Pipeline Publishing, Volume 3, Issue 11
This Month's Issue:
The Long Arm of Telecommunications Law
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Staring Down the Compliance Conundrum
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such as IMS, increasing demands will be made on systems that collect and correlate such data.

In the U.S., roving surveillance requirements are specified in Section 206 of the U.S. Patriot Act. This measure has had profound impact on lawful interception methods, since it expands the scope of surveillance beyond a single communications identity to multiple communications identities associated with a target. For example, multiple fixed line and mobile phone numbers, e-mail addresses, SIP addresses, and other identifiers may now be involved in correlating the traffic of various service usage for a particular person or persons of interest.

Finally, in a controversial ruling, the Federal Communications Commission (FCC) has required that operators of broadband Internet and interconnected Voice-over Internet Protocol (VoIP) services establish systems to enable law enforcement agencies to process wiretapping requests. While standards are not finalized for this technology, it is clear that these services are next to be brought under surveillance and control.

Other legislative concerns

In the meantime, the Wireless Communications and Public Safety Act of 1999 required as a feature of the 911 emergency-calling system that operators automatically associate a physical address with each calling party’s telephone number. This data enrichment was unneeded for broadband and VoIP services until recently, when in 2005 the FCC required that VoIP services that interconnect with the public telephone network begin to provide 911 service, as well as provide notice to their consumers concerning the 911 limitations. As mandated, the E911 hookup may be directly

Ultimately, implementing a lawful intercept and surveillance solution and strategy is no longer a choice; it’s a necessity.


with the wireline E911 Network, indirectly through a third party such as a competitive local exchange carrier (CLEC), or by any other technical means, although some VoIP providers remain significantly out of compliance with the order.

The Sarbanes-Oxley Act was established in 2002, requiring that all operators’ internal systems and operational controls, pertaining to business activities and financial reporting, produce audit evidence that can be tracked, monitored, and ensured by the management team of the companies.

In short, above and beyond the operators’ own requirements to collect, mediate, store, and distribute call records for service usage, there is increasing pressure to handle processing of this service usage for other reasons, often in real-time, and sometimes involving very processing-intensive correlation and business rules.

How is all of this done?

The lawful interception standards proposed by ETSI have provided the dominant reference model that is currently applied in Western countries worldwide. Although there are slight variations in terminology according to region and to address specific verticals (e.g., Cable/MSO), the ETSI model is essentially the same as the predominant architecture deployed throughout the U.S. to achieve CALEA compliance.

See Figure 1 – Lawful Intercept Reference Model representing a composite view based on ETSI and TIA standards and terminology.

figure 1
Figure 1 – Lawful Intercept Reference Model
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