Dubious would have been seeking approval from a non-US regulator. That's abusing the framework but technically I think there's no reason you couldn't get the CI

Dubious would have been seeking approval from a non-US regulator. That's abusing the framework but technically I think there's no reason you couldn't get the CIO of Vanuatu (the relevant ITU administrator) to approve your satellite and have that be legal. The FCC would be mighty sour about that but I think you could do it. This is just straight-up illegal.