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<aside> ➡️ Examples of Telecommunication and Internet Infrastructure Companies: ISPs (MTN), Mobile Operators and Content Delivery Networks (CDNs)

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<aside> 🔷 In its 2020 transparency report, the South African telecom MTN included its Iran subsidiary Irancell, providing partial figures on government requests for user data and network restrictions. However, in MTN's 2021 report, Irancell's data vanished entirely. The report stated Iran was excluded due to insufficient information and in-country reporting limitations [19]. Digital rights groups suspect MTN Irancell, which is jointly owned by Iranian state-linked Kowsar Sign Paniz, faced government pressure to remove evidence of state surveillance and network interference [20].

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Human Rights Concerns

<aside> 📌 (UDHR Article 3: Right to life, liberty, security; UDHR Article 2: Freedom from discrimination; UDHR Article 12: Privacy; UDHR Article 19: Freedom of Expression & Access to Information; UDHR Article 21: Political Participation)

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One major human rights concern is that telecommunications and internet infrastructure companies may enable censorship and surveillance in Iran by providing technologies and services that empower the Iranian government to restrict citizens' access to information and monitor their online activities. These activities clearly infringe on Iranians' fundamental rights to freedom of expression, access to information, and privacy. In the past, there have been documented cases of companies like MTN allegedly establishing monitoring centers that perform deep packet inspection, aiding the government's suppression of dissent and control of information [21].

In the case mentioned above, foreign internet infrastructure and telecommunication companies may decide to exit the country to avoid dealing with reputation risks. However, Internet infrastructure companies should carefully consider potential impacts on connectivity and human rights when exiting markets in authoritarian countries. As chokepoints of access, divestment without ensuring continuity of infrastructure service can severely compromise users' digital rights. Companies should conduct human rights impact assessments, and work with civil society groups to advocate for safe alternative providers. Responsible exit plans preserving connectivity should be prioritized over quick sales to state-owned entities. Telenor’s exit in Myanmar demonstrates the severe consequences when telecom infrastructure falls under military control post-divestment [22].

Another issue is companies disrupting access to online content, services, and websites for Iranian users through practices like wholesale IP address blocking. Reports indicate providers like Amazon CloudFront have instituted disruptive bans on Iranian IPs, temporarily denying access to many services dependent on the provider [23]. Such arbitrary denials of access severely restrict Iranian citizens' human rights to seek, receive, and impart information online. In addition, Amazon Web Services' new policy to charge for public IPv4 address usage will severely affect Iranians' access to online services, as many technology providers may block Iranian IP addresses to avoid these extra costs [24].

Companies also sometimes impose discriminatory limitations on Iranian users trying to access services like accounts, domain registration, content delivery networks, etc. solely due to their nationality. There are reports of domain registrars like GoDaddy frequently rejecting registration requests from Iranians, hurting entrepreneurs [25]. Although we understand some of these take-downs are due to alleged misinformation and campaigns by the Islamic Revolutionary Guard Corps (IRGC), blanket rejections and discrimination against Iranians inhibit their ability to access the global internet, violating norms of non-discrimination and pushing them toward domestic alternatives that can be easily controlled and censored by the government.

There are also net neutrality concerns when providers arbitrarily restrict services like CDNs or network traffic for Iranians based solely on geography rather than valid behavioral reasons. Some CDN providers have openly disabled services for Iranians based on nationality alone, contradicting principles of net neutrality. In addition, many companies dealing with the Iranian government fail to provide transparency around issues like surveillance, censorship, requests for user data, and other human rights risks, similar to the example provide above about MTN.

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