US. Department of Justice

 

Federal Bureau of Investigation

 

Washington, DC. 20535-0001

November 25, 2019

The Honorable Charles E. Schumer
United States Senate
Washington, DC. 20510

Dear Senator Schumer:

On behalf of the Federal Bureau of Investigation (FBI), this responds to your letter, dated
July 17, 2019, to the FBI and the Federal Trade Commission (FTC) regarding the mobile
software application aceApp.

The language of FaceApp?s terms of service and end user license agreement describes the
mechanisms aceApp uses for access to a device?s analytics information, cookies, log ?le
information, device identi?ers, and metadata, and to any user content and communications made
directly between the user and FaceApp. Social media providers generally use such mechanisms
to obtain consent from users. Speci?c to aceApp, however, is the submission of a user?s photo
for manipulation, which FaceApp uploads to cloud servers hosted (according to aceApp) in the
United States, Singapore, Ireland, and Australia. FaceApp has publicly claimed that it removes
most photos from its servers 48 hours after submission.

The FBI considers any mobile application or similar product developed in Russia, such as
FaceApp, to be a potential counterintelligence threat, based on the data the product collects, its
privacy and terms of use policies, and the legal mechanisms available to the Government of
Russia that permit access to data within Russia?s borders. Russia?s intelligence services maintain
robust cyber exploitation capabilities as evidenced by, for example, Russia?s surveillance system,
the System of Operative Search Measures, which allows the Russian Federal Security Service
(F SB) to obtain telephonic and online communications via direct connection to internet service
providers (ISP). In other words, the FSB can remotely access all communications and servers on
Russian networks without making a request to ISPs.

If the FBI assesses that elected of?cials, candidates, political campaigns, or political
parties are targets of foreign in?uence operations involving aceApp, the FBI would coordinate
noti?cations, investigate, and engage the Foreign In?uence Task Force, as appropriate. The
Protected Voices webpage on FBI. gov provides publically accessible videos on the most
urgent cybersecurity issues that may leave an election campaign?s computer networks vulnerable
to attack.

 

The Honorable Charles E. Schumer
Page Two

Thank you for your continued support of the FBI, its mission, and its people.

Sincerely,


L- .
.1111 C. Tyson
Assistant Director
Of?ce of Congressional Affairs

Co: The Honorable Joseph Simons, Chairman
Federal Trade Commission