[co-author: Stephanie Kozol]*
In 2022, a bipartisan task force of 51 state attorneys general (AGs) was formed to investigate and take legal action against companies allegedly responsible for large volumes of fraudulent and illegal robocall traffic. North Carolina AG Jeff Jackson, Indiana AG Todd Rokita, and Ohio AG Dave Yost lead the “Anti-Robocall Litigation Task Force.” The task force is made up of AGs from both political parties.
In August 2025, the task force announced “Operation Robocall Roundup,” a multistate effort to stop the alleged proliferation of illegal robocalls. There are three ways that voice service providers targeted in Operation Robocall Roundup have purportedly failed to comply with federal anti-robocall requirements. Either the provider (1) failed to comply with Federal Communications Commission (FCC) rules on responding to government traceback requests; (2) failed to register in the FCC’s Robocall Mitigation Database (RMD); or (3) has not filed a plan with the RMD describing how they will reduce illegal robocalls on their network.
The task force sent warning letters to 37 different voice service providers, demanding that each take action to stop any illegal robocalls from being routed through their network. In addition, the task force warned 99 other telecommunications companies that accept call traffic from the 37 targeted companies, informing them that they are doing business with entities failing to comply with federal anti-robocall rules. The FCC also announced the removal of seven of the 37 targeted providers from the RMD, meaning that other providers will no longer be able to accept or route call traffic from these seven providers on their networks.
Each letter concerns the respective voice service provider’s failure to comply with FCC requirements on the RMD and/or traceback participation.
Robocall Mitigation Database
Under FCC mandates, all domestic and foreign voice service providers are required to participate in the RMD. Providers must file a certification with the RMD along with a robocall mitigation plan, which “must describe with particularity the provider’s specific mitigation practices addressing how it avoids originating, carrying, and/or processing illegal robocall traffic.” The RMD is meant to ensure uniformity among voice service provider regulations, facilitate enforcement efforts, and maximize the use of provider due diligence and call analytics to stop robocalls. Voice service providers must also refuse any call traffic sent by non-RMD-registered providers.
Traceback Participation
The letter also emphasizes the alleged failure of voice service providers to respond to traceback requests. Tracebacks are cooperative efforts by telecommunications providers intended to find the point of origin of the robocall. Requests to assist in traceback efforts are often sent to providers. While providers are required to respond to tracebacks generally within 24 hours of any request, the targeted providers have allegedly repeatedly failed to respond.
Requested Action
After providing a detailed review of how each voice service provider was violating its obligations to the FCC, each letter requests the provider to review the contents and respond within 21 days of the letter’s issuance, detailing how the provider plans to address the identified concerns. The task force also informed several law enforcement counterparts of its intention to issue notices to these companies. Within the notice, the task force makes clear that the letter does not waive or otherwise preclude an enforcement action being brought against the voice service providers at a later date.
Why It Matters
Voice service providers should be aware of the increased scrutiny placed on their activities. These businesses must proactively come into compliance with FCC standards by filing certifications and a robocall mitigation plan in the RMD, as well as following up with traceback requests. Failure to comply can lead to a potential enforcement action and may hinder business, as compliant providers would not be able to route the calls of noncompliant providers.
*Senior Government Relations Manager
