Protecting Our Communications Networks by Promoting Transparency Regarding Foreign Adversary Control

Introduction

China’s growing ambition to dominate the global telecommunications market has manifested across a range of industries, from drones to submarine cables. Spurred by aggressive industrial policies such as Made in China 2025, Beijing has poured resources into becoming a global leader in science and technology, by innovating or stealing key breakthroughs and using its vast manufacturing capacity to add weight to its advances.[1] This practice has given China expansive leverage over several key markets, including drones connected to U.S. networks, telecommunications and broadband infrastructure, undersea communications cables, and equipment-testing laboratories.

This threat has been heightened by China’s extensive legal and regulatory architecture intended to provide Beijing with leverage over key American markets. China’s National Security Law, National Intelligence Law, and Cybersecurity Law facilitate Chinese authorities’ access to information collected by firms and individuals subject to Beijing’s jurisdiction, effectively blurring the lines between commercial ventures and intelligence collection.[2] This issue is only heightened by the CCP’s reliance on other mechanisms to control private firms, such as seizing “golden shares” and placing party cadres in key roles to direct corporate strategy.[3]

In response, the Federal Communications Commission (FCC) should broaden the scope of its foreign ownership reporting requirements to cover all applicants for licenses, permits, and other authorizations. This expansion will streamline efforts to prevent China and other foreign adversaries from accessing the nation’s telecommunications network, while preventing states, entities, and individuals from circumventing reporting requirements.

The FCC should also expand the definition of foreign ownership to include entities controlled by, or subject to, the jurisdiction or direction of a foreign adversary. This expansion will stymie Beijing’s efforts to use its regulatory and legal architecture to coerce nominally independent firms into furthering the CCP’s geopolitical ambitions.

Recommendations to Strengthen the Cyber-Physical Resilience of U.S. Telecommunications

To safeguard U.S. national security, the Commission should expand foreign ownership disclosure requirements for all licenses, applications, and other issued certifications while broadening its definition of foreign ownership to encompass firms subject to, or under the jurisdiction of, a foreign adversary.

• The Commission should request foreign ownership disclosure requirements for all licenses, applications, and other issued certifications, including both positive and negative attestations. The FCC should require applicants to certify whether or not they are owned or controlled by a foreign adversary, rather than simply requiring applicants to assert they are not under foreign adversarial control. This change will be effective in building out a more comprehensive registry while also allowing for potential prosecution of claimants found to be falsifying submissions.
• The Commission should require additional information from regulated entities with reportable foreign adversary control. The Commission should require firms or individuals under its regulatory jurisdiction to report on their interactions with a foreign adversary government, including its officials or officers of its dominant political party. The Commission should also require these regulated entities to submit to standard questions as part of the executive branch review process. This process should also force regulated entities to report on interactions within the United States, particularly on contracts with U.S. entities, products, and services, and their interactions with U.S. communications networks.
• The Commission should require regulated entities to inform the Commission of any deficiencies in complying with its requests to solicit information regarding their relationships with foreign adversaries. The Commission should be required to send a letter to request explanations or corrections from regulated entities; a failure to comply within 30 days should result in the Commission automatically revoking the regulated entities’ covered authorization.
• The Commission should expand sourcing for its list of “foreign adversaries” to include the Consolidated Screening List and other designations. Along with its current Covered List, the Commission should also rely on the Consolidated Screening List, a list of parties for which the U.S. government maintains restrictions on exports, reexports, or the transfer of items. In determining its list of “foreign adversaries,” the Commission should also rely on the Entity List maintained by the Bureau of Industry and Security and the 1260H List maintained by the Department of Defense.

[1] Emily de La Bruyère, “Made in China 2025—Who Is Winning?” Foundation for Defense of Democracies,

February 6, 2025. (https://www.fdd.org/analysis/2025/02/06/made-in-china-2025-who-is-winning); “Outline of the People’s Republic of China 14th Five-Year Plan for National Economic and Social Development and Long-Range Objectives for 2035,” Xinhua News Agency, March 12, 2021. (archived version available at

https://perma.cc/73AKBUW2)

[2] Craig Singleton and Mark Montgomery, “Laser Focus: Countering China’s LiDAR Threat to U.S. Critical Infrastructure and Military Systems,” Foundation for Defense of Democracies, December 2, 2024. (https://www.fdd.org/analysis/2024/12/02/laser-focus-countering-chinas-lidar-threat-to-u-s-critical-infrastructure-and-military-systems/)

[3] Jack Burnham and Johanna Yang, “Protecting Our Communications Networks by Promoting Transparency Regarding Foreign Adversary Control,” Foundation for Defense of Democracies, July 21, 2025. (https://www.fdd.org/analysis/2025/07/21/protecting-our-communications-networks-by-promoting-transparency-regarding-foreign-adversary-control/)