Nobody gets a trunk before we know exactly who they are.

01 Why this policy exists

Wholesale voice is only as clean as the accounts sitting behind it. An unvetted customer does not merely harm the people it calls: it gets numbers blocked, gets routes de-prioritized, drags every other customer’s answer rates down with it, and invites regulatory attention onto the carrier that let it on.

So we treat onboarding as part of the product rather than as paperwork in front of it. This policy exists to make that process legible — to the customer being asked for documents, to the upstream carriers who ask us how we choose customers, and to any regulator who asks us to show our work.

It reflects the Federal Communications Commission’s expectation that voice service providers know their customers and take affirmative steps to keep illegal traffic off their networks, the robocall mitigation obligations in 47 C.F.R. Part 64, Subpart HH, and the ordinary commercial expectations of the carriers we interconnect with.

02 Who we verify

We verify every applicant for service. There is no self-serve tier, no trial that skips review, and no volume too small to be worth checking.

For each applicant we verify:

• the legal entity applying for service;
• each beneficial owner holding 25% or more, directly or indirectly;
• each individual with substantial control over the entity, whether or not they hold equity; and
• the authorized signatory who executes the agreement.

Where the applicant is a reseller, we additionally require a description of its own onboarding process, and we require it to apply standards at least as strict as these to its customers.

03 Stage one — business verification

We establish that the business exists, is in good standing, and is who it says it is. Nothing proceeds until this stage closes.

Discrepancies between the registry, the tax letter and the application are resolved before we move on. A name that does not match exactly is a discrepancy, not a typographical detail.

04 Stage two — beneficial ownership

We map ownership until we reach natural persons. Layered structures are permitted; opaque ones are not.

• We require an ownership chart identifying every person holding 25% or more, directly or through intermediate entities.
• We verify the chart against the entity’s constitutional documents, state registry filings, cap table or operating agreement, and any regulatory or audited filings the applicant is subject to. Where an applicant has filed beneficial ownership information with a government authority and is willing to give us a copy, we will accept it — but we do not have, and do not claim, access to non-public government beneficial-ownership registries.
• We identify individuals exercising substantial control — senior officers, anyone with authority to appoint or remove them, and anyone directing the entity’s traffic decisions — whether or not they appear on the equity chart.
• Nominee arrangements, bearer instruments and undisclosed trusts are grounds for refusal.

If we cannot reach a natural person, we do not open the account.

05 Stage three — identity verification

Each individual identified in stage two must complete identity verification. Where we have engaged a third-party identity verification provider, that provider performs document authenticity checks on a government-issued photo identity document together with a liveness check confirming that the person presenting the document is physically present and is the person it depicts. Where no such provider is engaged for a given check, verification is completed through the documented manual route below. We name the provider to each person before any capture takes place.

The check confirms three things: that the document is genuine and unaltered, that the person is live rather than a photograph, recording or synthetic likeness, and that the face presented matches the face on the document.

Where an individual cannot or will not complete the check, we offer a documented manual alternative — a notarized identity affidavit with certified copies — reviewed by a human. Refusal to complete either route ends the application.

06 Sanctions, PEP and adverse media screening

Every entity and every individual identified above is screened before activation and re-screened periodically thereafter.

• Sanctions. The U.S. Treasury Office of Foreign Assets Control Specially Designated Nationals list and the Consolidated Sanctions List, plus the consolidated lists maintained by the United Nations, the European Union and the United Kingdom.
• Denied and debarred parties. Including the Bureau of Industry and Security and State Department lists, and the FCC’s Covered List where relevant to equipment or providers in the path.
• Politically exposed persons. Identified and, where present, routed to enhanced due diligence rather than automatically refused.
• Adverse media and enforcement history. Including prior FCC or FTC enforcement, state attorney general actions, and traceback history attributable to the applicant or its principals.

A confirmed match against a U.S. sanctions list ends the application immediately. Where we hold funds or property in which a designated person has an interest, we block or reject the transaction as required and file the report required by 31 C.F.R. § 501.603 within ten business days. We disclose the existence of a report only as the law permits.

07 Stage four — use case and consent review

Knowing who you are is half the check. The other half is knowing what you intend to send.

• Declared use case. What the traffic is for, in the customer’s own words, at a level of detail that would let a third party recognize the campaign from its call records.
• Dial pattern. Expected volume, calls-per-second, hours of operation, geographic distribution, and the ratio of outbound attempts to connected calls.
• Consent source. Where the right to call each number comes from, how it was captured, and the disclosure language used at capture. Purchased lists require the provenance of the list and the original capture disclosure.
• Suppression practice. How and how often the customer scrubs against the National Do Not Call Registry, state registries, and its internal list.
• Caller identification. Which numbers will be presented, and the evidence of the customer’s right to use them.
• Carrier history. Current and prior providers, and the reason for any prior termination. We may contact a prior carrier.

Sample scripts and recordings are required for prerecorded and artificial-voice campaigns. A use case that cannot be described plainly does not clear this stage.

08 Risk rating and enhanced due diligence

Each approved account carries a risk rating that sets its initial capacity, its monitoring cadence and its re-verification interval.

Enhanced due diligence adds source-of-funds review, additional ownership documentation, and a named accountable officer at the customer. A rating can move in either direction as evidence accumulates.

09 The decision, and what refusal means

Approval requires every stage above to close cleanly. Approval is a commercial decision reserved to us, and we are not obliged to explain a refusal beyond telling the applicant that the application was unsuccessful.

We refuse where identity cannot be established, where ownership cannot be traced to natural persons, where screening returns a match we cannot resolve, where the declared use case would breach the Acceptable Use Policy, or where the answers we receive are inconsistent with the records we can check.

We also refuse where an applicant appears to be a reconstitution of a previously terminated account — a new entity wrapped around the same principals, numbers or traffic. Refusal decisions and their reasons are recorded.

10 Monitoring after activation

Verification at signup is a snapshot. The account is watched continuously thereafter, against the indicators set out in section 08 of the Acceptable Use Policy: answer-seizure ratio, average call duration, short-duration call ratio, attempt concentration, complaint and labeling rates, and traceback frequency.

Traffic that diverges materially from the declared use case triggers a review even where every individual call would be lawful. A customer approved for inbound customer service that begins running outbound marketing has not merely changed its mix; it has invalidated the basis on which it was approved.

Sanctions re-screening runs on a scheduled basis and on any change of ownership or control.

11 Re-verification and material changes

You must notify us in writing within ten business days of any of the following, and we may re-run any stage of this policy in response:

• a change in beneficial ownership at or above 25%, or in substantial control;
• a change of legal name, entity type, or state of formation;
• a material change in use case, dial pattern, expected volume or consent source;
• the commencement of any regulatory investigation or enforcement action against the customer or a principal; or
• termination or suspension by another carrier.

Independently of any change, accounts are re-verified at an interval set by risk rating — annually as standard, and more often above it.

12 Records we keep, and for how long

We retain onboarding records for five years after the account closes, or five years after we refuse an application or you abandon it, whichever applies — or longer where a law, regulator, carrier obligation or litigation hold requires it. Records include the documents collected, the verification results, screening outcomes, the risk rating and its basis, the approval decision and the identity of the person who made it.

Biometric information is the deliberate exception and is destroyed on the schedule set out in the Privacy Policy — substantially sooner than the rest of the file. Verification records are kept as an outcome and an audit trail, not as a store of raw biometric data.

13 How we handle what we collect

Onboarding material is confidential, access is limited to personnel with a role that requires it, and access to onboarding material is logged. We do not use onboarding data for marketing, we do not sell it, and we do not disclose it to other customers.

Full detail on lawful bases, sharing, international transfers, retention and individual rights is in the Privacy Policy. Requests to exercise a data protection right should go to privacy@evergladescomms.com, not to compliance@.

14 Law enforcement and regulatory requests

We respond to lawful process from courts, regulators and law enforcement, and we cooperate with the Industry Traceback Group. Where we receive a request for customer records, our practice is to notify the affected customer so it can exercise its own rights — unless a court order, statute or an active investigation forbids notification.

We do not provide customer records to private parties without the customer’s consent or valid legal process.