What it does The Companies certify their prior representations and agree to controls over access to U.S. Records, domestic communications, domestic communications infrastructure, lawful U.S. process, and principal telecommunications equipment. The LOA requires a U.S. law-enforcement point of contact, a U.S.-based security officer eligible for a Secret clearance, personnel screening, CALEA compliance, U.S.-based handling of responsive information, restrictions on foreign access and disclosure, cybersecurity and system-security plans, equipment and service-provider disclosures, incident reporting, annual compliance reports, audits, and DOJ site visits. Equipment and service-provider changes generally require advance notice and DOJ objection or non-objection.

Who it affects The obligations bind Millennium Telcom/OneSource, Ubiquity DFW, and Generate-Ubiquity Holdings, including successors and assigns, and reach their personnel, foreign persons with access, vendors, managed network service providers, and other service providers. DOJ, including the FBI, receives review, approval, objection, and oversight rights, while the FCC’s authorizations remain subject to possible modification or revocation for noncompliance.

Why it matters The agreement illustrates how Team Telecom mitigates risks associated with foreign ownership and control of a U.S. telecommunications authorization holder, particularly access to customer, communications, network, and lawful-intercept information. It also expressly requires reporting concerning covered-list, Entity List, foreign-adversary, and related supply-chain exposure.

Key dates and numbers

• LOA dated October 3, 2023; company signatures are dated October 2, 2023.
• OneSource must report security incidents and material breaches promptly and no later than 48 hours after learning of them.
• Many initial submissions are due within 30 or 60 days after the “Date of FCC Approval”; annual reports begin one year after that date.
• The applications concern Section 214 transfer of control and a Section 310(b)(4) foreign-ownership petition.
• TT 22-062 to -064