication standards on its network; any attempt to circumvent these authentication measures or to send calls that cannot be properly authenticated (e.g., by using unauthorized numbers) is a violation of this AUP.
  • Harassing or Unlawful Calls: Using the service to make calls that are harassing, threatening, abusive, obscene, or intended to stalk, intimidate or mislead the called party is prohibited. This includes calls that contain obscene or profane language, calls made with the intent to annoy or harass the recipient, and any calls that violate applicable anti-harassment or privacy laws.
  • Emergency Service and Critical Lines Abuse: Any use of automated or bulk calling to emergency lines (e.g. 911, police or fire department lines, hospital or healthcare facility lines) or to other protected numbers (such as cellular phones, pagers, or specialized telecommunications devices) without proper authorization is prohibited. The TCPA and other regulations forbid using auto-dialers to engage sequential or excessive dialing of such numbers. Clients must not knowingly transmit calls that disrupt public safety answering points (PSAPs) or emergency communication systems.
  • Fraudulent Schemes & Call Pumping: Engaging in schemes to generate traffic for illicit purposes or financial gain, such as one-ring callback scams (Wangiri scams where calls disconnect after one ring to induce a callback), or traffic pumping/access stimulation schemes designed to inflate call volumes to high-cost numbers, is prohibited. Likewise, any use of the service to impersonate or represent oneself as another individual, business, or government agency in order to deceive (for example, “IRS” or law enforcement impersonation calls) is strictly forbidden.
  • Unlawful Content via Voice: It is a violation of this AUP to use USTelco’s voice services to transmit content that is illegal or violates the rights of others. This includes, for instance, calls used to facilitate gambling operations in jurisdictions where it is illegal, calls that solicit or promote child exploitation, or calls providing content that is defamatory or infringes intellectual property rights. Clients are also prohibited from using the service for any calls that would result in USTelco’s network being used to commit or further any criminal offense.
  • Violation of Carrier or Network Standards: Any calling practices that violate generally accepted telecommunications industry rules or USTelco’s underlying carrier agreements are not allowed. For example, deliberately short-duration calls or continuous repetitive calling that appears intended to jam networks or exploit telecom settlement systems is prohibited. Clients should not engage in dialing patterns that could be interpreted as denial-of-service attacks or other forms of network abuse. USTelco also prohibits the initiation of calls to numbers on any official Do-Not-Originate (DNO) list, which includes numbers that should never originate traffic (such as IRS taxpayer assistance lines, etc.), as these are commonly used for spoofing scams.

In summary, any voice call usage that is unlawful, fraudulent, or could harm consumers or networks will be deemed a prohibited use of USTelco’s services. USTelco will actively monitor and mitigate such call traffic as described in Section 5 (Enforcement & Remediation).

3.2 Prohibited SMS/Messaging Traffic

Clients shall not use USTelco’s SMS or MMS messaging services (including any texting via long codes, short codes, or messaging APIs) for any of the following:

  • Unsolicited Messages and Spam: Sending text messages (SMS or MMS) to any recipient without the recipient’s explicit consent is prohibited. All messaging must be opt-in – the recipient must knowingly agree to receive messages of the type being sent. It is impermissible to send bulk or marketing messages to phone numbers obtained through purchasing lists, web scraping, or other methods that lack direct opt-in from the recipient. Unsolicited commercial messages, propaganda, or mass texting of random or sequential numbers are considered spam and are not allowed. This includes practices like “snowshoeing,” where a sender spreads messages over many telephone numbers or short codes to evade volume or spam detection limits.
  • Failure to Honor Opt-Out/Stop Requests: Every application-to-person (A2P) messaging campaign must allow recipients to opt out. If a message recipient texts “STOP”, “UNSUBSCRIBE”, or any commonly recognized opt-out keyword, the Client must immediately cease sending messages to that recipient (except for a final confirmation of the opt-out). Failing to honor opt-out requests or not providing a clear and accessible method for recipients to withdraw consent is a serious violation of this Policy and of industry standards. Clients must also periodically monitor and scrub their contact lists against opt-out records.
  • Prohibited Content Categories: USTelco prohibits the transmission of certain types of content via its messaging services. Clients may not send messages containing illegal, harmful, or offensive content, including but not limited to:
    • Obscene or Pornographic Content: Any texts including sexually explicit content, pornography, or illicit sexual solicitations.
    • Hate Speech or Harassment: Content that is hateful, defamatory, or encourages violence or discrimination against any individual or group based on race, religion, ethnicity, gender, sexual orientation, or other protected characteristics. Harassing messages targeting private individuals are likewise forbidden.
    • Fraudulent or Deceptive Messages: Any form of phishing (fraudulent attempts to obtain personal information), smishing (SMS phishing), or messages that mislead recipients about their origin (e.g., pretending to be a bank or government agency without authorization). This includes messages seeking to defraud recipients, such as prize scams or impersonation of known companies to solicit passwords or money.
    • Illegal Substances or Activities: Promotion of the sale or use of illicit drugs, controlled substances, or related paraphernalia is prohibited. Additionally, messages facilitating or promoting criminal activities, terrorism, or illicit trade (e.g., human trafficking, illegal firearms sales) are banned.
    • Regulated or High-Risk Offerings: Certain legal but high-risk content categories are subject to strict scrutiny or prohibition by carriers. Clients may not use standard SMS channels for content related to illegal gambling, illicit adult services, or other activities that, while possibly legal in some jurisdictions, violate carrier content rules. For example, firearms, alcohol, or tobacco-related marketing may be disallowed, especially when targeting underage persons. Financial scam content – such as get-rich-quick schemes, debt relief offers, payday loan advertisements, or credit repair services – is prohibited. Investment opportunities, cryptocurrency promotions, and pyramid or multi-level marketing messages are similarly banned or tightly regulated due to their high abuse potential.
    • Spam and Malware: Any messages that contain malware, viruses, or malicious links intended to harm recipients’ devices or steal information are strictly forbidden. Likewise, mass messaging of unsolicited links (URL spam) is not allowed. Messages must not knowingly direct recipients to fraudulent or misleading websites.
    • Emergency or Government Impersonation: Clients must not send messages falsely purporting to be from emergency services, law enforcement, or other authorities (e.g., false Amber Alerts, fake COVID-19 information from “CDC,” etc.). Impersonating legitimate organizations to alarm or mislead the public via text is not only prohibited by this AUP but may also violate laws.
  • Non-Compliance with 10DLC Requirements: USTelco requires compliance with all 10DLC (10-Digit Long Code) A2P messaging regulations and carrier policies. All Clients sending A2P SMS or MMS using long codes in the United States must register their messaging campaigns (and the associated brand information) through the designated registration system (e.g. The Campaign Registry) in accordance with carrier requirements. It is prohibited to send unregistered A2P traffic on 10DLC routes or to provide false information during the 10DLC registration process. Clients must adhere to all volume, throughput, and content restrictions imposed as part of 10DLC campaign approval. Any attempt to evade 10DLC rules – for example, rotating through pools of phone numbers to avoid campaign registration or throughput limits – is a violation of this Policy. USTelco and the mobile network operators may block or heavily filter messages that are not properly registered or that violate carrier spam guidelines, and any fines or penalties assessed by carriers for such violations will be passed on to the responsible Client.
  • Violation of CTIA and Carrier Guidelines: In addition to the above, Clients must not use the messaging service in any way that fails to conform to the CTIA’s Messaging Principles and Best Practices, the CTIA Short Code Monitoring Handbook, or any other applicable wireless industry guidelines. Content that is prohibited or controlled under those guidelines (for instance, unsolicited loan offers, certain types of sweepstakes, or SHAFT content – sex, hate, alcohol, firearms, tobacco – in marketing messages) must be strictly avoided unless clearly permitted and properly age-gated or otherwise in compliance. Shared short codes (sending unrelated campaigns over the same short code) are disallowed by carriers and therefore by USTelco, except where explicitly grandfathered or approved. Clients are expected to follow all “commercial best practices” for messaging, including proper formatting of help/stop instructions in messages, respecting frequency limits communicated to users, and ensuring that any affiliate marketers or third parties sending messages on Client’s behalf also comply with this AUP.

In summary, any SMS/MMS traffic that is unsolicited, malicious, fraudulent, or violates consumer protection laws or industry guidelines is prohibited. USTelco and its underlying carriers actively monitor messaging traffic, and detected violations will result in enforcement action as outlined in Section 5.

4. Compliance Obligations

All Clients are responsible for understanding and complying with the laws, regulations, and standards applicable to their use of USTelco’s services. By using the services, Clients agree to the following ongoing compliance obligations:

  • Compliance with Law: Clients must at all times use USTelco services in compliance with all applicable laws and regulations. This includes, but is not limited to, the Telephone Consumer Protection Act (47 U.S.C. § 227) and its implementing regulations (47 C.F.R. § 64.1200 et seq.) which govern telemarketing calls and texts, the Telemarketing Sales Rule (16 C.F.R. Part 310) enforced by the FTC, the CAN-SPAM Act (15 U.S.C. § 7701 et seq., as applicable to commercial electronic messages), the Truth in Caller ID Act (47 U.S.C. § 227(e)), state laws regarding telemarketing and text messaging, and any regulations or orders issued by the FCC or other regulatory bodies concerning communications. It is the Client’s responsibility to stay informed of legal requirements; compliance with this AUP does not excuse any failure to abide by the law. Where laws differ by jurisdiction (federal, state, local), the strictest applicable rules should be followed.
  • Consent and Recipient Permissions: Prior to initiating any call or text, the Client must obtain and document all necessary consents or authorizations from the intended recipients as required by law and industry best practices. For example, if the Client is sending marketing text messages, it should have prior express written consent from each recipient (as defined by the TCPA for automated marketing) on record. For automated or pre-recorded calls to wireless numbers or residential lines, the appropriate form of consent must be secured. Clients should also maintain internal do-not-call (DNC) lists and honor any direct requests from recipients not to be contacted, in addition to scrubbing marketing contact lists against the National Do Not Call Registry where applicable. Adequate record-keeping systems should be in place so that proof of consent can be provided if a complaint arises. USTelco may request evidence of consent for specific campaigns or calls/messages if a compliance issue is brought to our attention, and Clients are expected to promptly furnish such proof upon request.
  • Know Your Customer/Business (KYC/KYB) Information: Clients are required to participate in USTelco’s KYC/KYB onboarding protocols. This means Clients must provide accurate and current information about their identity, business, designated authorized users, and nature of service usage when establishing service and upon USTelco’s reasonable request. USTelco may require documentation such as corporate formation documents, identification of account administrators or end users, physical address, federal tax ID or other government-issued identification, and information about the Client’s intended use case for voice or messaging services. This information is used to verify the legitimacy of Clients and enable compliance measures such as STIR/SHAKEN attestation at the appropriate level. Clients have a continuing obligation to update USTelco if any of their provided information changes (for example, a change in ownership, or using new phone numbers for different purposes than initially described). USTelco reserves the right to decline or terminate service if a Client fails KYC/KYB verification, provides false or misleading information, or refuses to furnish information required to meet regulatory obligations (such as responses needed for the FCC’s Robocall Mitigation Database filings or carrier 10DLC registrations).
  • Use of Assigned Numbers and Caller Identification: Clients must use only those telephone numbers for caller ID or message origination that have been assigned to them by USTelco or properly ported to USTelco for their use, or for which they have documented permission from the number’s owner. Using USTelco’s service to transmit traffic with a caller ID that is unauthorized or spoofed is prohibited (as per Section 3.1). USTelco participates in the STIR/SHAKEN caller ID authentication framework as mandated by FCC regulations. In line with these standards, USTelco will sign and attest to the authenticity of Client call traffic based on the level of trust established (Attestation A, B, or C). Clients are expected to cooperate in this process by providing any needed information to verify number ownership or usage authority. If USTelco determines that a Client has not been “fully verified” or has not “identified its end user customer,” a lower attestation level may be assigned to that Client’s calls (which could affect call completion and labeling). Clients must not attempt to circumvent STIR/SHAKEN signing or verification. USTelco may block or refuse to carry calls that cannot be appropriately attested or that fail authentication in a manner suggesting illegal spoofing.
  • 10DLC Campaign Registration and Messaging Compliance: As noted in Section 3.2, any Client utilizing A2P messaging via 10-digit long codes in the U.S. is required to register their campaigns through the official process (e.g., The Campaign Registry) before sending live traffic. Clients must provide truthful and complete information about the message content, category, sample messages, opt-in method, etc., as part of registration. If a campaign is rejected or requires modification, the Client must resolve those issues and obtain approval prior to sending messages. Clients are also responsible for paying any applicable 10DLC registration fees or messaging surcharges imposed by carriers for their campaigns. Once a campaign is active, the Client must adhere to the use case and content submitted; any material change may necessitate re-registration or update. Furthermore, Clients must follow CTIA and carrier guidelines in operation of their campaigns, including sending required initial disclosure messages (for recurring programs, the first message must typically include the program name, frequency of messages, and opt-out instructions), and maintaining low complaint rates. USTelco may request periodic auditing of the Client’s messaging program (such as proof of opt-in records or content samples) to ensure ongoing compliance. Failure to comply with 10DLC requirements or messaging best practices not only violates this AUP but can result in carriers suspending the Client’s messaging capabilities or levying substantial fines, for which the Client will be responsible.
  • Cooperation with Robocall Mitigation and Tracebacks: USTelco has filed a Robocall Mitigation Plan with the FCC and participates in industry efforts to trace and stop illegal calls. Clients are required to cooperate fully and promptly with any efforts by USTelco, law enforcement. If USTelco receives a traceback request indicating that suspected illegal robocalls or spam texts have originated from the Client’s account or phone numbers, the Client must respond in a timely manner with complete and accurate information about the traffic in question. This may include providing the identity of the party on whose behalf the calls or texts were made, proof of consent from called/texted parties, or other details. Generally, traceback requests should be answered within 24 hours or within any specified deadline given by authorities. By using USTelco’s services, Clients acknowledge and agree that USTelco may share relevant Customer information and traffic data with the FCC, FTC, law enforcement agencies. Such information sharing will be done in accordance with USTelco’s privacy policy and applicable confidentiality laws, but to the extent allowed, USTelco will not hesitate to assist in identifying and blocking sources of illegal communications. Refusal to cooperate with a legitimate traceback or investigation is grounds for immediate service suspension or termination.
  • Network Security and Integrity: Clients must implement reasonable security measures to prevent unauthorized use of USTelco services. For example, SIP credentials, API keys, portal logins, and other access credentials provided by USTelco should be safeguarded and not shared beyond authorized personnel. If a Client uses an on-premises PBX or server, it should be secured against hacking (e.g., strong passwords, IP access control, and up-to-date software) to prevent it from being taken over to send robocalls or spam. The Client should also monitor its account for any sudden or abnormal usage that could indicate a security breach. If the Client suspects that its account or equipment has been compromised (for instance, experiencing a burst of traffic that was not initiated by the Client, or noticing fraudulent charges or calls), it must immediately notify USTelco so that protective measures can be taken (see Section 6, Reporting Suspicious Activity). Clients are further prohibited from interfering with USTelco’s network security measures or testing the vulnerability of USTelco’s systems, except with prior written authorization for legitimate security research purposes.
  • Responsibility for End Users and Third Parties: If a Client re‑brands, resells, or provides USTelco’s services to third-party end users (for example, a partner integrating USTelco’s SIP trunking into their own product offering, or a corporate client allowing its affiliates to use the service), the Client is responsible for ensuring that any such end users or downstream customers also comply with this AUP. The Client must incorporate equivalent use restrictions in its agreements with those parties and promptly enforce any violations. In the event that an end user of the Client engages in conduct that would violate this AUP, USTelco may take action against the Client’s account as if the Client had committed the violation. Therefore, Clients should screen and monitor their users’ activities and educate them on compliance. Know Your Customer’s Customer (KYCC): USTelco expects Clients to know and vouch for the identities and reputations of any sub-clients or traffic sources they introduce. Passing through traffic from unknown or unvetted sources is a violation of this obligation.

By adhering to the above compliance requirements, Clients help USTelco maintain a trusted network environment and avoid service interruptions. USTelco stands ready to assist Clients in understanding these obligations and implementing compliant solutions. However, ultimate responsibility for legal compliance in using the services rests with the Client. Any breach of these obligations will be addressed under Section 5 (Enforcement & Remediation) and could also constitute a material breach of the Client’s contract with USTelco.

5. Enforcement & Remediation

To protect its network, customers, and the public from harm, USTelco enforces this AUP vigorously. Violation of this AUP may result in immediate remedial action by USTelco, up to and including suspension or termination of services. USTelco reserves the right to act unilaterally and without prior notice (if necessary) in response to prohibited conduct, though it will attempt to provide advance warning when reasonably possible. The following enforcement measures and remedies are incorporated into this Policy:

  • Monitoring and Filtering: USTelco may monitor traffic on its network and systems (in compliance with applicable privacy laws) to detect violations of this AUP. This can include the use of automated systems to scan for patterns consistent with robocalling, high spam SMS volumes, or other abuse indicators. USTelco may also deploy call analytics and third-party spam detection services to identify potentially illegal calls or texts. While USTelco does not routinely eavesdrop on call content or read message content, it reserves the right to investigate the content of communications if needed to determine whether a violation has occurred (for example, reviewing a sample of messages for CAN-SPAM compliance when investigating a spam complaint). All monitoring and filtering will be conducted in accordance with USTelco’s obligations under the law (including CPNI regulations and wiretap laws). Clients acknowledge that USTelco and/or downstream carriers may block or tag (e.g., label as “Spam Likely”) communications suspected to be unlawful or unwanted, and such actions are taken in good faith to mitigate abuse. USTelco does not guarantee that all offending traffic will be detected or stopped, and conversely, legitimate traffic may on rare occasions be erroneously flagged by automated systems; nonetheless, USTelco’s good faith efforts to filter harm are a condition of providing service and no warranty is provided that all legitimate communications will always be delivered.
  • Suspension of Service: If USTelco becomes aware of a violation of this AUP (either through its own monitoring, a third-party complaint, or a notice from law enforcement), USTelco may immediately suspend the Client’s offending service(s) as needed to halt the violation. Suspension might be limited to certain phone numbers, specific high-risk services (for example, outbound calling while allowing 911 or inbound calls), or in severe or unresponsive cases, the Client’s entire account. USTelco will make efforts to notify the Client of the suspension and the nature of the suspected violation promptly (via email or phone call to the contact on file), but in emergencies or if the notice would impede an investigation, prior notice may not be given. Service restoration is at USTelco’s discretion and may require the Client to demonstrate that the root cause of the violation has been addressed (such as stopping a spam campaign, implementing new opt-in procedures, or identifying and removing a rogue user on their side). Repeated violations or egregious conduct may result in permanent termination rather than temporary suspension.
  • Termination of Service: USTelco reserves the right to terminate the Client’s services for cause if the Client materially violates this AUP or fails to promptly cooperate in remediation. Particularly serious violations – for example, use of the service for illegal robocall operations, sustained spam campaigns, or any activity that puts USTelco at risk of legal liability or reputational harm – may result in termination without the opportunity for reinstatement. Termination for AUP violations is considered a breach of the MSA/CSA, and USTelco may pursue any remedies available under contract or law, including recovery of fees for the remaining contract term (if applicable) or damages caused by the violation. USTelco shall not be liable to the Client for any loss of business or damages resulting from a termination or suspension in accordance with this AUP, as the Client’s own misconduct or violation will be the cause of such action.
  • Blocking and Rate Limiting: USTelco may directly block or restrict specific traffic as an immediate protective measure. This can include:
    • Blocking Specific Numbers or Codes: USTelco may block calls to or from particular telephone numbers or area codes that are known sources or targets of fraud (such as numbers on a Do-Not-Originate list or high-cost premium numbers involved in traffic pumping). For messaging, USTelco may block SMS to particular short codes or long codes that have been blacklisted by carriers.
    • Traffic Rate Limiting: If a Client’s call or message volumes trigger thresholds suggestive of abuse (e.g. exceedingly high calls-per-second or messages-per-second rates far outside the norm for the type of service), USTelco may throttle the traffic (reduce the allowed rate) to mitigate potential network congestion or spam blasts. Such rate limiting might be applied while investigating the cause of the traffic spike.
    • Content-based Filtering: In coordination with downstream carriers, USTelco may filter or drop communications that contain disallowed content (for instance, messages containing known phishing URLs or profanity to short code programs that forbid it). For voice, USTelco may utilize call analytics that block calls likely to be illegal (e.g., calls with spoofed IRS caller IDs or matching patterns of known scam campaigns). Clients should be aware that carriers are now required by the FCC to block certain blatantly illegal calls (like those purporting to be from numbers that do not or cannot make outgoing calls), so some calls may be blocked upstream as part of industry-wide efforts.
  • Incident Investigation and Remediation Plans: Upon detecting a violation, USTelco may initiate an investigation and will typically reach out to the Client for information. The Client is expected to cooperate fully in such investigations, providing logs, records, and responsive explanations as appropriate. USTelco may require the Client to implement a remediation plan to prevent future violations. Such a plan could include actions like: re-training of staff on calling/texting practices, tightening of opt-in processes, obtaining proper consent for marketing, filtering the Client’s outbound contact lists, enhanced monitoring or use of captcha on web forms to prevent fraudulent number collection, etc. USTelco will work with the Client in good faith to establish reasonable measures. Failure by the Client to participate in or implement an adequate remediation plan can result in suspension or termination of service.
  • Financial Liability and Indemnification: Clients who violate this AUP may incur financial liability. Many carriers and regulatory agencies impose fines or penalty fees for unwanted traffic – for instance, mobile carriers may assess substantial fines for spam texts or unregistered 10DLC traffic, and the TRACED Act allows the FCC to levy heavy fines for illegal robocalls. Clients will be responsible for any such fines or charges that are attributable to their violations. USTelco may charge these amounts directly to the Client’s account or invoice, and the Client shall pay them promptly. Furthermore, as a condition of service, the Client agrees to indemnify and hold USTelco harmless from any third-party claims, government actions, or legal proceedings that arise out of the Client’s breach of this AUP or violation of law using USTelco’s services. This means if USTelco is sued or investigated due to the Client’s wrongful conduct (e.g., a lawsuit under TCPA because of the Client’s telemarketing practices), the Client will cover all losses, penalties, and legal costs incurred by USTelco. Such indemnification supplements any similar provisions in the MSA/CSA.
  • No Waiver: USTelco’s enforcement of this Policy is at its discretion. Any failure of USTelco to enforce any aspect of this AUP in a particular situation does not constitute a waiver of USTelco’s right to enforce it in the future. All determinations of violations will be made by USTelco in its reasonable discretion, considering the facts and circumstances of each incident. The examples of prohibited conduct in this AUP are not exhaustive, and conduct that is not specifically listed but that is similar in nature to the examples or that has the same detrimental effect on consumers, networks, or legal compliance will also be considered a violation.

USTelco aims to enforce this AUP in a fair and consistent manner, focusing on stopping abusive behavior while respecting legitimate use. Clients are encouraged to be proactive and transparent with USTelco if they believe their use might trigger any compliance flags – often, mitigations can be implemented to allow legitimate campaigns to proceed without issues. Ultimately, maintaining the integrity of communications and the trust of call recipients and message recipients is paramount; therefore, USTelco will take all necessary actions to remediate any use of its services that runs contrary to these objectives.

6. Reporting Suspicious Activity

Maintaining a spam-free and fraud-free communications environment is a shared responsibility. USTelco expects its Clients to immediately report any suspected violation or security issue related to its services. The following outlines how Clients and others can report problems and what steps should be taken:

  • Client’s Duty to Report: If a Client becomes aware of any activity on its account or use of USTelco’s network that may violate this AUP or applicable law, the Client must promptly notify USTelco’s Compliance Team. Examples include discovering that your employee or sub-customer is making illegal telemarketing calls, finding out that your API credentials have been misused to send unauthorized messages, or receiving consumer complaints or regulatory notices (e.g., an FCC citation) regarding your communications practices. Early reporting may help prevent escalation and allow for cooperative resolution. Clients should send reports of suspected misuse to [email protected] (or another contact method designated by USTelco for abuse reports), and include as much detail as possible (e.g. phone numbers involved, call/message examples, timestamps, and the nature of the suspected abuse).
  • Reporting Received Spam/Abuse: Parties who are not Clients (for example, members of the public who believe they received an illegal call or text from a USTelco-provisioned number) may also report such incidents to USTelco. USTelco will accept complaints or reports at [email protected] or via a web form if provided on our website. These reports should ideally include the calling number or texting number, the content of the call or message (if a voicemail or text is available), and the date/time of the incident. USTelco will investigate all credible reports and take appropriate action under this AUP.
  • Internal Review and Response: Upon receiving a report of suspicious activity, USTelco will log the report and may acknowledge receipt to the reporting party. USTelco’s compliance personnel will then investigate the issue, which may involve analyzing network logs, contacting the Client for clarification, and potentially suspending relevant traffic if the evidence indicates ongoing abuse. USTelco may also reach out to the reporting party for any follow-up information. Clients are expected to cooperate in any such investigation (as noted in Section 5). If a Client proactively reports their own incident (for instance, a compromised PBX that made calls), USTelco will work with the Client on next steps to secure the system and prevent recurrence, rather than immediately resorting to punitive measures, our primary interest is stopping the unwanted traffic and addressing the cause.
  • Whistleblower Protection: USTelco policy prohibits retaliating against any employee or Client personnel who in good faith reports a suspected violation of this AUP or any law (even if it turns out no violation occurred). We encourage a culture of compliance, and that includes raising concerns without fear of repercussions. Clients should similarly encourage their staff to escalate potential issues up the chain.
  • External Reporting: Clients are hereby informed that they may also file complaints about unwanted calls or texts with regulatory agencies such as the FCC or FTC. USTelco participates in these processes and will respond to such external reports with the information needed to trace and mitigate illegal traffic. It is in the Client’s interest to self-report problems to USTelco first, as we may be able to resolve the issue before it draws regulatory scrutiny.

In summary, if you see something, say something. Timely reporting of suspicious or malicious activity can significantly reduce harm and help maintain the integrity of USTelco’s network. USTelco values cooperation from Clients in identifying and stamping out abuse. All reports can be sent to [email protected] or the designated abuse point of contact, and may be submitted 24/7. USTelco will treat reported information with confidentiality and will only use it for purposes of enforcement and remediation.

7. Changes to the AUP

Regulatory requirements and industry practices in the telecommunications sector are continually evolving (for example, new FCC orders, updates to 10DLC rules, etc.), and USTelco must adapt its policies accordingly. USTelco therefore reserves the right to modify or update this Acceptable Use Policy at any time. Any changes will be made in good faith to further the objectives of this Policy or to comply with new legal mandates.

When material changes to the AUP are made, USTelco will provide reasonable notice to Clients. Notification may occur by various means, including: (a) posting the updated AUP on USTelco’s official website (with a new effective date), (b) sending an email announcement or service bulletin to the primary administrative contacts of Clients, or (c) other electronic notice via the USTelco customer portal. The notice will indicate the effective date of the modifications. Continued use of the services after the effective date of any revised AUP will constitute acceptance of the changes by the Client. If a Client objects to any update, its sole remedy is to cease using the affected services and, if applicable, terminate the service contract pursuant to its terms (subject to any early termination liabilities), in consultation with USTelco.

We encourage Clients to review the AUP periodically to ensure they remain in compliance, especially when they receive notice of an update. USTelco will typically archive previous versions of the AUP or maintain a change log to document what changes were made and when. If any change is required by law or a regulatory authority and immediate implementation is needed, USTelco may not be able to provide advanced notice, but will still post the updated Policy as soon as practicable.

No single or partial exercise of any right, power, or privilege under this AUP by USTelco shall preclude any other or further exercise of that or any other right, power, or privilege. In other words, updates or leniencies in certain aspects of this Policy do not waive USTelco’s right to enforce strict compliance in others. This AUP, as updated, forms part of the agreement between USTelco and the Client regarding acceptable use of the services, and it is incorporated by reference into the MSA/CSA or equivalent service contract.

In the event of any conflict between this AUP and any other policy or agreement (for example, a separate Privacy Policy or the general Terms and Conditions), the provisions of this AUP will govern with respect to acceptable use and conduct, except to the extent that the other document expressly overrides the AUP on a specific issue. USTelco’s determination on such matters will be final. We appreciate our Clients’ understanding and cooperation with any changes, as they are often driven by the need to address new threats or legal requirements in the telecom landscape.

8. Acknowledgment

By signing the service agreement or using USTelco’s services, the Client acknowledges that it has read and understood this Call and SMS Traffic Acceptable Use Policy and agrees to be bound by its terms. The Client further acknowledges that this AUP is a material part of the agreement with USTelco and that compliance with this AUP is required for the continued provision of services. The Client’s signature on the MSA, CSA, or any other service order or contract documentation shall be deemed to also constitute signature and acceptance of this AUP, as of the Effective Date noted above.

Clients must ensure that all relevant personnel – including employees, agents, contractors, or any third parties who are authorized to use USTelco’s services on the Client’s behalf – are made aware of this AUP and agree to comply with it. Ignorance of the Policy will not excuse non-compliance. USTelco recommends that Clients incorporate internal policies or training to reinforce the requirements of this AUP, particularly for teams involved in marketing, customer outreach, or telecom infrastructure management.

In addition, the Client understands that USTelco may require a formal acknowledgment (electronically or in writing) of this AUP (or any updated version) from time to time. This could be in the form of an addendum to the service agreement or a click-through acknowledgment via the USTelco user portal. Refusal to acknowledge or agree to this AUP or any updated AUP may result in USTelco’s inability to provide or continue service. If a Client has any questions about the AUP or its application to their use case, they should contact USTelco’s compliance department at the contact information provided.

Finally, by accepting this AUP, the Client also acknowledges USTelco’s commitment to compliance and enforcement. The Client agrees that USTelco, in enforcing this AUP, may take actions that could temporarily impact the Client’s service (such as blocking suspected spam) and that, as long as such actions are taken in good faith to enforce this AUP and applicable laws, the Client will not hold USTelco liable for those actions. The Client accepts that compliance is a shared responsibility and pledges to do its part in adhering to both the letter and spirit of this Acceptable Use Policy.

This Acceptable Use Policy is issued by USTelco’s Office of the Chief Compliance Officer as of April 10, 2025. It is intended to be a comprehensive guide to permissible and impermissible uses of USTelco’s services and is to be read in conjunction with the Client’s service agreement. By implementing and following this Policy, Clients help ensure a safer and more trustworthy communications ecosystem for everyone.