April 2015

Protecting 900+ MVNOs around the Globe from IRSF Fraud Pirates

interview with Colin Yates

Telecom fraudsters behave a lot like electricity: they follow the path of least resistance, gold being their favorite conductor of electrons.

And when it comes to International Revenue Share Fraud (IRSF) — a fraud that robs telecoms of a cool $4 billion a year — that new path of least resistance is the MVNO, the 900+ mobile operators who generally own no mobile networks, but sell mobile service virtually — reselling the facilities of a network operator.

That’s the analysis of Colin Yates, a foremost consultant and authority on fighting IRSF fraud, and he’s here to tell Black Swan readers all about this new threat — and explain what MVNOs should do to protect themselves.

	Dan Baker: Colin, what’s the scoop? What’s changed to make MVNOs more susceptible to IRSF? And maybe we should change the meaning of the term MVNO to “Massively Vulnerable Network Operator”.

Colin Yates: Dan, the MVNOs definitely are massively vulnerable. Without fraud management domain knowledge, training, and tools, you’re an easy target to be picked off by IRSF fraudsters. Data I’ve collected suggests that in the last 3 or 4 months there has been a gradual shift toward fraudsters attacking MVNOs more and more.

I think that’s a conscious decision by the fraudsters. Mobile and fixed operators have suffered IRSF attacks for 7 or 8 years now, but over time they have become skilled at putting in controls for prevention and early detection.

Big damage has already been done. Last month I spoke to two MVNOs who suffered losses of around $500,000 each. And neither of them had any effective controls. One of those MVNOs missed out entirely on the required knowledge transfer and intelligence around IRSF.

Now the mobile networks have got their education networks in place such as the GSMA Fraud Forum, but many MVNOs are outside that information loop. So they are hiring guys like me to come in and do fraud reviews to bring them up on industry best practices.

	What are these MVNOs doing wrong?

They basically don’t understand the fundamentals of fraud management. For example, in near real-time roaming data exchange, they often don’t look at those records because they don‘t understand their importance. Many are not even aware that IRSF exists.

Now the ‘Light’ MVNOs are probably in a bit better shape because their traffic is going through a large network operator who has the necessary fraud defenses in place.

Those ‘Full’ MVNOs who have their own core network are probably more exposed because most have not implemented any fraud management tools. Then the other thing that works against MVNOs is that their operations are very lean and they make their money on volume and low prices.

	Sure, they treat telecoms as a no-risk commodity to offer, like selling cinema or lottery tickets. Some of these MVNOs are grocery store chains.

Yes, most of the emphasis is on acquiring customers. Even if the MVNO appoints someone to be a fraud manager, that function often gets low priority.

They also don’t realize that they can get into a fraud management system for a reasonable price these days. Some excellent tools are available that run around $100,000. The days of million dollar fraud systems for small to medium operators are gone. And some of these suppliers are offering 24/7 fraud monitoring via a managed service. The managed service is a good fit for a medium-sized MVNO because it’s not efficient for them to employ dedicated people to look at fraud records.

	So what do you prescribe for these MVNO organizations? What do you consider they need to do?

Well, I think the actions they need to take generally boil down to five steps:

Fix accountability — Assign someone in the organization to be responsible for fraud management. They may not be big enough to appoint a full-time fraud manager, but someone needs to be accountable. At some MVNOs whoever answers an incoming call about a fraud issue is responsible for handling it. That sort of policy is too loose and doesn’t take the risk seriously. Your average person has no idea how fraud occurs.
Make an investment in training — Whoever is appointed to the job needs to spend some time learning the basic principles of fraud management, at least. They must learn what’s required to bring their organization in line with industry best practices for their smaller shop. Because people don’t have the background in fraud, they end up being purely reactive. A solid fraud program needs to be proactive — and it’s best to develop a two or three year strategy for implementing programs they need to build.
Invest in Automated Tools. — It’s not practical for MVNOs to put people behind a desk 24/7. They have got to look at an inexpensive and automated fraud management system with the ability to send an email or text message to alert someone when the system identifies likely fraud. About 90% of all IRSF happens between Friday night and Monday morning. No one in the organization is working during that period so you must cover that period with an automated system.
Do a Full Risk Assessment-- It’s worth having someone like me come in and do a fraud health check to see where their risks are and what controls should be in place. In every fraud risk audit I’ve done, the organization was surprised at the level of risks they were exposed to. CFOs are giving fraud management a low priority, but that’s because they don’t understand the risks. Actually the damage could be anything from $1,000 a week to $500,000 a week.
Enlist the Aid of the MNO Supporting Them — Another key thing is to look over their agreements with their MNO supplier. One of the surprises is the contracts in many cases date back before the time when IRSF was an issue, so fraud management doesn’t even appear as a line item.

While an MVNO is expected to manage its own fraud risk as far as acquiring customers and offering products and services, it’s important that the MNO agrees to remove their margin in IRSF rather than profiting from it. The MNO should at least be stopping the fraud once it’s detected to minimize the damage.

	Colin, when you go in and consult with an MVNO, what’s the typical procedure?

When I do get called in to consult, I get all the information I can about the organization — who they are, customers, and products and services. Then, over a 5 to 7 day period, I’ll typically interview all of the execs from the CEO on down and any Key Stakeholders in the next level of management.

With that information I’ll have a better understanding of their products and services. If they’ve suffered a fraud loss in the last year, I’ll review each fraud case and identify every point of failure that contributed to that fraud.

From there, I start compiling a complete risk profile for the organization, what controls are missing, and what opportunities there are. Typically I’ll come out with 15 to 40 recommendations on where to protect their network.

So usually within 2 week’s elapsed time, they come away with a complete framework for what they need to do. And I also leave them with documented policies and instructions as well.

	Sounds like a must-have audit for an MVNO. Thank you, Colin.

Colin Yates

Colin started his working life in Law Enforcement in New Zealand, then after 18 years moved to a Risk and Fraud Management role in Telecom New Zealand.

After 12 years there, he moved to Vodafone New Zealand and for the next 12 years had roles with Vodafone in New Zealand, Australia, Germany and the UK, leaving Vodafone in 2012 as Group Head of Fraud Management and Investigations, having had responsibilities for managing fraud and investigations right across the Vodafone footprint.

Colin has held Management positions in the GSMA Fraud Forum, CFCA, FIINA and Pacific Partners.

He is currently managing his own firm, Yates Fraud Consulting Limited which consults back to industry operators to review their Fraud and Revenue risk maturity. He also manages an IPR Test Number database currently in use by some of the world’s largest operator groups.

Colin is a Certified Fraud Examiner (CFE) and is also a Fraud Adviser to PITA (Pacific Islands Telecommunications Association). Contact Colin via

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Migration Success or Migraine Headache: Why Upfront Planning is Key to Network Decom — interview with Ron Angner — Shutting down old networks and migrating customers to new ones is among the most challenging activities a network operators does today. This article provides advice on the many network issues surrounding migration and decommissioning. Topics discussed include inventory reconciliation, LEC/CLEC coordination, and protection of customers in the midst of projects that require great program management skills.
Navigating the Telecom Solutions Wilderness: Advice from Some Veteran Mountaineers — interview with Al Brisard — Telecom solutions vendors struggle mightily to position their solutions and figure out what to offer next in a market where there’s considerable product and service crossover. In this article, a veteran order management specialist firm lays out its strategy for mixing deep-bench functional expertise with process consulting, analytics, and custom API development.
Will Telecoms Sink Under the Weight of their Bloated and Out-of-Control Product Stacks? — interview with Simon Muderack — Telecoms pay daily for their lack of product integration as they constantly reinvent product wheels, lose customer intelligence, and waste time/money. This article makes the case of an enterprise product catalog. Drawing on central catalog cases at a few Tier 1 operators, the article explains the benefits: reducing billing and provisioning costs, promoting product reuse, and smoothing operations.
Virtual Operator Life: Enabling Multi-Level Resellers Through an Active Product Catalog — interview with Rob Hill — The value of product distribution via virtual operators is immense. They enable a carrier to sell to markets it cannot profitably serve directly. Yet the need for greater reseller flexibility in the bundling and pricing of increasingly complex IP and cloud services is now a major channel barrier. This article explains what’s behind an innovative product catalog solution that doubles as a service creation environment for resellers in multiple tiers.
Telecom Blocking & Tackling: Executing the Fundamentals of the Order-to-Bill Process — interview with Ron Angner — Just as football teams need to be good at the basics of blocking and tackling, telecoms need to excel at their own fundamental skillset: the order-to-cash process. In this article, a leading consulting firm explains its methodology for taking operators on the path towards order-to-cash excellence. Issues discussed include: provisioning intervals; standardization and simplicity; the transition from legacy to improved process; and the major role that industry metrics play.
Wireline Act IV, Scene II: Packaging Network & SaaS Services Together to Serve SMBs — by John Frame — As revenue from telephony services has steadily declined, fixed network operators have scrambled to support VoIP, enhanced IP services, and now cloud applications. This shift has also brought challenges to the provisioning software vendors who support the operators. In this interview, a leading supplier explains how it’s transforming from plain ol‘ OSS software provider to packager of on-net and SaaS solutions from an array of third party cloud providers.
Telecom Merger Juggling Act: How to Convert the Back Office and Keep Customers and Investors Happy at the Same Time — interview with Curtis Mills — Billing and OSS conversions as the result of a merger are a risky activity as evidenced by famous cases at Fairpoint and Hawaiian Telcom. This article offers advice on how to head off problems by monitoring key operations checkpoints, asking the right questions, and leading with a proven conversion methodology.
Is Order Management a Provisioning System or Your Best Salesperson? — by John Konczal — Order management as a differentiator is a very new concept to many CSP people, but it’s become a very real sales booster in many industries. Using electronics retailer BestBuy as an example, the article points to several innovations that can — and are — being applied by CSPs today. The article concludes with 8 key questions an operator should ask to measure advanced order management progress.
NEC Takes the Telecom Cloud from PowerPoint to Live Customers — interview with Shinya Kukita — In the cloud computing world, it’s a long road from technology success to telecom busness opportunity. But this story about how NEC and Telefonica are partnering to offer cloud services to small and medium enterprises shows the experience of early cloud adoption. Issues discussed in the article include: customer types, cloud application varieties, geographic region acceptance, and selling challenges.
Billing As Enabler for the Next Killer Business Model — interview with Scott Swartz — Facebook, cloud services, and Google Ads are examples of innovative business models that demand unique or non-standard billing techniques. The article shows how flexible, change-on-the-fly, and metadata-driven billing architectures are enabling CSPs to offer truly ground breaking services.
Real-Time Provisioning of SIM Cards: A Boon to GSM Operators — interview with Simo Isomaki — Software-controlled SIM card configuration is revolutionizing the activation of GSM phones. The article explains how dynamic SIM management decouples the selection of numbers/services and delivers new opportunities to market during the customer acquisition and intial provisoining phase.
A Cynic Converted: IN/Prepaid Platforms Are Now Pretty Cool — interview with Grant Lenahan — Service delivery platforms born in the IN era are often painted as inflexible and expensive to maintain. Learn how modern SDPs with protocol mediation, high availability, and flexible Service Creation Environments are delivering value for operators such as Brazil’s Oi.
Achieving Revenue Maximization in the Telecom Contact Center — interview with Robert Lamb — Optimizing the contact center offers one of the greatest returns on investment for a CSP. The director of AT&T’s contact center services business explains how telecoms can strike an “artful balance” between contact center investment and cost savings. The discussion draws from AT&T’s consulting with world class customers like Ford, Dell, Discover Financial, DISH Network, and General Motors.
Mobile Broadband: The Customer Service Assurance Challenge — interview with Michele Campriani — iPhone and Android traffic is surging but operators struggle with network congestion and dropping ARPUs. The answer? Direct resources and service quality measures to ensure VIPs are indeed getting the quality they expect. Using real-life examples that cut to the chase of technical complexities, this article explains the chief causes of service quality degradation and describes efficient ways to deal with the problem.
Telco-in-a-Box: Are Telecoms Back in the B/OSS Business? — interview with Jim Dunlap — Most telecoms have long since folded their merchant B/OSS software/services businesses. But now Cycle30, a subsidiary of Alaskan operator GCI, is offering a order-to-cash managed service for other operators and utilities. The article discusses the company’s unique business model and contrasts it with billing service bureau and licensed software approaches.
Bricks, Mortar & Well-Trained Reps Make a Comeback in Customer Management — interview with Scott Kohlman — Greater industry competition, service complexity, and employee turnover have raised the bar in the customer support. Indeed, complex services are putting an emphasis on quality care interactions in the store, on the web, and through the call center. In this article you’ll learn about innovations in CRM, multi-tabbed agent portals, call center agent training, customer treatment philosophies, and the impact of self-service.
21st Century Order Management: The Cross-Channel Sales Conversation — by John Konczal — Selling a mobile service is generally not a one-and-done transaction. It often involves several interactions — across the web, call center, store, and even kiosks. This article explains the power of a “cross-channel hub” which sits above all sales channels, interacts with them all, and allows a CSP to keep the sales conversation moving forward seamlessly.
Building a B/OSS Business Through Common Sense Customer Service — by David West — Delivering customer service excellence doesn‘t require mastering some secret technique. The premise of this article is that plain dealing with customers and employees is all that’s needed for a winning formula. The argument is spelling out in a simple 4 step methodology along with some practical examples.

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