What has the U.S. Government gained by formalizing Team Telecom?: Team Telecom and the FCC’s dual security approach

This paper examines the impact of formalizing informal institutions in the U.S. telecom license process. Any foreign telecom company seeking to provide services between a foreign country and the U.S. must obtain a Section 214 license from the Federal Communications Commission (FCC). In 2020, Executive Order 13913 formalized “Team Telecom,” an interagency group that had previously provided informal national security advice to the FCC.The formalization has highlighted stricter regulations, such as license revocations of Chinese firms, yet its broader objectives remain largely unexamined. Therefore, this paper examines FCC license records between 1997 and 2024 to gain a deeper understanding of Team Telecom’s informal and formalized reviews through a historical institutionalism approach. The findings reveal that, against the backdrop of China’s global rise, the formalization has not only strengthened Team Telecom’s role but has also enabled the FCC to expand its security policy purview. This conclusion draws on evidence indicating an increased likelihood of retroactive license terminations, implying that the formalization of Team Telecom was largely motivated by the need to scrutinize authorizations held by Chinese firms. Leveraging this precedent, the FCC has strategically broadened its interpretation of the foundational purpose of Section 1 of the Communications Act—“national defense” and “promoting safety of life and property”—to include security determinations. The paper argues that the formalization of Team Telecom presented an opportunity for the FCC to reinterpret its founding objectives and assert its security role with the support of Congress. This study offers a deeper understanding of new telecommunications regulations under Team Telecom and the FCC, marking a turning point in the FCC’s efforts to fulfill its role as a national security regulator.