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Public Policy Comments

M3AAWG actively seeks to provide the necessary technical and strategic guidance to protect end-users’ online experience as government, Internet and public policy agencies worldwide develop new Internet policies and legislation. Working to reduce the spread of spam, bots and malware, M3AAWG has submitted comments on these proposals:

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December 19, 2022

In the Matter of Trade Regulation Rule on Impersonation of Government and Businesses | Docket No. FTC-2022-0064 | COMMENTS OF THE MESSAGING MALWARE MOBILE ANTI-ABUSE WORKING GROUP (M3AAWG) ON THE NOTICE OF PROPOSED RULEMAKING

Messaging, Malware and Mobile Anti-Abuse Working Group (M3AAWG) supports the U.S. Federal Trade Commission’s (FTC) proposed rulemaking as part of its current mission in protecting the public from deceptive or unfair business practices to include a critical role in protecting consumers from ongoing and increasing impersonation schemes targeting businesses and governments alike. M3AAWG suggests additional regulatory solutions and best practices to complement the goals of this rule, such as clarifying the scope of the rule to include the use of domain names in impersonation schemes and the use of technologies that enable impersonation. M3AAWG notes that the investigation of impersonation schemes requires cooperation and information from many entities.  Specifically, WHOIS information is vital to the investigation of impersonation scams. The Comment identifies best practices to tackle impersonation scams, including the validation of commercial senders, DNS mitigation steps, and adoption of trusted notifier relationships to facilitate abuse reporting.

November 09, 2022

In the Matter of Targeting and Eliminating Unlawful Text | CG Docket No. 21-402 | COMMENTS OF THE MESSAGING MALWARE MOBILE ANTI-ABUSE WORKING GROUP (M3AAWG) ON THE NOTICE OF PROPOSED RULEMAKING

M3AAWG states that while spoofing is common in U.S. voice communications, originating number spoofing is extremely rare in U.S. text messaging, and the originating service provider is also almost always well known.  This is due to voluntary industry agreements and operational checks currently in place in the U.S.   These voluntary agreements and checks are effective - they ban and block the delivery of messages from not only spoofed but also invalid, unassigned, and unallocated phone numbers. M3AWWG's comments explain how the industry's current anti-spoofing safeguards work and state that they are effective.

January 06, 2022

EPDP Phase 2A Policy Recommendations for ICANN Board Consideration

It is in the public interest for anti-abuse actors to be able to contact, and obtain information about, the registrant of a public resource such as a domain name, in order to address cybercrime, hacking, botnets, phishing, and other abuse. For bona fide actors with a legitimate interest, access to WHOIS must be effective, functional, timely, and efficient to ensure appropriate cybercrime and abuse response. Thus, we would like to voice our agreement with the recommendations made in SAC118, as released by SSAC on July 15th 2021.

September 30, 2021

Recommendations pertaining to findings from the M3AAWG and APWG WHOIS Survey Report presented to ICANN in June, 2021

As a followup to the June 2021 survey report of cyber investigators and anti-abuse service providers on the ongoing impacts of ICANN’s implementation of the EU GDPR, the Temporary Specification for gTLD Registration Data (Temporary Specification, adopted in May 2018), M3AAWG and the Anti-Phishing Working Group (APWG) has released their recommendations for ICANN'S consideration.

June 08, 2021

ICANN, GDPR, and the WHOIS: A Users Survey - Three Years Later

M3AAWG and the Anti-Phishing Working Group (APWG) conducted a follow up survey to our 2018 survey of cyber investigators and anti-abuse service providers to determine the ongoing impacts of ICANN’s implementation of the EU GDPR, the Temporary Specification for gTLD Registration Data (Temporary Specification, adopted in May 2018). The report contains our findings and presents some recommendations for consideration.

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