The Lawfare Podcast

Lawfare Daily: FCC’s New Submarine Cable Rules with Adam Chan

Aug 20, 2025
Adam Chan, National Security Counsel at the FCC, offers insights into new regulations on submarine cables aimed at enhancing national security. He discusses the vital role these cables play in global communication, handling 99% of high-speed internet traffic. The conversation delves into requirements for cybersecurity certifications from license applicants and strategies to limit Chinese influence on U.S. infrastructure. Chan highlights the importance of collaboration between the government and industry to address emerging threats in the telecommunications landscape.
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INSIGHT

Submarine Cables Are Internet Backbone

  • Submarine cables carry ~99% of global high-speed internet traffic and huge daily financial flows.
  • Only ~600 global cables exist, with ~90 landing in the United States, so each is strategically critical.
INSIGHT

FCC Licenses; Team Telecom Reviews Security

  • The FCC licenses cables landing in the U.S. under the 1921 Cable Landing License Act and delegates review to Team Telecom.
  • Team Telecom (DOJ, DOD, DHS) conducts national security reviews and negotiates mitigation agreements the FCC can condition on licenses.
INSIGHT

Rule Follows NSPM-3: Protect And Promote

  • The FCC frames policy under NSPM-3: welcome trusted investment, block foreign-adversary risks, and streamline trusted parties.
  • The rule combines protections (restrictions, reporting) with promotion (streamlining, Build America support).
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