China Mobile USA is vulnerable to exploitation, influence, and control by the Chinese government. Team Telecom concluded that China Mobile USA is vulnerable to exploitation, influence, and control by the Chinese government, in part because of its government ownership.[1] Team Telecom also noted that China Mobile USA would be required to comply with intercept requests from the Chinese government.[2]
China Mobile USA's authorization would allow it to interconnect with U.S. telecommunications networks and carriers. Team Telecom warned that, with Section 214 authorization, China Mobile USA would have been able "to interconnect [its international voice traffic] with the U.S. telecommunications network."[3] "A carrier connected to [the U.S. telecommunications networks] has greater access to telephone lines, fiber-optic cables, cellular networks, and communication satellites. . . ."[4] Further, China Mobile USA would have been able to build "direct and indirect interconnection relationships with other telecommunications carriers, from basic connections between networks in order to exchange traffic . . . to much more integrated relationships."[5] Access to these networks and relationships with U.S. carriers would provide China Mobile USA—and by extension the Chinese government—with access to critical infrastructure, which the Chinese government could use to further its espionage and intelligence activities.[6]
China Mobile USA's authorization would allow it to increase its operations in the United States without further FCC approval. The concern about China Mobile USA's access to the U.S. telecommunications networks was "amplified" given that,
after obtaining an international Section 214 authorization, China Mobile [USA] could further expand its U.S. operations by increasing the number of its points of presence in the United States, developing its own domestic network without relying on underlying carriers for connectivity, increasing its number of peering partners, providing mobile service, or operating as a mobile virtual network operator.[7]
- ↑ See Executive Branch Recommendation re China Mobile USA, supra note 56, at 7-17. See also In the Matter of China Mobile Int'l (USA) Inc., FCC No. 19-38, 34 FCC Red 3361, ¶¶8, 19 (May 10, 2019).
- ↑ See Executive Branch Recommendation re China Mobile USA, supra note 56, at 8. The Executive Branch also expressed concern that "there is a substantial risk that the Chinese government would exert even greater control over China Mobile and China Mobile USA than other state-owned enterprises given the Chinese government's 100% ownership of China Mobile, the size and reach of China Mobile and its subsidiaries, and the importance of any opportunities afforded by the telecommunications services offered both within China and globally." See Executive Branch Recommendation re China Mobile USA, supra note 56, at 8. See also In the Matter of China Mobile Int'l (USA) Inc., FCC No. 19-38, 34 FCC Red 3361 ¶¶8, 19 (May 10, 2019).
- ↑ Executive Branch Recommendation re China Mobile USA, supra note 56, at 3.
- ↑ Executive Branch Recommendation re China Mobile USA, supra note 56, at 10.
- ↑ Executive Branch Recommendation re China Mobile USA, supra note 56, at 3.
- ↑ Executive Branch Recommendation re China Mobile USA, supra note 56, at 3, 10.
- ↑ Executive Branch Recommendation re China Mobile USA, supra note 56, at 10-11.
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