- United States. To carry out these efforts, the Chinese government frequently enlists the assistance of state-owned entities. Chinese state-owned companies are subject to an added layer of state influence in that they must comply with strict national security, intelligence, and cyber security laws regardless of where they operate. The U.S. National Counterintelligence and Security Center and the Director of National Intelligence have warned that the Chinese government is likely to use its state-owned carriers to assist in its espionage efforts because the carriers "provide valuable services that often require access to the physical and logical control points of the computers and networks they support." In fact, public reports allege that at least one Chinese carrier—China Telecom—and its affiliates have hijacked and rerouted data through China on a number of occasions since 2010. China Telecom and its affiliates, including its U.S. affiliate, China Telecom Americas, deny the public reports.
- The FCC regulates foreign carriers seeking to provide international telecommunications services between the United States and foreign points, but historically relied on Team Telecom to assess the national security and law enforcement risks associated with a foreign carrier's proposed services. The FCC also seeks input from other Executive Branch agencies concerning other risks, such as foreign policy and trade implications.
- The FCC is not required to review a foreign carrier's authorization after it has been granted. Authorizations effectively exist in perpetuity despite evolving national security implications. The FCC does not require a foreign carrier's authorization to be periodically reassessed to confirm the services continue to serve the public interest.
- Team Telecom was an informal group, with no statutory authority. As a result, its review of foreign carriers' applications was ad hoc, leading to delays and uncertainty. Throughout its existence, Team Telecom operated under no formal legislative or regulatory authority. Instead, it reviewed foreign carriers' applications at the request of and under the powers of the FCC. The lack of statutory authority resulted in a disorganized, haphazard, and lengthy review process that has been heavily criticized and referred to as an "inextricable black hole." Team Telecom had no deadlines by which it needed to make recommendations to the FCC, meaning the review of an application could—and often did—last years.
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