Russia Messaging Compliance

[arthurgousset]

Reflecting feedback received from mbay2002 | VCAP on Discord regarding a recent message from Twilio:

Just got an email from Twilio regarding "Russia Messaging Compliance". I see in the suggested configs we have (for each of the messaging services)
UNSUPPORTED_REGIONS=CU,SY,KP,IR,SD
I'm going to add "RU" to that list to just avoid dealing with the current geopolitical issues....

👇 This is a copy of Twilio's email for ease of reference 👇

You’re receiving this email from Twilio because you have used Twilio’s Programmable SMS Product to send traffic to Russia using an Alphanumeric Sender ID or a Numeric Phone Number within the past 90 days.

What do you need to know?

Mobile operators in Russia are implementing changes in their Messaging regulation to prevent cases of fraud via SMS. Twilio is asking customers to opt-in via the Sender ID registration process by July 22, 2022.

The changes are as follows:

All Alphanumeric Sender IDs will require pre-registration. Registered Sender IDs must correlate to the brand sending the messages. No generic Sender IDs will be allowed.
SMS traffic via non-registered Sender IDs or numeric phone numbers will not be supported.
Subscribers need to provide consent to receive SMS messages (see details below).
Spam and phishing are not allowed; this includes advertising another legal entity other than the company registered.
Messages related to alcohol, tobacco, and pornography are prohibited.
Effective August 12, 2022, SMS to Russia delivered from numeric Phone Numbers and non-registered Alphanumeric Sender IDs will not be accepted for delivery.

What do you need to do?

If you want to continue sending SMS messages to Russia, you must opt in to pre-registered Alphanumeric Sender IDs by July 22, 2022.

If you are using a numeric phone number(s) or a non-registered Alphanumeric Sender ID(s), you will need to pre-register an Alphanumeric Sender ID(s). Due to the current situation, we're only allowing existing customers and use cases related to the Twilio.org team to register. To register, please complete the Sender ID Registration form by July 22, 2022.
If your Sender ID(s) are already pre-registered, you must comply with three additional requirements: subscriber consent, spam and phishing control, and new content rules surrounding alcohol, tobacco, and pornography.
Additionally, if you’re using or need to use Multiple Sender IDs in a single destination country, each Sender ID needs to have its own Twilio Account SID. You can do this by creating sub-accounts and registering the new sub-account SID in the Alphanumeric Sender ID application form.

If no action is taken, SMS delivered to Russia from numeric Phone Numbers and Alphanumeric Sender IDs that are not pre-registered will not be accepted for delivery starting on August 12, 2022.

For more information on SMS compliance requirements, please review our SMS guidelines for Russia.

Sincerely,
Team Twilio

[arthurgousset]

Copy of my response on Discord:

Hey @mbay2002 | VCAP 👋 Thanks for sharing this here. I made a Github discussion so we can keep the conversation going more easily and refer to it in the future: https://github.com/celo-org/identity/discussions/28

I'll ask the cLabs legal counsel for some advice on your feedback above. At first glance, it seems the "Russia Messaging Compliance" email from Twilio relates to ordinary:

changes in [Russia's] Messaging regulation to prevent cases of fraud via SMS

[arthurgousset]

Copy of mbay2002 | VCAP response on Discord:

Yes, the email from Twilio has to do with regulation (in Russia ) to prevent cases of fraud via SMS. But I took the leap that the situation in Russia right now is a little dicey so I'm just putting them on the blacklist. Great idea to run by cLabs legal counsel.

[arthurgousset]

Copy of response on Discord:

Hi mbay2002 | VCAP sorry for the delay in getting back to you! I wanted to make sure I provide a complete response to your query.

👉 As expected, we leave the decision to support sending SMS to Russia at the discretion of attestation service operators like yourself.

If other attestation service operators choose to add Russia to their list of unsupported regions, I'd appreciate a brief heads up here or in a DM, so I can keep track of the approximate impact that would have on coverage in Russia.