Voice over Internet Protocol (VoIP) is an innovative and evolving technology that is transforming the telecommunications world. H.323, SIP, and other protocol-based networks can be established quickly and easily, allowing exponential growth opportunities for VoIP entrepreneurs. Further, VoIP offers consumers the benefit of a less expensive alternative to a traditional telephone line, with exciting new features. Because VoIP is not inherently tied to a particular location and often provides access to multiple phone numbers, it provides a level of anonymity that allows subscribers to mask their identities as well as the physical locations. Combine that with free VoIP service offerings, which forego customer screening requirements or established internal controls in lieu of quick profits, and the result is fertile ground for criminal activity. The relative ease of access to and the ability to veil location and identity through VoIP networks provides ample opportunity for misuse and
furtherance of illegitimate goals.
VoIP as a means of communication for criminals has, naturally, drawn the attention of law enforcement. In her June 2004 testimony before the U.S. Senate Committee on Commerce, Science, and Transportation related to a pending VoIP bill, Laura Parsky, Deputy Assistant Attorney General, Criminal Division, at the U.S. Department of Justice stated, I am here to underscore how very important it is that this type of telephone service not become a haven for criminals, terrorists, and spies. She added that any criminal conspiracy requires communication in order to operate, and reminded Congress that how it treats VoIP will profoundly impact the Department of Justices ability to protect communities across the nation from the harms inflicted by drug trafficking, organized crime, and terrorism, and to fundamentally protect the national security of the United States.
An example that underscores the potential for misuse of a VoIP network is the ability of end users wishing to remain anonymous to use a proxy service to communicate covertly. To the outside world, because the call likely will never hit the public switched telephone network, it will appear that the callers are not talking to each other. Perhaps more importantly, it will appear as though no call was ever placed. In an effort to thwart this misuse, the federal government recently provided a research grant to George Mason University to develop an application that allows law enforcement to track these calls and identify the participants.
Law enforcement officials also will soon be able to turn to the 1994 Communications Assistance for Law Enforcement Act (CALEA), which requires telecommunications carriers and manufacturers of telecommunications equipment to ensure that their equipment, facilities, and services allow law enforcement agencies to conduct necessary surveillance. On September 23, 2005, the Federal Communications Commission released a First Report and Order, in which it concluded that interconnected VoIP service providers are, in fact, telecommunications carriers and, as such, are subject to regulations and terms of CALEA. By Spring 2007, law enforcement agencies will be able to enforce CALEA and require interconnected VoIP service providers to assist them with the intercept and delivery of communications and call identifying information transmitted via VoIP.
Until that time, however, there are additional proactive steps that VoIP providers canand shouldtake to remain vigilant about detecting illegal uses of VoIP. Network security is a good place to start. In fact, many VOIP providers offer encryption as a selling
feature to their customers. IP PBXs and IP Networks themselves, if not properly protected, can be hacked, allowing individuals to make calls purporting to originate from the hacked customers location. In addition to encryption, other options include prohibiting connections in your network from hosts other than those attributed to your customers and implementing an authorization process that requires an IP address or username/password combination to permit access to the network.
Familiarity with customers and their intended use of your network is also advisable. Simple prudence and observation can go a long way in helping to defeat, or at least discourage, individuals engaging in terrorism or other forms of criminal activity.
What customer behavior scenarios might raise a red flag?
The easy saleRegardless of the obstacles that might be presented during negotiations, the prospective customer raises no issues and presses forward, wising to complete the transactions as quickly as possible. This customer may have no problem with large up-front payments (sometimes in cash) or same-day wires.
No follow up communication from the customerIf you offer a pre-paid VoIP service, you might sell multiple accounts to customers that have no need to follow up with you once they have used up all of the minutes and have disposed of their service related equipment.
Usage patterns VoIP providers should be aware of typical traffic termination patterns originating from their networks through the review of call detail records (CDRs) pursuant to general business practices. A sharp traffic boost to an international destinationparticularly one recognized by the U.S. Department of State as a one that has repeatedly provided support for terrorist activitymay, in conjunction with other factors, be a telling sign. CDRs likely served as a valuable tool for federal investigators when determining, post-9/11, that the hijackers used hundreds of payphones, cell phones, and pre-paid calling cards to conceal their communications.
What should you do if you are suspicious? This question raises several issues of personal and corporate responsibility, and is fraught with privacy and legal considerations. Until CALEA compliance is upon us, retaining records pursuant to your companys data retention policy is worth exploring with your legal counsel, along with cooperation with law enforcement. While VOIP providers are not policemen, they do share a common sense obligation to do what they can to assist in curbing the misuse of VoIP networks in an effort to keep our country safe. IT
Richard Koch is president of RNK Telecom. For information visit www.rnktel.com.