One Allied LOA (FBI

PETITION submitted by U.S. Department of Justice

LOA

2015-01-14

This document pretains to ITC-214-20140409-00112 for International Global Resale Authority on a International Telecommunications filing.

IBFS_ITC2142014040900112_1073062

One Allied Fund Corporation mGthal LH’M December 15, 2014 Elaine N. Lammert Deputy General Counsel Federal Bureau of Investigation U.S. Department of Justice 935 PenneyIvania Avenue, NW Washington, DC 20535 Re: Pending Application by One Allied Fund Corporation for Authorization Under Section 214 of the Communications Act of 1934 FCC ITC—214—20140409—00112 Dear Ms. Lammert: This letter outlines the commitments made by One Allied Fund Corporation (hereafter "OAFC") to the Federal Bureau of Investigation (FBI) in order to address national security, law enforcement, and public safety concerns raised with regard to OAFC‘s application to the Federal Communications Commission (FCC) for authority to provide resale service to all authorized international points under Section 214 ofthe Communications Act of 1934. OAFC confirms that it will comply with all applicable lawful interception statiites, regulations, and requirements, including the Communications Assistance for Law Enforcement Act (CCALEA®), 47 U.S.C. 1001 et seq., and its implementing regulations, and will comply with all court orders and other legal process for lawfully authorized electronic surveillance. Upon completion of the development ofits lawful interception capabilities, OAFC will request that the FBI send its CALEA Implementation Unit to conduct a CALEA compliance fest.‘ Once a compliance test is scheduled, OAFC will provide notice ofthe scheduled date. OAFC will continue to maintain such lawful interception capabilities for the duration of the time it provides services subject to CALEA. OAFC also agrees that it will comply with all other statutes, regulations, and requirements regarding electronic surveillance. OAFC agrees to maintain a point of contact in the US, preferably a US citizen or Lawful Permanent Resident, to receive service of process for US records and to support US law enforeement agencies‘ lawful requests for assistance and surveillance needs. OAFC also agrees that for all customer billing records, subscriber information, and any other related information used, processed, or maintained in the ordinary course of business refating to — _ Arequest can be made by contacting the general helpdesk for the CALEA Implementation Unit at (855) LECALEA (532—2532). . — 1600 Ponce de Leon Blvd {305) 985—5800 10" Floor ' Coral Gables, FL 33134 USA

One Alfied Fund Corporation mGlObal L‘fl% telecommunications services offered in the U.S. (U.S. Records), OAFC will store either originals or copies in the U.S. OAFCfurther agrees that its designated law enforcement point of contact will have access to, and will makesuch records available promptly andin any event no later than five business days, in the ULS. in response to lawful U.S. process." For these purposes, U.S. Records shall include information subject to disclosure to a U.S. Federal or state governmental enitity under the procedures specified in Sections 2703(c) and (d) and Section 2709 of Title 18 of the U.S. Code. OKFC also agrees to ensure that U.S. Records are not made subject to mandatory destructionunder any foreign laws. OAFC agrees that it will not, directlyor indirectly, discloseor permit disclosure of or access to T.S. Records, dom@stic communications; or any information (including the content of communications) pertaining to a wiretap or electronic surveillance order, penftrap order, subpoena, or otherlawful demand by a U.S. law enforcement agency for U.S. Records or lawfully authorized electronic surveillance inresponse to legal processora request on behaif of a non—U.S. government, without first satisfying all pertinent requirements 6f U.S. law and obtaining the. express writterm consent of DOJ or the authorization of a court of competent Jjurisdiction in the U.8 The term "noa—U.S. government" means any government, including an identified represen wagent, component, of subdivision thereof, that is notalocal, state, or ‘federal government the U.S. Any such—requests or legalprocess submitted by a non—U.S. government to OAFC shall be referred to DOJ assoon as possible, and in no eventlater thanfive business days aftersuch request or legal processis received by or known to OAFC, unlessthe disclosure ofthe request or legal process would be in violation of U.S. law or an order of a court ofthe U.S. OAFC agrees that:in theevent the commutments set forth in this letter are breached, FBI may request, in addition to any other remedy available at law or equity, that the FCC modify, condition, revoke, cancel, or render null and vmd any relevant license, permit, or other authorization granifed by the FCC to OAFC or any successor—in—interest. Nothing herein shall be constraedto be a waiver by OAFC of, or limitation on, its right to oppose or commenton any such request. : Nothing in this letter is intended to excuse OAFCfrom its obligations to comply with any and all applicable legal requirements and obligations, including jany and all applicable statutes, regulations, requirements, or orders. OAFC understands that, upon execution of this letter by an authorized representative or attorney for OAFC, DOJ shall notify the FCC that it has no objection to the FCC‘s grant of its application. * This stafement does mot supersede or replace OAFC‘s other duties.to comply with any applicable FCC requirements and regulations regarding the storage and protection of customer records, including but not Iimited to requirements related 16 the storage and protection of Customer Proprietary Network Information. 1600 Porice de Leon Blvd (305) 985—5800 10 Floor Coral Gables, FL 33134 USA

UOne Allied Fund Corporation mGlflbat Link The Company can send all notices pursuant to this fetter to: Unit Chief, Science and Technology Policy and Law Unit Federal Bureau of Investigation 935 Pennsylvania Ave, NW Room 7350 Washington, DC 20535 Courtesy electronic copies ofall notices and communications should also be sent to Jonathan Freakel of the FBI (at jonathan.frenkel@ic.fbi.gov). Sincerely, Title:PreStDy For One Allied Fund Corporation 1600 Ponce de Leon Blvd {305) 985—5800 10"" Floor Coral Gables, FL 33134 USA


Document Created: 2019-04-18 11:57:50
Document Modified: 2019-04-18 11:57:50
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