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In brief

As part of the multi-pronged effort by the Infocomm Media Development Authority (IMDA) and other stakeholders to combat scams and safeguard SMS messaging as a communications channel, the IMDA will implement two measures following a public consultation:

  1. Mandatory registration with the Singapore SMS Sender ID Registry (SSIR): Registration with the SSIR will be mandatory for all organizations that use SMS Sender IDs.
  2.  Telecommunications operators to implement SMS anti-scam filtering solutions: Anti-scam filtering solutions will be implemented by telecommunications operators within their mobile networks to automatically filter potential scam messages before they reach consumers.

In depth

Full SMS sender ID registration 

The pilot SSIR regime was first launched in August 2021. However, due to an increase in scam messages, the setting up of the SSIR was accelerated in March this year. As a result, there was a marked 64% reduction in scams through SMS between the end of 2021 to mid-2022.

Sender IDs permit the identification of the sender of an SMS message, so that a word or phrase appears instead of a number. The SSIR regime allows organizations to block messages sent by scammers attempting to use these registered Sender IDs. In this way, the regime aims to prevent scammers from impersonating banks and other organizations.

Though registration with the SSIR is currently voluntary, registration will be made mandatory with effect from 31 January 2023. Only SMSes with registered Sender IDs will be transmitted, and all other Sender IDs will be blocked.

Notably, both local and foreign organizations registering with the SSIR must first present a local unique entity number (UEN) that can be obtained through registration with the Singapore Accounting and Corporate Regulatory Authority (ACRA).

As some organizations may need time to prepare and register, and because organizations’ SMS messages will not be clearly differentiated from other SMS messages that come from unknown sources, all non-registered SMS Sender IDs after 31 January 2023 will be channeled to a Sender ID with the header “Likely-SCAM” for a period of approximately six months. According to the IMDA, this is akin to a “spam filter and spam bin”. To avoid their messages being labelled as such, the IMDA encourages merchants to have their Sender IDs registered with the SSIR as early as possible.

Anti-scam SMS filtering solutions

From the end of October 2022, key mobile operators will implement anti-scam filtering solutions in their networks. This involves the use of machine-reading technology and it will take place in two phases.

The first phase involves the automatic scanning of SMS messages sent via the telecommunications network for malicious links, allowing the upstream filtration of potential scam messages. The second phase involves detection of keywords, phrases and formats typical of fraudulent messages.

Some messages may require further human assessment, in which case personal data will be stripped by the machine before being channeled to technical personnel for additional review. The hope is that the accuracy of the artificial intelligence system will increase over time and keep pace with scammers’ evolving tactics.

Comments

Notably, mobile operators Singtel, Starhub, and M1 have voiced concerns over privacy violations and SMS disruptions with the roll-out of the two above-mentioned measures. In particular, members of the public may not be aware that their SMS messages will be scanned. The involvement of human review is also cause for concern, even with anonymization measures in place.

With regard to SMS disruptions, concerns are that due to the nascence of anti-scam filters, SMS delivery could be degraded, resulting in delays of the delivery of, for example, OTPs (one-time passwords). Overseas organizations that are unaware of the SSIR regime would also be disadvantaged, and may ultimately choose not to send SMS messages to their customers in Singapore due to additional costs.

Read the other measures introduced to combat SMS-phishing scams in our earlier newsletter here.

Author

Andy Leck is the head of the Intellectual Property and Technology (IPTech) Practice Group and a member of the Dispute Resolution Practice Group in Singapore. He is a core member of Baker McKenzie's regional IP practice and also leads the Myanmar IP Practice Group. Andy is recognised by reputable global industry and legal publications as a leader in his field. He was named on "The A-List: Singapore's Top 100 lawyers" by Asia Business Law Journal 2018. In addition, Chambers Asia Pacific notes that Andy is "a well-known IP practitioner who is highlighted for his record of handling major trade mark litigation, as well as commercial exploitation of IP rights in the media and technology sectors. He's been in the industry for a long time and has always been held in high regard. He is known to be very fair and is someone you would like to be in the trenches with you during negotiations." Furthermore, Asian Legal Business acknowledges Andy as a leading practitioner in his field and notes that he “always gives good, quick advice, [is] client-focused and has strong technical knowledge for his areas of practice.” Andy was appointed by the Intellectual Property Office of Singapore (IPOS) as an IP Adjudicator to hear disputes at IPOS for a two-year term from April 2021. He has been an appointed member of the Singapore Copyright Tribunal since May 2010 and a mediator with the WIPO Arbitration and Mediation Center. He is also appointed as a Notary Public & Commissioner for Oaths in Singapore. He previously served on the International Trademark Association’s Board of Directors and was a member of the executive committee.

Author

Ren Jun Lim is a principal with Baker McKenzie Wong & Leow. He represents local and international clients in both contentious and non-contentious intellectual property matters. He also advises on a full range of healthcare, as well as consumer goods-related legal and regulatory issues. Ren Jun co-leads Baker McKenzie Wong & Leow's Healthcare as well as Consumer Goods & Retail industry groups. He sits on the Law Society of Singapore IP Committee and on the Executive Committee of the Association of Information Security Professionals. He is also a member of the Vaccines Working Group, Singapore Association of Pharmaceutical Industries, a member of the International Trademark Association, as well as a member of the Regulatory Affairs Professionals Association. Ren Jun is ranked in the Silver tier for Individuals: Enforcement and Litigation and Individuals: Prosecution and Strategy, and a recommended lawyer for Individuals: Transactions by WTR 1000, 2020. He is also listed in Asia IP's Best 50 IP Expert, 2020, recognised as a Rising Star by Managing IP: IP Stars, 2019 and one of Singapore's 70 most influential lawyers aged 40 and under by Singapore Business Review, 2016. Ren Jun was acknowledged by WTR 1000 as a "trademark connoisseur who boasts supplementary knowledge of regulatory issues in the consumer products industry." He was also commended by clients for being "very responsive to enquiries and with a keen eye for detail, he is extremely hands-on. His meticulous and in-depth approach to strategising is key to the excellent outcomes we enjoy."

Author

Ken Chia is a member of the Firm’s IP Tech, International Commercial & Trade and Competition Practice Groups. He is regularly ranked as a leading TMT and competition lawyer by top legal directories, including Chambers Asia Pacific and Legal 500 Asia Pacific. Ken is an IAPP Certified International Privacy Professional (FIP, CIPP(A), CIPT, CIPM) and a fellow of the Chartered Institute of Arbitrators and the Singapore Institute of Arbitrators.

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