FCC Takes First Enforcement Action on Team Telecom Mitigation Agreement

FCC Takes Landmark Enforcement Action Over National Security Violations

In an unprecedented move, the Federal Communications Commission (FCC) has taken decisive action against Marlink, Inc. for breaching its mitigation agreement with Team Telecom, signaling a shift in regulatory enforcement within the telecommunications sector. This landmark decision comes after a referral from the US Department of Justice and sets a new precedent for handling compliance with national security agreements.

On January 8, 2026, the FCC issued an Order and Consent Decree, finding that Marlink had violated its international section 214 and earth station authorizations. The violations pertained to the company's failure to comply with its commitments to restrict foreign employee access to US communications infrastructure, as outlined in its mitigation agreement with Team Telecom. As a result, Marlink agreed to pay $175,000 and implement a comprehensive compliance plan.

Implications of FCC's Action

The FCC's action underscores the binding nature of commitments made to Team Telecom. The enforcement measures provide Team Telecom with a new method to refer noncompliance cases to the FCC, potentially leading to severe penalties, including license revocation. This move increases regulatory scrutiny and imposes stricter compliance expectations on telecommunications and ICTS companies.

According to the FCC’s press release, this is the first enforcement action focused entirely on Team Telecom mitigation agreement compliance. Companies in the telecommunications and ICTS sectors must evaluate their compliance frameworks to ensure adherence to national security obligations.

Understanding Team Telecom's Role

Established under Executive Order 13913, Team Telecom is tasked with assessing national security and law enforcement risks related to foreign participation in US telecommunications. While it can recommend mitigation conditions, it lacks direct enforcement power, relying instead on the FCC to enforce compliance.

Marlink, a provider of maritime and land-based satellite communications, was found noncompliant due to procedural failures in its employee screening processes. These lapses involved granting access to 186 foreign employees without prior approval from the DOJ, as required by its mitigation agreement.

Marlink's Compliance Measures

To address the compliance breach, Marlink has entered into a Consent Decree with the FCC. The company has committed to a series of remedial measures, including:

• Paying $175,000 to the US Treasury.
• Establishing a robust compliance plan, with a senior corporate manager overseeing implementation.
• Enhancing procedures for employee onboarding and screening.
• Conducting mandatory compliance audits and additional reporting to the FCC.
• Reporting any noncompliance incidents promptly.

The Consent Decree, binding for three years, mandates that Marlink enhance its operational procedures and employee training regarding compliance with mitigation agreements.

Key Takeaways for the Industry

The Marlink case serves as a critical reminder of heightened compliance expectations and the potential consequences of noncompliance. It highlights the importance of rigorous adherence to Team Telecom agreements, as companies face risks such as investigations, penalties, and reputational damage.

The FCC's decision also underscores the importance of maintaining robust internal controls to ensure compliance with national security mitigation obligations. Companies must proactively assess their compliance strategies, taking into account the potential for increased oversight and operational costs associated with meeting these regulatory requirements.