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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:

April 04, 2023

M3AAWG Comments on Review of the Computer Misuse Act 1990: consultation and response to call for information (accessible)

M3AAWG has submitted Comments focused on technical recommendations in response to the UK government's request for Review of the Computer Misuse Act 1990: consultation and response to call for information. These comments provide recommendations supporting efforts to tackle online abuse and cybercrime while respectfully urging the UK government to liaise with key security and anti-abuse groups including M3AAWG and its partner organizations as well as key UK-based and international industry stakeholders.

March 02, 2023

M3AAWG Comments on NIST Cybersecurity Framework 2.0 Concept Paper

The Messaging Malware Mobile Anti-Abuse Working Group (M3AAWG) has submitted comments in response to the National Institute on Standards and Technology (NIST) Cybersecurity Framework 2.0 Concept Paper: Potential Significant Updates to the Cybersecurity Framework (CSF Concept Paper), released on January 19, 2023. As discussed in the Comments, M3AAWG generally supports the proposals outlined in the CSF Concept Paper. However, M3AAWG urges NIST to consider the impact of proposals that could potentially dilute the usefulness of a framework originally developed to focus on critical infrastructure cybersecurity risks and needs.​

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


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.