- The lack of statutory authority also prohibited Team Telecom from conducting meaningful oversight of foreign carriers authorized by the FCC. Team Telecom's monitoring and oversight capabilities existed only when it signed a security agreement with a foreign carrier. But, it was limited to monitoring compliance with the particular terms of the agreement. The stringency of these agreements increased over time, but historical agreements—particularly those entered before 2010—were written broadly, such that Team Telecom had little to verify. Further, Team Telecom did not start to develop an interagency process for monitoring compliance with security agreements until 2010 or 2011.
- Team Telecom had insufficient resources. DOJ and DHS historically dedicated fewer than five employees to reviewing applications and monitoring compliance with security agreements.
- Nearly a year after the Subcommittee began its investigation, the Administration issued an executive order that formalized Team Telecom. Executive Order 13913 established the EO Telecom Committee, set deadlines by which the EO Telecom Committee must complete reviews, and provided for input from other Executive Branch agencies, including the Intelligence Community. While the Order is a positive development, it does not address all of the concerns the Subcommittee identified relating to Team Telecom, including resource levels and formal review procedures.
- The FCC has authorized three Chinese state-owned carriers to provide international telecommunications services between the United States and foreign points. These three Chinese state-owned carriers have operated in the United States for decades: China Unicom Americas and China Telecom Americas obtained authorization in 2002; ComNet first obtained authorization in 1999.
- Team Telecom has had no interaction with China Unicom Americas since the FCC's authorization. Team Telecom has never sought a security agreement with China Unicom Americas, despite having opportunities to do so as recently as 2017. As a result, Team Telecom had no oversight of the company's operations in the United States.
- Team Telecom entered into security agreements with China Telecom Americas and ComNet, but conducted just two site visits in more than 10 years. Team Telecom entered into a security agreement with China Telecom Americas in 2007 and ComNet in 2009.
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