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Middle East Regulatory Compliance for Electronics

“One pound of learning requires ten pounds of common sense to apply it.” – Persian Proverb

Containing about half of the proven global oil reserves, the countries in the Middle East have a solid base for their economies in the petroleum extraction and refinement industries, and have been expanding into other fields, such as finance, banking, and software. Many of these countries have been investing huge amounts in information technology equipment (ITE) and Internet infrastructure. In addition, the citizens of these countries want access to the latest smart phones and electronic products and devices, such as those available to their neighbors in Europe. So demand is growing in their consumer markets as well, making them very attractive to many ITE and electronics companies.

Companies considering entry into these market countries need to weigh the possible benefits against the risks in this region. Political instability and unrest, as well as ongoing armed conflicts within and between countries, present special challenges that must be addressed and evaluated prior to making business decisions. In fact, certain countries are restricted from trade by embargoes established by the U.S. government (identified later in this article). One useful online source of country-specific information is the Central Intelligence Agency World Factbook website [1], which is the source for data concerning the economies and infrastructure of these countries presented in this article. However, despite these issues, many companies have found successful markets for their products in most of these countries by understanding the laws, requirements, and restraints on the importation and sales of electronic products, and by identifying local partners to assist with this process.

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There are different levels of complexity and development in the compliance programs for the sixteen selected countries addressed here. For example, Saudi Arabia and Israel have had comprehensive product compliance programs in place for many years, with their own agency standards covering the EMC, product safety, and telecommunications attributes. Conversely, most other countries regulate only the telecom and wireless radio aspects of electronic products, chiefly to protect the radio frequency (RF) spectrum allocated to emergency and military radio operations within their borders. Regulators in these countries typically rely on the standards or compliance reports of other countries to provide assurances that the products are acceptable for use in their countries.

One important caveat. This article is only intended to provide summary information regarding the regulatory agencies and requirements in the countries discussed. The article should not be viewed as offering legal advice, nor should it serve as your only source of information for obtaining product approvals. You should always obtain the official standards and laws that are applicable to your products for each country. In addition, if you are not thoroughly familiar with the regulatory requirements and trade restrictions for countries in this region, the services of experienced regulatory consultants as well as legal experts in trade and importation of products for each market country should be utilized to avoid legal issues and to ensure that your products get to your customers.

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Turkey

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Turkey is a modern country that has been intensively working to strengthen its economy and democracy since 2005, when it first began talks with the European Union (EU) and the process of becoming a full EU member state. The gross domestic product (GDP) at purchasing power parity (PPP) for Turkey is ranked 18th in the world. While discussions with the EU have been progressing, no date has been set for achieving full EU member state status.

Although Turkey is not yet an EU member country, regulators and customs officials accept the EU’s “CE” Declaration of Conformity (DoC), CE product label mark, and EU directive reports as proof of compliance for many categories of products entering their country. EU regulations applicable in Turkey include those for electromagnetic compatibility (EMC), safety low voltage, medical, and industrial.

The Information and Communications Technologies Authority (ICTA) is the telecom authority of Turkey. While they accept the EU’s R&TTE Directive compliance reports, ICTA defines the mandatory approval requirements for wireless and telecom products, and has the right to review or reject any application that might interfere with protected frequencies, such as those for emergency or military uses, or products that might cause degradation to their telephone telecommunications infrastructure. Typically, the ICTA does not ask for product samples as part of the approval process.

The ICTA requires that an authorized local representative for the manufacturer or importer is physically located in Turkey, who is responsible for maintaining a file of approved products and certificates. This local representative can be a company employee at a branch office in Turkey, or an agent hired to represent the company who has been provided with a notarized letter of authorization from the company attesting to that fact.

Certificates issued by ICTA are permanent as long as the product does not change. If the product is changed, the updated product must go through
a resubmittal process, and the updated product cannot be imported until a new approval has been issued. ICTA has an English-language website
(http://eng.btk.gov.tr/) with additional information on their responsibilities and programs.

Cyprus

Cyprus joined the EU in 2004 and therefore accepts all of the standard EU Directive “CE” reports, CE DoCs, and CE markings, meaning that products can be imported and sold in here just like in any of the other 27 EU member countries. However, there are long-standing political difficulties dating back to 1960 when Cyprus obtained its independence from the United Kingdom. Since that time, the Greek Cypriot majority in the south and the Turkish Cypriot minority in the north have each tried to establish control of this island country. Both sides resumed United Nations-sponsored talks at the beginning of 2014 in an effort to achieve a political solution, so there is hope that a reconciliation will eventually be achieved.

In practical terms, this means that the EU body of common rights and obligations for citizens only applies to the areas currently under the authority of the internationally-recognized Greek Cypriot government, and is not applicable to those areas under the authority of the Turkish Cypriot government (which is recognized only by Turkey). Therefore, it is vital to have local expertise on what areas of the country will accept CE approved products.

The Cyprus Telecom Authority (CYTA) is the telecom authority for this country. While Cyprus is an EU member and accepts the EU CE mark as proof of compliance, CYTA is still the national authority with the final say on approving wireless and telecom products in order to safeguard their radio spectrum and telecommunications infrastructure. This agency has an English-language website (www.cyta.com.cy/personal/en) where additional information is available.

Syria

Syria is a U.S.-embargoed country as a result of sanctions implemented in 2004 by the U.S. Department of the Treasury Office of Foreign Assets Control (OFAC). The Syrian sanctions program is one of the most comprehensive currently in place, and deals with a multitude of issues that pose a potential threat to the national security, foreign policy and economy of the U.S. [2] The full text of the current sanctions can be obtained at the OFAC website [3]. However, in almost all cases, U.S. companies are legally barred from trading with Syria.

Iraq

Iraq has experienced internal and external conflict for many decades, but now has a democratically-elected government, and is in the process of rebuilding the country’s infrastructure, including telecommunications and Internet/ITE facilities. Iraq’s GDP-PPP ranking has been improving in the past few years, and the country is now ranked 38th in the world.

Unlike Syria, Iraq is not currently subject to a wide-ranging U.S. sanctions program. However, there are prohibitions in place targeted at specified individuals and organizations associated with the former regime, as well as those groups that have committed violence, or pose a substantial risk of violence, with the intention of disrupting the peace and stability of the people and government of Iraq [4]. A complete listing of these targeted individuals and organizations can be found on the OFAC Specially Designated Nationals List webpage. [5]

Certain “dual-use” technologies, that is, devices that have both military and non-military applications, are restricted. Information on determining if a specific commodity will require an export license from the U.S. Department of Commerce can be found by first determining the Export Control Classification Number (ECCN) for the product, and then by accessing the Commerce Control List (CCL) found in the Bureau of Industry and Security section of the Department of Commerce website. [6] The ECCN is an alpha-numeric code that designates the product and specifies the licensing requirements. For example, for an ECCN code of “3A001,” “3” would place it in the “electronics” category, and the “A” would place it in the “systems, equipment, and components” group.

The Communications and Media Commission (CMC) is the telecom authority for Iraq. They accept EU R&TTE Directive compliance reports as proof of compliance, but reserve the right to review applications for products that could interfere with critical radio spectrum, such as emergency or military channels, or those that directly connect to their telephone telecommunications systems. Test samples are not normally required, but the CMC does require that an authorized local representative for the manufacturer or importer of the product be located in Iraq.

Certificates issued by CMC are valid for one year, and then must be renewed on an annual basis for as long as the product continues to be sold in Iraq. If the product is changed, the updated product must be resubmitted for approval, and cannot be shipped into the country until the new certificate has been issued. The CMC has an English-language website (www.cmc.iq/en) where additional information is available.

Iran

Although Iran recently began diplomatic talks with the U.S., it is still a U.S.-embargoed country, with sanctions dating back to 1979 when the current government came to power. Iran is one of only five countries in the world that have in place a nearly total prohibition of trade with the U.S., except in cases related to humanitarian aid. While there is hope for diplomatic progress and an eventual lifting of the embargo, the sanctions currently in place are in response to multiple disputes with the Iranian government over potential threats to the national security, foreign policy, and economy of the U.S. [7] The full text of the current sanctions can be found at the OFAC webpage. [8] In almost all cases, U.S. companies are legally barred from trading with or importing to Iran.

Lebanon

Lebanon has experienced much unrest within its borders for several decades, but has enjoyed a relatively peaceful period during the past several years. For the past two years, Lebanon’s GDP-PPP has been ranked 88th in the world.

While there is not a broad-based U.S. sanctions program in Lebanon, there are targeted prohibitions in place for specific persons who may act to destabilize the democratically-elected government or economy of this country, or who take actions to collapse the rule of law, or who help Syria control or interference with the people or institutions of Lebanon. [9] A listing of these targeted individuals can be found on the OFAC Specially Designated Nationals List webpage. [5]

Certain dual-use technologies with both military and non-military uses are restricted from entering Lebanon. Information to determine whether a specific commodity will require an export license from the U.S. Department of Commerce can be found by first determining the Export Control Classification Number (ECCN) for the product, and then accessing the Commerce Control List (CCL) found in the Bureau of Industry and Security section of the Department of Commerce website. [6]

The Telecommunications Regulatory Authority (TRA) is the telecom authority for Lebanon, overseeing both hard-wired and wireless products. The TRA accepts EU R&TTE Directive compliance reports as proof of compliance, but reserve the right to review applications for telecom products that could interfere with radio frequencies reserved for use by emergency services and military units, or telecom products that connect to the Lebanese national telephone network.

Neither test samples nor a local representative are required, and the TRA website (www.tra.gov.lb) is in English, which provides access to TRA regulations, decisions, and application forms. Certificates provide by TRA have no expiration date, but they do require an update submittal any time the product is substantially changed.

Jordan

Jordan is a moderately progressive country that has implemented modest political and economic reforms. Compared with many other countries in the Middle East, Jordan does not have access to enough natural resources, such as water or oil, to be self-sufficient. Jordan is ranked 89th in the world in terms of GDP-PPP, and relies on foreign assistance to support its economy.

The Telecommunications Regulatory Commission (TRC) is Jordan’s government agency for wireless and telecom products. The TRC accepts both EU R&TTE Directive compliance reports and FCC grant and reports as evidence of compliance with it requirements. The TRC is responsible for the protection and assignment of their frequency spectrum, and also establishes the criteria and processes for product compliance approvals. Test samples for in-country testing are typically required as part of the submittal package for approvals.

The TRC requires a Jordanian-based local representative authorized by the manufacturer or importer, who is responsible for maintaining a file of approved products, certificates, and reports. This representative can be a company employee at a company office in Jordan, or an agent that has been hired to represent the company and who holds a notarized letter of authorization from the company attesting to that fact.

Certificates granted by the TRC are good for one year, and should be renewed annually as long as the product is imported and sold in Jordan. If any critical components in product are changed, the updated product must go through a resubmittal process, with the understanding that the changed product cannot be imported until a new approval has been issued. The TRC has an English-language website (www.trc.gov.jo/index.php?lang=english) where additional information is available about the TRC’s responsibilities and programs.

Israel

Israel has a robust and innovative economy. Despite being ranked 99th in the world in terms of population, Israel is ranked 56th in the world based on its GDP-PPP. The top exports are machinery equipment, software, cut diamonds, agricultural products, chemicals, textiles, and clothing, providing the company with a diversified economic base.

The Standards Institute of Israel (SII) is the government agency for EMC and Safety certification of electrical and electronic products, and also is responsible for evaluating the energy conservation performance of some types of ITE. SII requires product samples to be submitted for in-country testing to the applicable SII standards, and for the submission of required documentation including product construction files, user manuals, and a letter of authorization for the required local company representative.

Certificates granted by SII do not expire as long as the product is not modified. If any critical components in product are changed, the updated product must go through a resubmittal process, with the understanding that the changed product cannot be imported until a new approval has been granted. SII has an English-language website (www.sii.org.il/20-en/SII_EN.aspx) which provides more information on SII standards, testing, and product certification.

The Ministry of Communication (MOC) is Israel’s telecom authority, responsible for the protection and assignment of their frequency spectrum, especially military frequencies, and the protection of their telephone telecommunications network. MOC requires an authorized local representative in Israel, but does not typically require test samples. They accept EU R&TTE Directive “CE” reports and DoCs as evidence of compliance with its requirements.

One unique aspect of MOC regulations is that devices that both transmit and receive require two MOC certificates, one for the transmitter portion, and the other for the receiver section. Certificates issued by MOC have a five year validity period as long as the product is not modified. If critical components in a product are modified, the updated product must be resubmitted for approval to the MOC. MOC has an English-language website (www.moc.gov.il/130-en/MOC.aspx), which provide more information on their criteria and activities.

Egypt

Egypt has experienced internal unrest for the past several years, but has become more stable politically as a result of the 2014 elections and a passage of a new constitution. Crude oil and petroleum products are Egypt’s leading exports, and the country is ranked 24th in terms of GDP-PPP. Egypt has the 16th largest population, and its citizens actively seek access to the latest smart phones and wireless electronics.

Egypt’s National Telecommunication Regulatory Authority (NRTA) is that country’s wireless, telecom, and ITE certification agency, setting the compliance criteria for EMC, health & safety, wireless and telecom attributes. The NRTA accepts EU R&TTE Directive compliance reports as evidence of compliance with its requirements.

The NTRA does not require a local representative, and test samples are only required for telecom products. Certificates do not expire, but products must be resubmitted for evaluation and approval by the agency when any critical product components are changed or modified. The NRTA has an English-language website (www.tra.gov.eg/english), where additional information about their allocated frequency spectrum and type approvals is available.

Kuwait

Kuwait is small in land size and population but has a prosperous and relatively open economy, based almost entirely on its oil reserves. This country has a GDP-PPP ranking of 54th in the world, and has plans to diversify its economy by investing over $100 billion (USD) in infrastructure projects to attract foreign investment and increase the number of private businesses.

The Ministry of Communication (MOC) is the wireless and telecom agency for Kuwait, responsible for the management of their frequency spectrum and the protection of their telephone telecommunications network. The MOC does not require a local representative, nor do they require test samples. They accept EU R&TTE Directive “CE” reports and DoCs as evidence of a product’s compliance with its requirements.

Certificates issued by the MOC are valid for one year, as long as the product is unchanged. If critical components in a product are modified, the updated product must be resubmitted for approval to the MOC. The MOC website has an English version (http://moc.kw/English/index.html) activities where additional information about the agency’s activities is available.

The Public Authority for Industry (PAI) is the agency responsible for safety in Kuwait, under the authority of the Minister of Commerce & Industry. Only certain types of equipment are required to obtain approvals from this agency, which accepts EU Directive “CE” reports and DoCs as evidence of compliance. The PAI website (www.pai.gov.kw/en) has a limited amount of information available in English.

Saudi Arabia

Saudi Arabia has an economy based on oil. It holds more than 15 percent of global proven reserves, and is the largest exporter of petroleum in the world. Saudi Arabia has a GDP-PPP ranking of 15th in the world, making it the wealthiest country in this region. The country is also working to diversify its economy and increase businesses in the private sector, focusing on power generation, telecommunications, and natural gas exploration.

The Communications and Information Technology Commission (CITC) is the government authority for wireless, telecom, and EMC aspects of electronic products, including limits on human exposure to radio frequencies. CITC accepts both EU Directive “CE” compliance reports and FCC grant and reports as proof of compliance. CITC is responsible for the protection and assignment of the Saudi frequency spectrum, and also establish the criteria and processes for product compliance approvals. Test samples for in-country testing are normally not requested as part of the submittal package for approvals.

CITC does not require a local representative of the company in Saudi Arabia. Their issued certificates are valid for one year, and should be renewed annually as long as the product is imported and sold in Saudi Arabia. If any critical components in product are changed, the updated product must go through a resubmittal process, with the understanding that the changed product cannot be imported until the new approval has been issued. CITC has an English-language website (www.citc.gov.sa/English) with more information on their responsibilities and programs (specific regulatory documents can be obtained from the “CITC Statues” tab found on the website home page).

The Saudi Standards, Metrology and Quality Organization (SASO) is the national authority for product safety in Saudi Arabia, under the authority of the Minister of Commerce & Industry. CB reports or EU Directive test reports with CE DoC which are based on the SASO-mandated standard are accepted as evidence of compliance. Test samples are not typically required, but the agency reserves the right to request those in exceptional cases. SASO certificates are valid for one year, and should be renewed annually as long as the product is imported and sold in this country. The SASO website (www.saso.gov.sa/en) has information available in English, but some search results are available only in Arabic.

Bahrain

Bahrain’s economy is heavily dependent on declining oil reserves, so the country has sought to diversify through investments in petroleum processing and refining, international banking, and communication and transport facilities. A substantial victory in Bahrain’s diversification efforts was achieved in 2006, when the country successfully negotiated a Free Trade Agreement (FTA) with the United States, the first FTA between a Gulf state and the U.S. Bahrain’s GDP-PPP has reached 102nd in the world in the past two years.

The Telecommunications Regulatory Authority (TRA) is the wireless and telecom agency for Bahrain, responsible for the management of that country’s frequency spectrum and the protection of their telephone telecommunications network. The TRA requires an authorized local representative in-country, but doesn’t require test samples. It accepts EU R&TTE Directive “CE” reports and CE DoCs as evidence of compliance with its technical requirements.

Certificates issued by TRA are valid for three years and should be renewed as long as the product continues to be sold in Bahrain. If the approved product design is modified, or if critical components are changed, the updated product must be resubmitted for approval to the TRA. The TRA website has an English version (www.tra.org.bh), where additional information about TRA’s compliance requirements and activities is available (regulations and telecommunication laws can be accessed via the “Legal Instruments” tab on the website home page).

Qatar

Qatar is small in land area and population, but the country has the highest per capita income in the world, having avoided the domestic unrest and war experienced by many of their regional neighbors. Although it still has massive oil and gas reserves, it has been actively working for some time to diversify its economy by expanding into manufacturing, construction and financial services. At present, Qatar’s GDP-PPP has grown to 69th globally, with oil revenues accounting for less than half of the country’s nominal GDP. Another driver for economic growth is the upcoming 2022 World Cup to be held in Qatar, which is instigating a number of major infrastructure construction projects in the country.

The Ministry of Information and Communications Technology (ICT) is the wireless and telecom authority of Qatar. The ICT accepts EU R&TTE Directive compliance reports with CE DoCs as evidence of compliance. The ICT does not require a local representative, nor does it require test samples. Certificates do not expire but, if any critical components in the product are changed, the modified product must be submitted for evaluation and approval by the agency. The ICT has an English-language website (www.ictqatar.qa/en), where more information on their allocated frequency spectrum and type approvals is available.

United Arab Emirates

The United Arab Emirates (UAE) has a diversified economy, with oil and gas accounting for just 25 percent of their GDP, and a high per capita level of income. The UAE has free trade zones, which allow for foreign company ownership and no taxes and which have attracted many outside investors. This country has a GDP-PPP ranking of 33rd in the world, and is now actively working to create more opportunities for their citizens by improving their education and increasing private sector employment rates.

The Telecommunications Regulatory Authority (TRA) is the national telecom and wireless authority for the UAE, responsible for the management of that country’s frequency spectrum and the protection of their telephone telecommunications network infrastructure. TRA does require an authorized local representative in the UAE. Test samples are required for certain types of equipment, such as tablet computers and GSM devices. They accept EU Directive “CE” reports and CE DoCs as evidence of compliance.

Certificates issued by the TRA are valid for three years, as long as the product is not modified from the approved design, and should be renewed if the product will continue to be sold in the UAE for more than three years. If critical components in a product are changed, the updated product must be resubmitted for approval to the agency. The TRA website (http://tra.gov.ae/index.php) has an English-language version, which can be accessed by clicking on the “EN” tab in the upper left-hand corner of the website home page.

Yemen

Yemen has very low per capita income, and is still highly dependent on oil revenues despite declining oil reserves. The country is seeking to diversify its economy, but still has many obstacles to overcome, including diminishing water supplies, a high unemployment rate, serious food shortages, and a rapidly growing population. For many decades, Yemen has experienced internal and external conflicts. But, since 2011, the problem has escalated to the point where some government offices and function operate sporadically at best, hampering overall efforts to solidify government and strengthen the country’s economy. Yemen’s GDP-PPP is ranked at 82nd globally.

While there are not wide-ranging U.S. sanctions against the government of Yemen, there are targeted prohibitions in place for specified individuals who are deemed as threats to the peace, security, or stability of the country. [10] The listing of targeted individuals and organizations can be found on the OFAC Specially Designated Nationals List webpage, listed in the reference section. [5]

Certain dual-use technologies are restricted. Information on determining if a specific commodity will require an export license from the U.S. Department of Commerce can be found by determining the Export Control Classification Number (ECCN) for the product, and then accessing the Commerce Control List (CCL) found in the Bureau of Industry and Security section of the Department of Commerce website.[6]

The Ministry of Telecommunications and Information Technology (MTIT) is the telecom and wireless authority for Yemen. They accept the EU R&TTE Directive compliance reports and CE DoCs as evidence of compliance, but they can mandate additional reviews for applications that could interfere with critical radio spectrum, such as emergency or military channels, or products that might degrade the national telephone telecommunications systems. Test samples are not required, nor does the MTIT require a manufacturer’s or importer’s representative to be located in Yemen.

Certificates issued by MTIT are valid for one year, and must be renewed on an annual basis as long as the product is imported and/or sold in Yemen. If the product is modified from the original submitted design, the updated product must be resubmitted for approval, and cannot be shipped into the country until a new certificate has been issued. The MTIT has an English-language website (www.mtit.gov.ye), but the website was non-functioning as this article was being prepared.

Oman

Oman has an economy that relies heavily on its oil resources. However, as those resources are being depleted, the country is turning to enhanced oil recovery techniques to help maintain production. The government Oman is also concentrating on efforts to diversify the economy away from oil through industrialization and encouraging private ownership of small and medium-sized businesses. Tourism and natural gas industries are seen as two key areas of this diversification, along with privatizing non-essential government functions. Oman still has a healthy GDP-PPP ranking of 69th out of the 229 ranked countries.

Oman’s Telecommunications Regulatory Authority (TRA) is the country’s telecom agency for both hard-wired and wireless products. It accepts EU R&TTE Directive compliance reports as evidence of compliance, and product test samples are not required as part of the approval process. An authorized local representative is required to be in-country, who most hold a notarized letter of authorization from the manufacturer or importer of the product.

The TRA website (www.tra.gov.om) is in English and provides information on telecom regulations, type approvals, and frequency spectrum allocation. Certificates provide by the TRA have no expiration date, but the agency does require an update submittal if the product is substantially changed or modified from the approved version of the product.

Conclusion

Now we have completed our trip, which started from the north in Turkey, and ended up in Oman to the south. While there are many market opportunities to be found with large infrastructure projects and growing telecommunications networks, there are additional burdens in dealing with the importation and customs clearance of products, as well as a dynamic regulatory environment. Companies entering into this region should perform an objective risk versus reward analysis to evaluate whether entry into each country makes sense as a commercial profit-producing enterprise.

While this article provides a snapshot of the current regulatory compliance landscape in these countries, including the agencies and current requirements for product approvals, this information will almost certainly become outdated over time. It is important to stay connected with your network of compliance professionals and affinity organizations, so that your company remains positioned to take advantage of opportunities in these markets.

Engineering and regulatory compliance affinity groups are an invaluable resource for staying current on the latest changes to the regulatory compliance standards and processes. The local chapters of the Institute of Electrical and Electronics Engineers (IEEE), such as the IEEE EMC Society and the IEEE Product Safety Engineering Society, provide presentations and opportunities for networking with regulatory compliance engineers on the shifting certification requirements. In addition, social media site Linked In has a wealth of different regulatory compliance-related groups that can be joined at no cost, such as the “International Approvals/Certifications” group, where the latest news on country-specific regulatory criteria is shared among group members.

References

  1. U.S. Central Intelligence Agency, (2015) The World Factbook index webpage. [Online].
  2. U.S. Department of the Treasury, Office of Foreign Assets Control, (2015) Syria Sanctions webpage. [Online].
  3. U.S. Department of the Treasury Office of Foreign Assets Control, “Syria Sanctions Program”, August 2, 2013, pp.3-6.
  4. U.S. Department of the Treasury, Office of Foreign Assets Control, (2015) Iraq-related Sanctions webpage. [Online].
  5. U.S. Department of the Treasury, Office of Foreign Assets Control, (2015) Specially Designated Nationals List webpage. [Online].
  6. U.S. Department of Commerce, Bureau of Industry and Security, (2015) Commerce Control List webpage. [Online].
  7. U.S. Department of the Treasury, Office of Foreign Assets Control, (2015) Iran Sanctions webpage. [Online].
  8. U.S. Department of the Treasury Office of Foreign Assets Control, “IRAN – What You Need to Know About U.S. Economic Sanctions”, January 23, 2012, pp.1-3.
  9. U.S. Department of the Treasury, Office of Foreign Assets Control, (2015) Lebanon-related Sanctions webpage. [Online].
  10. U.S. Department of the Treasury, Office of Foreign Assets Control, (2015) Yemen-related Sanctions webpage. [Online].

Mark Maynard is a Director at SIEMIC, a global compliance testing and certification services firm. He also serves as the President-Elect for the IEEE Product Safety Engineering Society Board of Directors. He can be reached at mark.maynard@siemic.com.

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