Page:2020-06-09 PSI Staff Report - Threats to U.S. Communications Networks.pdf/9

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Until recently, Team Telecom conducted limited oversight of these Chinese state-owned carriers. Team Telecom entered into security agreements with China Telecom Americas (2007) and ComNet (2009), but it exercised minimal oversight over those entities until recently. During the more-than-ten year period in which these security agreements have been in effect, Team Telecom conducted just two site visits to each company—or four in total, three of which occurred within the past three years. At no point did Team Telecom enter into a security agreement with China Unicom Americas, meaning Team Telecom has no oversight authority to assess the company's operations in the United States.

The national security concerns Team Telecom and the FCC outlined in relation to China Mobile USA are applicable to the Chinese state-owned carriers currently operating in the United States. In advocating that the FCC deny China Mobile USA's application, Team Telecom raised a number of national security concerns related to China Mobile USA's Chinese government ownership. As Team Telecom officials acknowledged to the Subcommittee, those concerns also apply to China Telecom Americas, China Unicom Americas, and ComNet. The carriers are ultimately owned by the Chinese government; are required to comply with Chinese national security laws to support the Chinese government's intelligence work; and have established relationships with U.S. carriers, giving them access to critical infrastructure that the Chinese government could exploit in its economic and cyber espionage efforts. Team Telecom recognized these issues in its recent recommendation that the FCC to revoke China Telecom Americas' authorizations. The FCC also indicated its awareness of these concerns, when it recently called for all the carriers to demonstrate why their authorizations should not be revoked.

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It must be noted that state-ownership does not presume a national security risk. Indeed, many foreign telecommunications companies around the world are state-owned. There are also compelling commercial interests dependent on facilitating the flow of data between the United States and China, which are among each other's top trading partners. The vast global telecommunications and technology infrastructure that facilitates commerce and economic development include undersea, terrestrial, wireless, and space-based networks jointly owned or operated by Chinese and Western companies.

Commercial interests, however, must be balanced against national security interests. Striking an appropriate balance between these interests requires the Executive Branch to exercise greater oversight and regularly evaluate the risks posed by foreign-owned companies, especially considering that national security concerns evolve over time. Currently, Chinese state-owned carriers are providing international telecommunications services based on FCC authorizations granted

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