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Pillsbury’s communications lawyers have published the FCC Enforcement Monitor monthly since 1999 to inform our clients of notable FCC enforcement actions against FCC license holders and others.  This month’s issue includes:

  • FCC Proposes $25,000 Fines Against Eight Companies for Failing to Respond to Enforcement Bureau Letters of Inquiry
  • Louisiana Broadband Provider Enters $10,000 Consent Decree to Resolve Investigation into Inaccurate Reimbursement Program Certification
  • Texas AM Stations Face Possible License Revocation Over Unpaid Regulatory Fees

Eight Companies Face $25,000 Fines for Failing to Respond to FCC Letters of Inquiry

The FCC’s Enforcement Bureau (Bureau) issued eight Notices of Apparent Liability for Forfeiture (NALs) proposing a total of $200,000 in fines against eight companies for failing to respond to Bureau Letters of Inquiry (LOIs).  Each company faces a proposed $25,000 fine for failing to respond to an LOI seeking information about whether it marketed radiofrequency equipment in the United States that was included on the FCC’s Covered List.

In November 2022, the FCC adopted rules implementing the Trusted Networks Act, which, among other things, prohibit entities or equipment included on the Covered List from obtaining new equipment authorizations for the “covered equipment.”  The adopted rules were prospective and did not revoke authorizations for previously authorized equipment, though the rules do prevent such equipment from being modified.

In October 2025, the FCC began the process of updating its equipment authorization rules to enable it to place additional limitations on previously authorized equipment.  In December 2025, the FCC expanded the Covered List to include the first categorical prohibition, adding all foreign-produced uncrewed aircraft systems (UAS) and UAS Critical Components, as well as two named UAS manufacturers identified in Section 1709 of the FY2025 National Defense Authorization Act.  The FCC has subsequently added three additional categories of foreign-produced devices to the Covered List (commercial routers, power inverters, and advanced robotic devices).

Between March and May 2026, the FCC opened investigations and issued LOIs to eight companies that produce UAS and UAS Critical Components abroad.  The NALs cite to publicly available information (including published articles based on a post in an online forum) suggesting certain products marketed by each of the companies were exact hardware copies of covered equipment and that one company may have marketed equipment incorporating the same code or proprietary communications protocols used in covered equipment.

The Bureau issued the LOIs to investigate whether the companies were marketing “disguised covered equipment” and to determine whether the equipment complied with FCC regulations.  None of the companies responded to the LOIs, leading the Bureau to issue the NALs in July 2026.

The Bureau based its enforcement finding on the conclusion that an LOI is a Commission “order” under Section 503(b) of the Communications Act, and failing to respond to an LOI is a violation of that order.  Section 503(b) authorizes the FCC to fine an entity found to have willfully or repeatedly failed to comply with an FCC rule or order up to $25,132 for each day of a continuing violation, up to a statutory maximum of $188,491 for a single act or failure to act.  The FCC’s forfeiture guidelines establish base fines for certain violations and identify the factors it should consider when determining whether a higher or lower fine is warranted.  Under the FCC’s Rules, the base fine for failing to respond to an FCC communication is $4,000.

In each NAL, the Bureau proposed an upward adjustment to $25,000, concluding that the alleged violations were egregious, intentional, and continuing because the respective company’s failure to respond impeded investigations involving potential risks to national security and the nation’s communications infrastructure.  The FCC declined to make any downward adjustments, explaining that a failure to respond to investigative inquiries involving potential national security risks is not a minor violation.

In addition to proposing the fines, the Bureau ordered each company to fully respond to its outstanding LOI within ten days of the release of the NAL.  The Bureau warned that failure to comply could constitute an additional continuing violation subject to further enforcement action.

In a concurrent action a week after the NALs were issued, the FCC released a Public Notice proposing to limit the scope of the companies’ respective existing equipment authorizations.  The FCC tentatively concluded that equipment identified in the Public Notice is “covered equipment” and if the proposals are adopted, such covered equipment would be prohibited from any further importation and marketing activities 30 days after publication of a final decision in the Federal Register.

Louisiana Broadband Provider Agrees to Pay $10,000 to Resolve Investigation Into Inaccurate FCC Certification

The FCC’s Enforcement Bureau entered into a Consent Decree requiring a Louisiana broadband services provider to pay $10,000 to resolve an investigation into inaccurate statements made in connection with the Secure and Trusted Communications Networks Reimbursement Program.  The investigation concerned whether the provider violated Section 1.17(a) of the FCC’s Rules by incorrectly certifying that it had permanently removed, replaced, and disposed of all covered communications equipment from its network where it was unable to confirm the proper disposal of such equipment. Continue reading →

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August 1 is the deadline for broadcast stations licensed to communities in California, Illinois, North Carolina, South Carolina, and Wisconsin to place their Annual EEO Public File Report in their Public Inspection File and post the report on their station website.

Under the FCC’s EEO Rule, all radio and television station employment units (“SEUs”), regardless of staff size, must afford equal opportunity to all qualified persons and practice nondiscrimination in employment.

In addition, those SEUs with five or more full-time employees (“Nonexempt SEUs”) must also comply with the FCC’s three-prong outreach requirements.  Specifically, Nonexempt SEUs must (i) broadly and inclusively disseminate information about every full-time job opening, except in exigent circumstances, (ii) send notifications of full-time job vacancies to referral organizations that have requested such notification, and (iii) earn a certain minimum number of EEO credits based on participation in various non-vacancy-specific outreach initiatives (“Menu Options”) suggested by the FCC, during each of the two-year segments (four segments total) that comprise a station’s eight-year license term.  These Menu Option initiatives include, for example, sponsoring job fairs, participating in job fairs, and having an internship program.

Nonexempt SEUs must prepare and place their Annual EEO Public File Report in the Public Inspection Files and on the websites of all stations comprising the SEU (if they have a website) by the anniversary date of the filing deadline for that station’s license renewal application.  The Annual EEO Public File Report summarizes the SEU’s EEO activities during the previous 12 months, and the licensee must maintain adequate records to document those activities.

For a detailed description of the EEO Rule and practical assistance in preparing a compliance plan, broadcasters should consult The FCC’s Equal Employment Opportunity Rules and Policies – A Guide for Broadcasters published by Pillsbury’s Communications Practice Group.

Deadline for the Annual EEO Public File Report for Nonexempt Radio and Television SEUs

Consistent with the above, August 1, 2026 is the date by which Nonexempt SEUs of radio and television stations licensed to communities in the states identified above, including Class A television stations, must (i) place their Annual EEO Public File Report in the Public Inspection Files of all stations comprising the SEU, and (ii) post the Report on the websites, if any, of those stations.  Once the new Report is posted on a station’s website, the prior year’s Report may be removed from that website. Continue reading →

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This advisory is directed to television stations with locally produced programming whose signals were carried by at least one cable system located outside the station’s local service area or by a satellite provider that provided the station’s signal to at least one viewer outside the station’s local service area during 2025. These stations may be eligible to file royalty claims for compensation with the U.S. Copyright Royalty Board. These filings are due by July 31, 2026.

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