NGN ICS Anti-FAS Policy

1. Purpose

False Answer Supervision (“FAS”)—also known as False Answer Signaling—occurs when a call is reported as “answered” (and therefore billable) before it is actually connected to the called party or interactive media. FAS is a form of telecom fraud that inflates traffic statistics, erodes customer trust, and exposes carriers to legal and financial risk. This Policy codifies NGN ICS’s zero-tolerance stance toward FAS and applies to every interconnect partner (“Supplier”) and all their upstream and downstream affiliates.

2. Scope

  • Who is covered: All voice and messaging Suppliers, including their agents, resellers, and affiliates, that terminate or transit traffic through the NGN ICS network.
  • Where it applies: Every route, switch, point-of-presence (POP), and signaling path used to deliver traffic to or from NGN ICS, worldwide.
  • Obligations survive termination: All representations, warranties, and liabilities relating to FAS survive any disconnection or contract termination. (In other words, a Supplier’s responsibility for FAS does not end when the partnership or contract ends.)

3. Policy Statement

  • Zero Tolerance: NGN ICS strictly prohibits FAS in any form.
  • Material Breach: Any instance of FAS constitutes a material breach of the Supplier’s Interconnect Agreement with NGN ICS.
  • Classification as Fraud: NGN ICS classifies FAS as intentional fraud.
  • Sanctions—Permanent Ban: Any confirmed FAS incident will result in:
    • Immediate suspension of the affected trunks, routes, or the entire interconnect.
    • Permanent termination of the Supplier relationship, with no option for future reconnection.
    • Forfeiture or claw-back of all payments for traffic transiting the affected route(s) during the billing period(s) in which the FAS occurred, plus any investigative costs, third-party analysis fees, or regulatory fines incurred by NGN ICS.
  • No Safe Harbor: So-called “isolation,” “testing,” or “pilot” routes are not exempt from this policy. A single confirmed FAS event on any route triggers full enforcement as outlined above.

4. Monitoring & Detection

  • Real-Time Analytics: NGN ICS continuously monitors key performance indicators such as Answer/Seizure Ratio (ASR), Average Call Duration (ACD), Post Dial Delay (PDD), and other metrics to flag anomalies that may indicate FAS. All automated alerts are subject to review by NGN ICS’s fraud management team to verify the anomaly before initiating an investigation.
  • Test Calls & Probes: We reserve the right to inject test calls (proactive probing) at any time, without notice, to verify call integrity.
  • Supplier Cooperation: Suppliers must promptly furnish call detail records (CDRs), full packet-capture (PCAP) SIP traces, and related logs in a standard, machine-readable format (e.g., CSV, PCAP) within 24 hours of a request from NGN ICS. Failure to cooperate with an FAS investigation will be treated as an admission of liability.

5. Investigation Procedure

  • Notification: NGN ICS will send written notice (email suffices) to the Supplier explaining the evidence of suspected FAS. Notice will be sent to the pre-designated technical and legal/compliance contacts provided by the Supplier in the Interconnect Agreement.
  • Response Window: The Supplier has 24 hours from the time of notice to provide comprehensive counter-evidence or a detailed root cause analysis and remediation plan.
  • Determination: NGN ICS, at its sole discretion, will review the evidence (and any response) and make a final determination as to whether FAS has occurred.
  • Enforcement: If FAS is confirmed, the sanctions outlined in Section 3.4 (Permanent Ban) will be applied immediately. NGN ICS will not restore service under any circumstances once a Supplier is terminated for FAS.

6. Right to Audit

NGN ICS or its designated third-party agent reserves the right to audit a Supplier’s systems, processes, and records related to traffic exchanged with the NGN ICS network to ensure compliance with this Policy. Such audits will be conducted with reasonable notice and during normal business hours. Should an audit reveal a material breach of this Policy, the Supplier shall bear the full cost of the audit.

7. Liability & Indemnification

Each Supplier must indemnify, defend, and hold harmless NGN ICS from and against all claims, penalties, losses, damages, or regulatory fines arising from FAS on their routes. This includes reimbursement for the costs of any related investigation, audit, reasonable attorneys’ fees, and other costs incurred by NGN ICS due to the Supplier’s breach of this Policy.

8. Regulatory & Legal Compliance

This Policy supplements (and does not replace) any obligations under applicable laws and regulations, including U.S. federal law, Delaware state law, Federal Communications Commission (FCC) regulations, and the laws of any local jurisdictions where traffic is carried. If any applicable law or regulation imposes a stricter standard or additional requirements regarding FAS, that stricter standard will apply and control.

9. Reporting Suspected FAS

NGN ICS employees, customers, or third parties may report suspected FAS incidents to [email protected]. All such reports will be treated confidentially. NGN ICS may, at its discretion, share relevant findings with appropriate regulators or law enforcement agencies as part of broader fraud prevention efforts.

10. Policy Updates

NGN ICS may amend or update this Anti-FAS Policy at any time. Updates will be published on our website or communicated through official channels. Continued use of our network or services after any Policy update constitutes acceptance of the revised terms.

11. Severability

If any provision of this Policy is held to be invalid or unenforceable by a court of competent jurisdiction, the remaining provisions will continue in full force and effect.

12. Acknowledgement

By sending traffic to, from, or through the NGN ICS network, each Supplier expressly accepts this Anti-FAS Policy in full. This Policy is incorporated by reference into the Supplier’s Interconnect Agreement, and the Supplier affirms that it has implemented sufficient internal controls to prevent, detect, and remediate FAS.

Last updated: June 24, 2025.