From: Anonymous <nobody@replay.com>
Date: Thu, 3 Dec 1998 06:58:53 +0800
To: cypherpunks@toad.com
Subject: SASMF, Part 1
Message-ID: <199812022206.XAA29326@replay.com>
MIME-Version: 1.0
Content-Type: text/plain



Space Aliens Stole My Freedom, Part 1
Know Your Gutless SheepleCustomer(TM)

Let's just take a peek at how the new FDIC proposed reg would
look if transposed into an FCC setting:

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"Know Your Customer" Requirements

AGENCY: Federal Communications Commission

ACTION: Notice of proposed rulemaking.

SUMMARY: The FCC is proposing to issue regulations requiring
FCC-supervised communications carriers to develop and maintain 
"Know Your Customer" programs. As proposed, the regulations would 
require each carrier to develop a program designed to determine the 
identity of its customers; determine its customers' sources of 
communicated information; determine the normal and expected 
calls of its customers; monitor account activity for calls that are 
inconsistent with those normal and expected callss; and report any 
calls of its customers that are determined to be suspicious, in 
accordance with the FCC's existing suspicious activity reporting 
regulations. By requiring communication carriers to determine the 
identity of their customers, as well as to obtain knowledge regarding 
the legitimate activities of their customers, the proposed regulations 
will reduce the likelihood that communications carriers will become 
unwitting participants in illicit activities conducted or attempted by 
their customers. It also will level the playing field between
carriers that already have adopted formal Know Your Customer programs
and those that have not.

---

Minimum steps to take to comply with the Know Your Customer rule.

Identify the customer.

If a communication carrier offers private leased communication services, 
it is important that the carrier understand a customer's personal and 
business background, source of information to be communicated, and 
intended use of the private leased communication services.

---

The extent of the information regarding the customer that may be 
necessary to fulfill the carrier's Know Your Customer obligations 
should depend on a risk-based assessment of the customer and the 
calls that are expected to occur, and should be addressed within the 
communication carrier's Know Your Customer program.

---

Determine the source of information.

Paragraph (d)(2)(ii) requires that the Know Your Customer program 
provide a system for determining the source of a customer's 
information. The amount of information needed to do this can depend 
on the type of customer in question.


Determine normal and expected calls.

Paragraph (d)(2)(iii) requires that the Know Your Customer program 
provide a system for determining a customer's normal and expected 
calls involving the communication carrier. A carrier's understanding 
of a customer's normal and expected calls should be based on 
information obtained both when an account is opened and during a 
reasonable period of time thereafter. It also should be based on 
normal calls for similarly situated customers.  Without this 
information, an institution is unable to identify suspicious 
calls.

Monitor the calls. Paragraph (d)(2)(iv) requires that the
Know Your Customer program provide a system for monitoring, on an 
ongoing basis, the calls conducted by customers to identify 
calls 'that are inconsistent with the normal and expected calls for 
particular customers or for customers in the same or similar 
categories or classes.' The proposed regulation does not require that 
every call of every customer be reviewed. Rather, it requires that a 
financial institution develop a monitoring system that is commensurate 
with the risks presented by the accounts maintained at that 
institution.


Determine if call should be reported.

Once a call is identified as inconsistent with normal and expected
calls, paragraph (d)(2)(v) requires that a communication carrier
determine if the call warrants the filing of a Suspicious Activity
Report. This is consistent with an carrier's existing obligations
under 12 CFR 353.3(a).

---

A.	Reasons for and objectives of the proposed rule.

The proposed Know Your Customer rule is designed to deter and detect
communication crimes, such as obscene phone calls, getting tax advice, 
and discussing the Constitution.

B.	Requirements of the proposed rule.

The proposed rule would require communication carrier to identify 
their customers, determine their customers' normal and expected 
calls, determine their customers' sources of information communicated 
in calls, monitor calls to find those that are not normal and 
expected, and, for calls that are not normal and expected, identify 
which are suspicious.

Know Your Customer monitoring would be similar to monitoring that 
communication carriers already do. For example, communication carriers 
monitor customer calls to ensure that calling volumes exceeding 
10,000 per month are reported under the Communications Secrecy Act, to 
ensure that customers do not overuse their telephones, and to ensure 
that required calls are accurate and timely. 

-----

Editor's Note:

Putting this in an FCC context makes it pretty clearly bizarre
and unconstitutional, doesn't it? Where do these fuckers get
off pulling this Nazi shit? Just to carry it all the way into
Wonderland, we've drawn up this questionnaire, also in the 
telephone context:

Sample Questionnaire

1. Is this a __residential or __business account?

2. Approximately how many calls do you expect per month?

    a. Incoming ____

    b. Outgoing ____

3. List the subject matter of expected calls (use extra
   sheets if necessary: ____

4. List the telephone numbers from which you expect to
   receive calls (use extra sheets, etc.) ____

5. List the telephone numbers to which you expect to 
   place calls (use extra, etc.):____

6. List the names of people with whom you expect to speak:

7. List the Social Security numbers of people with whom
   you expect to speak: ____

8. List the political organizations to which you belong:

9. List the political organizations to which people with
   whom you expect to speak belong: ____

10. Are any of the organizations in (8) or (9) on the 
    Attorney General's list? Yes__  No__

11. If the answer to (10) was Yes, do you have a current
    and valid waiver for that (those) organization(s)?
    Yes__  No__

12. If the answer to (11) was No, proceed directly to
    federal prison. Do not pass urine; do not collect
    $200 from any ATM.

13. Do you regularly call your mother?  Yes__  No__

14. If the answer to (13) was Yes, list the topics you
    commonly talk about with your mother (use extra, etc.)

15. What are your sources of information for your
    telephone conversations?____

16. List all facts known to you, about which you expect to
    speak in your telephone calls:____

17. List all times at which you expect to receive or place
    calls:____

18. Attach transcripts of all conversations you expect to
    have. In lieu of transcripts, recordings may be attached.

19. Staple this form to your head, jam a toilet plunger
    handle up your ass, waddle to the nearest telephone,
    dial "1" and say, "I'm ready. Pick me up." Wait at
    your front door.

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FuckingFedUpMonger