Attorney General Brown pushes FCC to strengthen “Know Your Upstream Provider” rules to combat illegal robocalls

SALT LAKE CITY, Utah — Attorney General Derek Brown and a bipartisan coalition of 48 other attorneys general are urging the Federal Communications Commission (FCC) to strengthen its “Know Your Upstream Provider” (KYUP) requirements to keep scammers from using the U.S. phone network to make illegal robocalls. KYUP rules require voice service providers to accept calls only from legitimate, responsible providers, not wave through the bulk of illegal traffic instead.

“Every annoying robocall you receive is supposed to be checked by a cell phone provider whose job it is to know who they are doing business with. Increasingly, that critical check is not happening, and the bad actors know it — and exploit it,” said Attorney General Brown. “We want the FCC to make this check more robust, make the penalties real, and make it much harder for these bad actors to hide.”

A phone call travels through a series of phone companies before it reaches your phone, and the FCC requires each voice service provider to take reasonable measures to vet the companies that originate and route those calls. Some skip that step, letting illegal robocalls onto the network. Last year, Americans received more than 29.6 billion scam robocalls and texts and lost nearly $2 billion to these scams.

The attorneys general ask the FCC to:

Mandate baseline KYUP measures. Require providers to collect detailed, verified information from their upstream provider customers, vet those providers’ compliance more thoroughly, monitor them regularly, and cut off any that break the law.

Add triggers for KYUP monitoring. Providers now generally review an upstream provider only at contract signing or renewal, or on evidence of illegal activity. The FCC should require monitoring more regularly, so bad actors cannot operate unchecked.

Strengthen STIR/SHAKEN protections. Under the anti-spoofing framework, the FCC should ensure every provider knows and meets its caller ID authentication obligations, and that everyone responsible for verifying a call’s true origin applies the rules the same way.

Move quickly and add teeth. Implement new rules as soon as possible, set base penalties for providers that fall short, and require providers to retain KYUP data so law enforcement and attorneys general can use it in future investigations.

Attorney General Brown is part of the Anti-Robocall Multistate Litigation Task Force, which launched Operation Robocall Roundup in 2025. In phase 1, the task force sent warning letters to 37 smaller providers for failing to meet baseline FCC mandates. Two weeks ago, the FCC ordered six of them to fix their robocall failures or risk losing the ability to route calls nationwide. In phase 2, the task force expanded the effort to four of the country’s largest intermediate providers and pushed the FCC to tighten its Know Your Customer rules.

Attorney General Brown is joined in signing this letter by the attorneys general of Alabama, Alaska, American Samoa, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Georgia, Hawaii, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Nebraska, Nevada, New Hampshire, New Jersey, New Mexico, New York, North Carolina, North Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, South Carolina, South Dakota, Tennessee, Vermont, Virginia, Washington, West Virginia, Wisconsin, and Wyoming.

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