Acceptable Use Policy

This Acceptable Use Policy (“AUP” or “Policy”) governs the use of the carrier-to-carrier voice termination, origination, DID/numbering, and related wholesale telecommunications services (the “Services”) provided by Mokrina, together with its affiliates (“Mokrina,” “Company,” “we,” or “us”), to any carrier, ITSP, CLEC, reseller, CPaaS/UCaaS platform, enterprise customer, or other entity that purchases or interconnects with the Services (“Customer” or “User”). This AUP applies to Customer and to any of Customer's own downstream customers, resellers, or end users whose traffic is carried over the Services. If this Policy conflicts with a signed interconnection agreement or Master Service Agreement between Mokrina and Customer, the signed agreement controls.

We may update this Policy from time to time on reasonable notice, provided by email, account notice, or by posting a revised version at mokrina.com. Continued use of the Services after a revised Policy takes effect constitutes acceptance of the changes. If Customer does not agree to a revised Policy, Customer must stop using the Services.

1. Prohibited Activities

The Services may not be used for any purpose that Mokrina determines, in its reasonable discretion, is illegal, fraudulent, or otherwise inappropriate or improper (“Prohibited Activities”). The categories and examples below illustrate, but do not exhaust, what counts as a Prohibited Activity.

1.1 Illegal Purposes

• Using the Services to violate any applicable law, regulation, order, or industry standard, including UK and EU rules governing nuisance and unsolicited calls (Ofcom, the Privacy and Electronic Communications Regulations, and GDPR), U.S. FCC rules governing robocalls, call authentication, and traceback (47 CFR Part 64), the Telephone Consumer Protection Act (TCPA), and any applicable national telemarketing or debt-collection statutes.
• Engaging in threatening, harassing, defamatory, deceptive, or fraudulent conduct over the Services.
• Originating or knowingly transmitting illegal robocalls, spoofed caller ID used to defraud or harm a called party, or traffic subject to a notification of suspected illegal traffic, cease-and-desist order, or traceback request from the Industry Traceback Group (ITG), Ofcom, the FCC, or an equivalent authority.

1.2 Call Authentication and CLI Abuse

• Signing or requesting a STIR/SHAKEN attestation level that misrepresents Customer's relationship to the calling party or the calling party's right to use the calling number (“over-attestation”), including attesting gateway or unknown-origin traffic as full (A) attestation.
• Falsifying, spoofing, or manipulating calling line identification (CLI) other than through legitimate, disclosed, and lawful means (e.g., authorised branded calling or verified CNAM services).
• Relying on a certificate, SPC token, or attestation credential that does not belong to the entity actually making the attestation decision.

1.3 Traffic Fraud and Network Abuse

• International Revenue Share Fraud (IRSF) — directing or permitting traffic to premium-rate or high-cost destination ranges to generate improper settlement revenue, including traffic patterns consistent with compromised PBX/SIP-trunk credentials.
• Traffic pumping / access stimulation — artificially inflating call volume or duration to numbers or rate centres that generate above-market access or termination fees, absent a legitimate business purpose.
• Wangiri and callback fraud — one-ring-and-cut schemes designed to induce return calls to premium numbers.
• Toll fraud arising from compromised SIP trunks, PBXs, or subscriber credentials used to originate unauthorised traffic.
• Long-duration or abnormal calling patterns — including calls to a single destination number exceeding four continuous or cumulative hours in a 24-hour period, or call volumes materially inconsistent with Customer's stated traffic profile, business description, or historical usage, particularly where such activity provokes complaints or degrades network performance for other Users.
• Unsolicited or non-consensual calling/messaging — transmitting calls without required consent, or failing to honour opt-out/do-not-call requests where legally required.

1.4 Misrepresentation

• Providing false, incomplete, or misleading information about Customer's identity, business purpose, expected traffic profile, upstream/downstream relationships, or the ultimate originator of traffic carried over the Services.
• Concealing the true originating party of international traffic, or misrepresenting Customer's status as a gateway or intermediate provider where that status legally applies.

2. Compliance Obligations for Wholesale Voice Traffic

Because the Services operate in the international and U.S. carrier-to-carrier voice market, Customer additionally agrees to the following, each a condition of continued interconnection:

• Robocall Mitigation. If Customer is a voice service provider, gateway provider, or intermediate provider subject to robocall mitigation rules (including 47 CFR § 64.6305 for U.S. traffic), Customer represents that it maintains a current certification and robocall mitigation plan, and agrees to notify Mokrina promptly if it becomes ineligible to remain listed.
• STIR/SHAKEN. Customer will not present traffic bearing an attestation signed under a certificate or SPC token it is not authorised to use, and will make its own attestation decisions where required.
• Know-your-upstream / know-your-customer. Customer will exercise reasonable diligence regarding the identity and traffic practices of any party whose calls it hands off to Mokrina, and will cooperate with our requests for information necessary to respond to a traceback or regulatory inquiry.
• Traceback response. Customer will respond to any traceback request forwarded by Mokrina (including ITG requests) within the timeframe we specify, and in no event later than 24 hours, and will investigate and block confirmed illegal traffic promptly.
• Do-Not-Originate (DNO) and blocking. Customer will cooperate with Mokrina's reasonable and effective steps to block traffic identified as illegal, spoofed, or associated with a number on an applicable DNO list.
• Customer data. Where applicable, Customer will handle customer and network information consistent with applicable data-protection and CPNI-equivalent requirements.

3. No Harm to the Network or Other Users

Customer may not engage in, or knowingly permit, any activity that Mokrina determines could harm or degrade: (i) our network or interconnected carrier relationships; (ii) the integrity, security, or quality (including ASR, ACD, PDD, MOS, or NER metrics) of the Services; or (iii) the experience of our other customers. This includes attempts to circumvent rate limits, velocity caps, geographic or destination blocking, or other fraud-control measures we have implemented.

4. Monitoring and Enforcement

Mokrina may monitor traffic patterns, CDRs, and quality metrics on an aggregate and per-account basis to detect Prohibited Activities, and may implement automated controls (including velocity caps, greylisting, geographic/destination blocking, and real-time fraud scoring) without prior notice to Customer where we reasonably believe such controls are necessary to protect the network or comply with law.

5. Remedies

If Mokrina reasonably believes Customer has violated this Policy, we may take any action we deem necessary, including without limitation:

• Suspending or terminating the Services, in whole or in part, with or without prior notice depending on severity, including where traffic implicates an active traceback, a notification of suspected illegal traffic, or apparent IRSF/traffic-pumping activity;
• Blocking specific traffic, destinations, or calling parties;
• Charging Customer for all completed and pending traffic, including traffic later determined to be fraudulent or unauthorised, consistent with the applicable service agreement;
• Reporting Customer's conduct to Ofcom, the FCC, the Industry Traceback Group, relevant regulators or law-enforcement authorities, and cooperating with any resulting investigation;
• Sharing relevant account or traffic information with a third party that has notified us it was harmed by Customer's violation of this Policy; and
• Pursuing any other remedy available at law or in equity.

Mokrina's decision not to act on a particular violation does not waive its right to act on that or any future violation. Nothing in this Policy creates a cause of action in favour of Customer or any User against Mokrina.

6. Additional Terms

Specific Services (e.g., international gateway traffic, toll-free origination, or number/DID provisioning) may carry additional requirements set out in the applicable service order, interconnection agreement, or supplemental terms, which apply only to the extent Customer uses those specific Services.