Messaging, Malware and Mobile Anti-Abuse Working Group (M³AAWG) supports the U.S. Federal Trade Commission’s (FTC) proposed rulemaking as part of its current mission in protecting the public from deceptive or unfair business practices to include a critical role in protecting consumers from ongoing and increasing impersonation schemes targeting businesses and governments alike. M³AAWG suggests additional regulatory solutions and best practices to complement the goals of this rule, such as clarifying the scope of the rule to include the use of domain names in impersonation schemes and the use of technologies that enable impersonation. M³AAWG notes that the investigation of impersonation schemes requires cooperation and information from many entities.  Specifically, WHOIS information is vital to the investigation of impersonation scams. The Comment identifies best practices to tackle impersonation scams, including the validation of commercial senders, DNS mitigation steps, and adoption of trusted notifier relationships to facilitate abuse reporting.

As a followup to the June 2021 survey report of cyber investigators and anti-abuse service providers on the ongoing impacts of ICANN’s implementation of the EU GDPR, the Temporary Specification for gTLD Registration Data (Temporary Specification, adopted in May 2018), M3AAWG and the Anti-Phishing Working Group (APWG) has released their recommendations for ICANN'S consideration.