would be applicable to the existing authorizations of other Chinese state-owned carriers.[1]
Not until 2017 did Team Telecom begin to engage in substantive oversight of CTA. Team Telecom officials explained that, by this time, Team Telecom and the Executive Branch agencies were finalizing its recommendation to deny China Mobile USA's application.[2] Thus, it was a logical sequence to then assess Chinese state-owned carriers with existing authorizations.[3] This began with a site visit to CTA's Herndon, Virginia headquarters on March 10, 2017, during which Team Telecom officials spoke with company officials about its (1) corporate organization; (2) products and services; (3) telecommunications infrastructure; (4) data and voice networks; (5) data storage locations; and (6) law enforcement request and Commission on Accreditation for Law Enforcement Agencies ("CALEA") processes.[4] During that visit, CTA explained that its budget was subject to approval by China Telecom Global ("CTG")[5] and that CTG consulted on "technical matters that relate to the establishment of network points of presence . . . within the United States."[6] In fact, CTA noted that it established "a [new] Dallas [point of presence]" after "discussion" with CTG.[7] When asked, a current Team Telecom official described this as a traditional relationship between a state-owned enterprise and its subsidiary.[8] Although the official believed that CTA exists to conduct traditional and legitimate telecommunications business, he also noted that it was a Chinese state-owned entity and there is a latent risk that CTA's business interests may be overridden by geostrategic interests.[9]
During the 2017 site visit, Team Telecom also identified concerns related to CTA's storage of U.S. customer data.[10] Team Telecom records indicate that, for a period of time, CTA's records were stored in China; they were transferred back to
- ↑ Briefing with the Dep't of Homeland Sec. (Feb. 7, 2020); Email from the Dep't of Homeland Sec. to the Subcommittee (June 4, 2020) (on file with the Subcommittee).
- ↑ Briefing with the Dep't of Homeland Sec. (Feb. 7, 2020); Email from the Dep't of Homeland Sec. to the Subcommittee (June 4, 2020) (on file with the Subcommittee).
- ↑ Briefing with the Dep't of Homeland Sec. (Feb. 7, 2020); Email from the Dep't of Homeland Sec. to the Subcommittee (June 4, 2020) (on file with the Subcommittee).
- ↑ See generally DHS00473PSI-76; TT-DOJ-495-99; TT-DOJ-500-06.
- ↑ In 2012, CTCL acquired China Telecom Global Limited, a Hong Kong company. See China Telecom Corp. Ltd., Annual Report (2016), https://www1.hkexnews.hk/listedco/listconews/sehk/2017/0406/ltn20170406631.pdf. China Telecom "streamlined its global business operations, establishing most operations outside China as divisions of [China Telecom Global]." TT-DOJ-495-99, at TT-DOJ-496.
- ↑ See DHS00473 PSI-76, at DHS00473PSI; TT-DOJ-495-99, at TT-DOJ-497.
- ↑ See DHS00473 PSI-76, at DHS00473PSI; TT-DOJ-495-99, at TT-DOJ-497.
- ↑ Briefing with the Dep't of Homeland Sec. (Feb. 7, 2020).
- ↑ Id.
- ↑ Team Telecom defined "customer data" to include customer billing and service data, as well as sales information "such as name, address, billing information, and contract terms. For technical reasons, CTA also retains information about the location of customer data closets, paths to endpoints, and initial data connection points." TT-DOJ-495-99, at TT-DOJ-499.
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