Traceback Search for Due Diligence

What is Traceback Search?

Traceback search is the process of tracing telephone calls back through the network to identify their origin. Unlike traditional call records that show where a call terminated, traceback reveals the complete call path — every carrier that handled the call from origination to termination.

Traceback search capabilities allow you to:

• Identify originating carriers — See which provider originated a call
• Map call paths — Understand routing through intermediate carriers
• Verify caller identity — Confirm who's behind specific phone numbers
• Investigate patterns — Analyze calling behavior across number ranges
• Document due diligence — Create audit trails for compliance

Types of Traceback Information

Data Element	What It Tells You
Originating Carrier	Which provider the call originated from
OCN (Operating Company Number)	Unique identifier for the originating carrier
LATA/Rate Center	Geographic origin of the number
LRN (Location Routing Number)	Routing information and porting status
Activation Date	When the number was last activated or ported
Line Type	Whether the number is wireless, landline, or VoIP

Know Your Customer (KYC) Due Diligence

Why KYC Matters in Telecom

Voice service providers have increasing obligations to know their customers. The FCC expects providers to:

• Verify the identity of customers before providing service
• Understand how customers plan to use voice services
• Monitor for suspicious or illegal calling patterns
• Take action when customers violate terms or laws

Failure to implement adequate KYC can result in:

• Liability for customer's illegal calling activities
• FCC enforcement actions
• Removal from the Robocall Mitigation Database
• Traffic blocking by downstream carriers

Using Traceback for Customer Vetting

Before onboarding new voice customers, use traceback search to investigate:

1. Numbers they want to use
   • Who currently owns or has owned these numbers
   • Historical calling patterns from these numbers
   • Any complaint history or spam reputation
2. Their existing voice presence
   • Other numbers associated with the customer
   • Previous carrier relationships
   • Any traceback history involving their traffic
3. Business legitimacy
   • Do their claimed business activities match calling patterns
   • Are the volume levels consistent with stated use case
   • Red flags that suggest potential bad actors

Voice Provider Qualification

Vetting Upstream Providers

If you're accepting traffic from other voice providers, due diligence is essential:

• RMD verification — Confirm they're filed in the Robocall Mitigation Database
• STIR/SHAKEN status — Verify their authentication capabilities
• Traceback history — Check for patterns of problematic traffic
• ITG responsiveness — Confirm they respond to traceback requests

Provider Due Diligence Checklist

# Example due diligence workflow for provider qualification
def qualify_voice_provider(provider_info):
    results = {
        'provider': provider_info['name'],
        'checks_performed': [],
        'issues_found': [],
        'recommendation': None
    }

    # Check RMD status
    rmd_status = check_rmd_filing(provider_info['name'])
    results['checks_performed'].append('RMD Filing Check')
    if not rmd_status['is_filed']:
        results['issues_found'].append('Not filed in RMD - traffic must be blocked')

    # Check traceback history
    traceback_history = search_traceback_database(provider_info['ocn'])
    results['checks_performed'].append('Traceback History Search')
    if traceback_history['count'] > threshold:
        results['issues_found'].append(f'High traceback count: {traceback_history["count"]}')

    # Check ITG responsiveness
    itg_status = check_itg_responsiveness(provider_info['ocn'])
    results['checks_performed'].append('ITG Response History')
    if itg_status['avg_response_hours'] > 24:
        results['issues_found'].append('Slow traceback response times')

    # Determine recommendation
    if len(results['issues_found']) == 0:
        results['recommendation'] = 'APPROVE'
    elif any('RMD' in issue for issue in results['issues_found']):
        results['recommendation'] = 'REJECT - Regulatory requirement not met'
    else:
        results['recommendation'] = 'CONDITIONAL - Address issues before approval'

    return results

Ongoing Provider Monitoring

Due diligence doesn't end at onboarding:

• Regularly re-verify RMD filing status
• Monitor for changes in traceback frequency
• Track complaint rates for traffic from each provider
• Review STIR/SHAKEN attestation quality

Traffic Investigation

When to Investigate

Use traceback search to investigate traffic when you observe:

• Unusual volume spikes — Sudden increases in traffic
• Low answer rates — Calls that rarely connect
• Consumer complaints — Reports of unwanted calls
• Spam labeling — Numbers flagged by analytics providers
• Traceback requests received — ITG or regulatory inquiries

Investigation Workflow

1. Identify suspicious patterns
   • High call volume from specific number ranges
   • Unusual geographic patterns
   • Time-of-day anomalies
2. Perform traceback search
   • Look up originating carrier for sample numbers
   • Map the call path
   • Identify common upstream sources
3. Analyze results
   • Are calls coming from known problematic sources?
   • Is the originating carrier properly filed and compliant?
   • Do calling patterns match claimed business purpose?
4. Take action
   • Block traffic if illegal activity is confirmed
   • Notify customers of potential issues
   • Report to ITG or regulators if appropriate
   • Document all findings and actions

Pattern Analysis

Look for patterns that indicate problematic traffic:

Pattern	Possible Indication
Numbers activated recently with high volume	Potential short-term campaign abuse
Calls from numbers with poor attestation	Possible spoofing or unverified caller
Traffic from carriers with high traceback counts	Source may be problematic
Sequential number ranges with similar patterns	Coordinated campaign activity
International gateway with domestic caller ID	Possible spoofing or traffic pumping

Compliance Documentation

Building an Audit Trail

Documenting your due diligence protects you in several ways:

• Regulatory safe harbor — Shows good faith compliance efforts
• Litigation defense — Evidence of reasonable procedures
• Customer disputes — Documentation of vetting performed
• Internal oversight — Enables review and improvement

What to Document

For each due diligence activity, record:

• Date and time of the check
• What was checked (numbers, providers, traffic)
• Results of the check (findings, data retrieved)
• Decision made (approve, reject, investigate further)
• Who performed the check (personnel or system)
• Follow-up actions taken if any

Example Documentation Format

# Due diligence record structure
due_diligence_record = {
    'record_id': 'DD-2025-001234',
    'date': '2025-01-15T10:30:00Z',
    'type': 'new_customer_vetting',
    'subject': {
        'customer_name': 'Example Communications LLC',
        'numbers_requested': ['+12025551234', '+12025551235'],
        'stated_use_case': 'Appointment reminder service'
    },
    'checks_performed': [
        {
            'check_type': 'traceback_search',
            'numbers_checked': ['+12025551234', '+12025551235'],
            'results': {
                'originating_carrier': 'Tier 2 VoIP Provider',
                'ocn': '123456',
                'lrn_activation_dates': ['2024-12-01', '2024-12-01'],
                'line_types': ['VoIP', 'VoIP']
            }
        },
        {
            'check_type': 'rmd_verification',
            'provider_checked': 'Tier 2 VoIP Provider',
            'results': {
                'is_filed': True,
                'filing_date': '2024-06-15',
                'stir_shaken_status': 'Partial Implementation'
            }
        },
        {
            'check_type': 'complaint_history',
            'numbers_checked': ['+12025551234', '+12025551235'],
            'results': {
                'complaints_found': 0,
                'spam_flags': 0
            }
        }
    ],
    'decision': 'APPROVED',
    'decision_rationale': 'All checks passed. Numbers recently activated but no negative history. Provider RMD compliant.',
    'performed_by': 'Compliance Team - JSmith',
    'follow_up_actions': ['Schedule 30-day traffic review']
}

Number Acquisition Due Diligence

Vetting Numbers Before Use

Before using new phone numbers, perform due diligence:

• Check history — Were these numbers previously used for spam?
• Verify clean reputation — No existing spam labels or blocks
• Confirm proper assignment — Documented authorization to use
• Check for recycling issues — Recently disconnected numbers may have lingering issues

Number Recycling Concerns

Phone numbers are recycled when previous users disconnect:

• Numbers may retain negative reputation from previous users
• Consumers may still expect to reach the previous assignee
• Analytics providers may have historical data affecting treatment

Use traceback search to identify:

• When the number was last activated
• Previous carrier assignments
• Gap between previous use and your acquisition

Bulk Number Verification

# Verify a batch of numbers before use
def verify_number_batch(numbers):
    results = []
    for number in numbers:
        lookup = traceback_api.lookup(number)
        verification = {
            'number': number,
            'activation_date': lookup.get('lrn_activation_date'),
            'current_carrier': lookup.get('carrier'),
            'line_type': lookup.get('line_type'),
            'spam_score': check_spam_reputation(number),
            'suitable_for_use': True
        }

        # Flag potential issues
        if verification['spam_score'] > 0.5:
            verification['suitable_for_use'] = False
            verification['issue'] = 'High spam score'

        if verification['activation_date'] and is_recently_recycled(verification['activation_date']):
            verification['suitable_for_use'] = False
            verification['issue'] = 'Recently recycled number'

        results.append(verification)

    return results

Enterprise Applications

Vendor Management

Enterprises using voice services should vet their providers:

• Verify provider's RMD status and STIR/SHAKEN capabilities
• Check provider's traceback response history
• Include compliance requirements in contracts
• Monitor ongoing provider performance

Inbound Call Verification

Use traceback search to verify inbound callers:

• Identify the true originating carrier
• Verify caller ID hasn't been spoofed
• Check calling patterns for fraud indicators
• Build intelligence on inbound call sources

Fraud Prevention

Traceback helps prevent various fraud types:

Fraud Type	How Traceback Helps
Caller ID Spoofing	Reveals true originating carrier vs. displayed caller ID
Account Takeover	Verifies caller location matches expected patterns
Traffic Pumping	Identifies unusual routing through specific carriers
Social Engineering	Validates caller claims about identity

Regulatory Context for Due Diligence

FCC Expectations

The FCC expects voice providers to exercise due diligence:

• Know your upstream and downstream partners
• Monitor traffic for illegal activity
• Respond to traceback requests within 24 hours
• Take action against bad actors

Safe Harbor Considerations

Documented due diligence can provide safe harbor:

• Demonstrates good faith compliance efforts
• Shows reasonable procedures were followed
• Provides evidence in enforcement proceedings
• May reduce liability exposure

Industry Best Practices

The ITG and industry groups recommend:

• Regular traceback capability self-testing
• Proactive traffic monitoring
• Customer vetting before service activation
• Documentation of all due diligence activities

Due Diligence Best Practices

1. Establish clear procedures — Document your due diligence processes
2. Use traceback systematically — Make it part of standard workflows
3. Check before onboarding — Vet customers and providers upfront
4. Monitor ongoing traffic — Regular sampling and analysis
5. Document everything — Create comprehensive audit trails
6. Act on findings — Take action when issues are identified
7. Update procedures — Refine based on experience and regulatory changes
8. Train personnel — Ensure staff understand due diligence requirements

Frequently Asked Questions

How often should I perform traceback due diligence on existing customers?

Best practice is to perform ongoing monitoring rather than periodic reviews. Sample traffic regularly (daily or weekly depending on volume) and perform deeper analysis when anomalies are detected. At minimum, conduct comprehensive reviews quarterly. If a customer's traffic patterns change significantly, investigate immediately rather than waiting for the next scheduled review.

Can traceback search identify the actual person making calls?

Traceback search identifies the originating carrier, not the individual caller. The originating carrier has the customer relationship and can identify the caller, but that information is typically only disclosed in formal traceback investigations through the ITG or in response to law enforcement requests. Your traceback search will show you which carrier to contact for further investigation.

What red flags should trigger immediate investigation?

Investigate immediately when you see: sudden traffic volume increases (especially from specific number ranges), multiple consumer complaints about the same calling numbers, answer rates that drop significantly below normal, numbers flagged by multiple analytics providers, or traceback requests from the ITG or regulators. These patterns often indicate either intentional abuse or compromised accounts.

How does traceback search differ from caller ID lookup?

Caller ID lookup shows you the CNAM (Caller Name) associated with a number, which can be set by the caller and may not be accurate. Traceback search reveals the actual network path and originating carrier, which cannot be faked. Traceback tells you where a call truly came from, while caller ID only tells you what the caller chose to display.

Is performing traceback due diligence legally required?

While there's no specific FCC rule requiring traceback-based due diligence, the FCC expects voice service providers to know their customers and take reasonable steps to prevent illegal robocalls. Traceback is one of the most effective tools for meeting these expectations. Providers that fail to exercise adequate due diligence may face liability for their customers' illegal calling and risk RMD removal.