Last week, I had the pleasure of attending the ESPC (Email Sender & Provider Coalition) annual meeting in Washington, DC. The ESPC is an advocacy organization that operates on behalf of email senders and other digital communications providers. The one-day meeting took places in the law offices of WilmerHale and featured industry speakers of all stripes, as well as Robert S. Mueller III, former director of the FBI.

Robert MuellerDirector Mueller gave a stirring speech in which he recounted the experience of leading the FBI during the September 11 terrorist attacks, and how the FBI transformed itself to focus on cyber crimes in the wake of the disaster. Director Mueller had much to say about the changes that occurred at the FBI, but one of his observations stands out: “The NSA has more geeks per square foot than any other agency in Washington, and you want those geeks on your side!” Yes, imagine you do.

I also had the pleasure of moderating a working group focused on international deliverability alongside Tara Natanson and Sam Silberman from Constant Contact and Spencer Kollas from Experian. The attendees broke into groups to discuss their experiences in remediating deliverability problems outside of North America and the MAGY (Microsoft, AOL, Gmail and Yahoo!). Here’s some of what we learned.

Working with international customers

In addition to operational topics focused on deliverability, we also talked about challenges vetting international clients and working across country borders and rules about data and privacy. One of the challenges faced when doing business with international senders or clients is contract enforcement. Several members of the group cited up-front fees, up to a year, as a show of good faith when negotiating a contract. Contract enforcement can be challenging when ESP and sender are in different geographies; further compounding the problem is the fact that a contract negotiated in February could have a very different value come October based on the behavior of monetary markets.

Do your homework before taking on international senders. Tools like eHawk and other third-party data sources can help vet potential clientele. Remember, your IPs are a business commodity that an unscrupulous customer can destroy; reputations are hard to build but easy to damage!

Deliverability to Asia

As we all know, China is a rapidly growing economy with an increasingly connected population. If you are doing, or plan to do, significant business in China, you may want to consider obtaining a local Chinese tax ID and even going so far as opening a local office. “Boots on the ground” was the consensus among my group for success in the Chinese market.

Another thing to consider is that sending tons of email during the night in China is frowned upon. And remember that daytime in North America is pretty much nighttime in China. Most Chinese recipients are receiving and reading email on mobile devices, and all of those mobile devices going off and waking up recipients will likely generate completes—so much, in fact, that receiving domains that are believed to limit transmission dates during the night. It’s a good reminder to consider segmenting your list by geography and sending time-appropriate communications to users in distinct locations.

Also, be sure to familiarize yourself with CASA (Chinese Anti-Spam Alliance), one of the major blacklist providers for the region. Their listings behave a little like SpamCop and self-expire, but should be indicative of potential deeper problems.

By the way, Yahoo! Japan ( applies additional filters to inbound email than does the mother ship in North America. This makes it more complex to deliver to the inbox. Just because you’re achieving good deliverability to doesn’t mean you’ll deliver to the regional domain in Japan.

Send globally but act (and comply) locally!

Although the Internet connects the global village there are still some very local and important rules to follow. If you plan on doing business in Russia or Germany, for example, you should consider setting up a local data center. Both countries have very strict requirements for data localization and privacy. The German law has been in effect for a number of years, but the Russian law is new. For more information on either you should consult your Chief Privacy Officer or check out the materials information coming out of the IAPP (International Association of Privacy Professionals).

Odds and ends

A few other tidbits to consider: anti-spam systems look at the language of your emails. Make sure you’re using the right encoding for the right geography, or use Unicode’s universal UTF-8. SMTP-UTF8 is here: this means that users can form email addresses that go beyond the limitations of the basic Latin alphabet). Make sure your MTAs are capable of sending and receiving messages on the truly global (and localized) Internet.

International bounce codes continue to be a challenge, and there are really only two solutions. Either you translate the extended descriptions to determine what the domain owner wants you to do, or you hope that the bounce code is accurate and focus your efforts on transient vs. permanent failures and their corresponding responses. Doing the latter should be done with the understanding that you’re going to make mistakes unless you translate the bounces yourself or get a handle on what they mean. Needless to say, either approach is better than doing nothing.

This represents just a portion of the great information we discussed at our meeting! For more insight, consider joining the ESPC. And, by the way, Dennis Dayman, ReturnPath’s chief privacy and security officer, and I will be hosting a webinar focused on International Deliverability in late October. Watch this space for more details.