All West Communications - Team Telecom mitigation agreement
The signed Letter of Agreement requires All West Communications and its affiliated companies, together with Novacap entities, to implement national-security and law-enforcement safeguards as a condition associated with their proposed transfer of control and foreign-ownership request.
What it does The LOA establishes detailed compliance commitments supervised by the U.S. Department of Justice, including a U.S.-based law-enforcement point of contact, cleared security personnel, personnel screening, lawful-intercept and CALEA compliance, U.S. handling of responsive records, restrictions on foreign access and disclosure, cybersecurity and system-security plans, and controls over principal equipment, service providers, network operations centers, and changes in ownership or services. It requires prompt reporting of security incidents, generally within 48 hours, annual compliance reports, possible third-party audits, and DOJ site visits. The agreement also references FCC Covered List and Commerce Entity List status in equipment and annual-report disclosures.
Who it affects The commitments bind All West, its wholly owned operating subsidiaries, Novacap All West Holdings, and Novacap Management, and extend operational obligations to relevant vendors, managed network providers, contractors, foreign personnel, and service providers.
Why it matters This Team Telecom mitigation agreement protects U.S. customer and network information during review of a transaction involving Section 214 authorizations, FCC licenses, and a request for foreign ownership above the Section 310(b)(4) benchmark. Breach can support FCC modification, conditioning, revocation, cancellation, or termination of relevant authorizations and other remedies.
Key dates and numbers
- The LOA is dated November 13, 2023; company signature blocks are dated November 9 and November 13, 2023.
- Incident and breach reporting is generally due within 48 hours; CPNI incidents must also be reported under 47 C.F.R. § 64.2011 within seven business days after a reasonable determination.
- Many initial plans, lists, and designations are due within 15, 30, or 60 days after the Date of FCC Approval; annual reports begin one year after that date.
- The transaction references Section 214, Section 310(b)(4), and Executive Order 13913.
- TT 23-018 to -020