Key announcements:

• On January 8, 2026, the Federal Communications Commission (FCC) announced its first enforcement action based on a failure to comply with Team Telecom Letter of Agreement (LOA) commitments.
• After violating the terms of a Team Telecom LOA by failing to screen foreign person employees and allowing foreign person employees to access U.S. communications infrastructure and customer information without seeking prior approval from DOJ, a satellite and earth-station operator (Operator) signed a settlement with the FCC, agreeing to (a) pay $175,000 to the U.S. Treasury Department; and (b) implement a robust compliance plan.

Background:

The Committee for the Assessment of Foreign Participation in the U.S. Telecommunications Services Sector (Team Telecom) is comprised of members of the Departments of Justice (DOJ), Defense, and Homeland Security and is responsible for reviewing FCC applications and licenses for national-security and law-enforcement risks. Team Telecom may advise that an application or license should be (i) granted, as it would not raise national security-or law enforcement risks; (ii) granted, subject to conditions to mitigate any national-security or law-enforcement risk; or (iii) denied. One method of mitigation is the use of an LOA. An LOA imposes binding commitments that mitigate national-security and law-enforcement risks arising from a provider’s FCC-licensed satellite or earth-station operations.

FCC enforcement action:

Under its LOA from 2022, the Operator committed to implement strict controls on foreign-employee access to U.S. communications infrastructure and customer information, including an obligation to notify DOJ before granting such access to any foreign employee. However, due to inadequate screening procedures, the Operator failed to submit at least 186 foreign employees for DOJ vetting. The FCC led the investigation following a DOJ referral which found that prior access had been granted without notification to DOJ.

The Operator signed a settlement with the FCC, agreeing to (a) pay $175,000 to the U.S. Treasury Department; and (b) implement a robust compliance plan to ensure there is no further unauthorized foreign-employee access. The enforcement action indicates the FCC’s intent to enforce Team Telecom mitigation agreements and compliance. Assistant Attorney General John Eisenberg issued the following statement: “The promises that companies make to Team Telecom are binding and enforceable commitments . . .” and “[the] enforcement action sends a clear message that compliance is not optional.” Moreover, “The Justice Department, as Chair of Team Telecom, remains committed to working with the FCC to . . . hold companies that violate the terms of their licenses to account.”