Roaming Agreement had been effected, a situation which is denied by ETKL. In the circumstance, it is surprising that ETKL has not taken the reasonable step of querying the genesis of the bill with AREDU; h) That if indeed there was a valid roaming bill to ETKL in respect of unauthorized roaming calls, this points to high level fraudulent activity; i) The suspected practice of call-back scenario as presented by ETKL is not technically feasible and raises more questions than answers. The Commission has carefully analyzed the suspected scenario and finds it necessary to bring out its interrogation of this aspect as shown in italics here below : a) B party (Say 0751xxxxxx) calls access number +254 751362050 ( ACL number issued by ETKL in Kenya) b) ACL Initiates call-back through internet to an ISP provider in Dubai – A Call back means the calling number (B-party-0751xxxxxx) is called back from Dubai and the number to call back will be a Dubai number (not ETKL number to generate a roaming TAP file) c) The call is dropped but Dubai gets all call details & calls back through DU GSM Network (local call) When the call is dropped, the B number details will be known to the Dubai ISP for call back and a call back will be initiated to B party (0751xxxxxx) by a Dubai number. How then will the same B-party (0751xxxxxx) appear to be calling from Dubai when it is supposed to be called back in Kenya? d) This call generates a TAP file payable by ETKL. (How can a number being called back in Kenya generate a TAP (roaming) file, when it is supposed to be called back while in Kenya? How possible is it that a Kenyan number will call a GSM network through an SS7 link of an ISP in Dubai? e) Through the internet, the call gets terminated in ACL Kenya f) ACL Kenya delivers the call to ETKL through E1 connection (If this is the case, did ETKL bill ACL for any calls delivered through the E1 link? The Commission was informed that ACL does not get any bill from ETKL as per the current arrangement. The link provided is bidirectional but ACL only uses one direction of calls coming from ETKL to ACL through the E1 link. Page 9 of 11