How we operate.

Who we are

MB Codus Nullus, a private limited company registered in the Republic of Lithuania. Registered office in Vilnius. Operating as a wholesale telecommunications provider under EU regulatory framework.

Legal name

MB Codus Nullus

Jurisdiction

Lithuania (EU member state)

Company registration

Available on request

VAT number

Available on request

RTK / NAT registration

In progress with RRT

Operating address

Vilnius, Lithuania

Where we source

For v1 we operate as a Voxbeam reseller with our own SBC and dispatcher in front. The architecture is multi-upstream-ready: customers connect to our edge, we authenticate and route, and the upstream is a routing decision rather than a customer-visible contract.

• - Customers never sign a contract with our upstream; they contract with us.
• - When a new upstream is activated, every active customer is notified by email and in the portal at least 14 days before any traffic begins to route over it.
• - When an upstream is removed, any DIDs hosted there are ported to a remaining upstream before removal completes; portability windows are communicated in advance.
• - No customer SIP configuration changes when upstreams are added or removed.

How DIDs work

Two tracks: API-orderable and regulatory-required. The same endpoint serves both; the response indicates which track applies.

More countries available on request. The matrix above covers the most-requested set; the full inventory is in the portal.

Typical document set per region

KYB and business identity

For wholesale accounts we run know-your-business checks before activating outbound termination. The checks are proportionate to the volume and risk profile.

What we collect

• - Company registration extract and tax ID
• - Beneficial-ownership disclosure for owners above 25%
• - Government-issued ID for the responsible signatory
• - Description of intended traffic and target geographies

Who sees it

• - Our internal compliance team (named individuals, audited access).
• - Relevant upstream operators when a country requires it for provisioning. Sharing is limited to what the upstream needs and is logged.
• - Lawful authorities when compelled by a valid order from a competent jurisdiction (see below).

We retain KYB records for the duration of the customer relationship plus the period required by Lithuanian and EU law (currently 5 years after termination for AML records; up to 10 years for accounting records).

A customer may close the account at any time. KYB records remain only for the legally required retention period and are then deleted.

AML and sanctions

• - We do not knowingly carry traffic to or from designated persons or entities on EU, UK, or US sanctions lists.
• - New customers are screened against EU consolidated, UK OFSI, and US OFAC SDN lists at onboarding and rescreened on list updates.
• - Suspicious-activity reporting follows Lithuanian Financial Crime Investigation Service (FCIS) procedure where applicable.
• - A customer found to be sanctioned after onboarding is suspended pending review and reported to the relevant authority.

Data

• - Customer business data (account, invoices, KYB documents) is stored in Hetzner data centres in Germany and replicated within the EU.
• - Edge configuration and short-lived caches are processed by Cloudflare globally; no long-term customer data is stored at the edge.
• - CDRs are stored on EU-resident infrastructure for the period required by Lithuanian retention rules.
• - Access to customer data is limited to named team members and is audited. Production access requires VPN, hardware key, and per-action logging.
• - Data subjects may exercise EU GDPR rights (access, rectification, erasure within retention limits) by writing to [email protected].

Reporting and cooperation

We respond to lawful requests from competent authorities. The applicable jurisdiction is Lithuania.

• - Requests must be served on the operating entity at our registered address or via email to [email protected].
• - Foreign requests must come through Lithuanian channels (mutual legal assistance treaty, EU evidence framework, or equivalent) unless directly applicable under EU regulation.
• - Customers are notified of requests for their data unless a court order specifically prohibits notification.
• - A short transparency note about request volumes is published annually.

Number portability

Where the destination country supports porting, we accept incoming and process outgoing port requests at no markup beyond the upstream pass-through cost.

• - EU domestic porting: typically 5 to 10 business days, subject to losing-carrier response.
• - UK porting: typically 5 business days.
• - US toll-free RespOrg change: typically 3 to 5 business days.
• - Outgoing port requests are processed within one business day of receiving a valid LOA.

Termination quality

Quality targets, monitoring methodology, and the auto-rotation policy are summarised on the voice termination page.

See voice termination quality commitments →

Compliance, legal, or procurement question?

Write to [email protected] for KYB, AML, or sanctions questions; [email protected] for lawful requests and contracts; [email protected] for data-protection matters. A reply lands within one business day.