Telecommunications Infrastructure and Corporate Risk can take very different forms — including sanctions, surveillance, corruption, government demands for data or network access, allegations arising from armed conflict, and human-rights litigation. 

Companies operating in politically unstable, conflict-affected or highly regulated environments can face significant legal, regulatory, reputational and financial risks arising from the environment in which they operate. 

EMFSA | 23 September 2026

This article aims to distinguish between allegations, investigations, regulatory findings, court judgments, settlements and admissions. Where we discuss allegations, we attribute them to the relevant source and identify the legal or investigative status of each case where known.

We examine:

• Operations in armed-conflict zones
• Allegations of complicity in human-rights abuses
• Civil litigation and criminal investigations
• Government demands for customer data or network access
• Surveillance and law-enforcement capabilities
• Sanctions and export-control violations
• Corruption and politically connected business relationships

➼Telenor — Myanmar

2021–2026 | Customer data, human-rights allegations and investigation

Norwegian police opened an investigation into Telenor concerning allegations relating to customer data and possible complicity in crimes against humanity. 

According to Reuters, Norwegian police are investigating Telenor on suspicion that the telecommunications operator aided and abetted crimes against humanity in Myanmar following the 2021 military coup. Telenor sold its Myanmar business following the coup and completed its exit from the country in March 2022. The company said it was cooperating closely with investigators and would do everything in its power to assist in clarifying the case. Reuters, 15 September 2026.

The Open Society Justice Initiative has a detailed account of the underlying civil litigation. It reports that plaintiffs filed a class action in Norway in April 2026 concerning the disclosure of customer data, and that the Asker and Bærum District Court subsequently allowed the case to proceed as an opt-out class action. Open Society Justice Initiative — Telenor case

➼MTN — Afghanistan and Iran

2006–2026 | Anti-Terrorism Act litigation, Iran-related legal issues and U.S. Department of Justice investigation

MTN’s operations in Afghanistan and its minority investment in Iran have been the subject of several separate U.S. legal proceedings and, since 2025, a U.S. Department of Justice investigation. These matters involve different allegations, defendants and legal issues. The existence of a complaint, court proceeding or government investigation does not by itself establish that MTN committed the alleged conduct.

Afghanistan and the U.S. Anti-Terrorism Act

MTN began operating in Afghanistan in 2006. On 27 December 2019, plaintiffs filed a complaint in the U.S. District Court for the District of Columbia under the U.S. Anti-Terrorism Act (ATA). The plaintiffs brought claims on behalf of American service members and civilians, and their families, who were killed or injured in Afghanistan. MTN Group and MTN Afghanistan were among the defendants.

The plaintiffs alleged, among other things, that companies operating in Afghanistan had made protection payments to the Taliban and thereby provided support connected with terrorist attacks. MTN disputed the allegations and sought dismissal, including on jurisdictional and ATA grounds. MTN said it intended to defend its position. Reuters, December 2019; MTN

One of the resulting proceedings is Cabrera v. Black & Veatch Special Projects Corporation, Civil Action No. 1:19-cv-03833 (D.D.C.). In 2021, a magistrate judge recommended dismissal of the claims against the MTN defendants. In March 2024, the district court allowed the plaintiffs to file a Second Amended Complaint, including a new theory concerning MTN’s investment in Iran. The court also vacated the earlier recommendation and stayed the case pending related proceedings concerning the interpretation of the U.S. Anti-Terrorism Act. Cabrera v. Black & Veatch Special Projects Corp. CaseMine (March 28, 2024).

The Cabrera docket records the case as “Unstayed” on 17 September 2026, indicating that the earlier stay had been lifted.

MTN’s 2025 Annual Financial Statements continued to list the Cabrera litigation among its legal matters.

Irancell and Iran

Since 2006, MTN Group has held a 49% minority, non-controlling interest in Irancell. MTN states that Irancell is not under MTN Group’s operational control. It has also stated that, following the re-imposition of U.S. sanctions in 2018, it has not deployed capital into the Iran business or extracted capital or dividends from it. MTN Group FY2025 Annual Financial Statements

MTN’s investment in Irancell has also been relevant to separate U.S. legal proceedings. 

In 2021, Zobay v. MTN Group was filed in the U.S. District Court for the Eastern District of New York. The plaintiffs alleged that MTN’s business relationships with Iranian entities, including its investment in Irancell, contributed to support for the Islamic Revolutionary Guard Corps and, indirectly, to attacks against Americans in Iraq and Afghanistan. MTN has contested those allegations.

On 28 September 2023, the court denied MTN Group Limited’s motion to dismiss the ATA claims, while granting MTN Dubai Limited’s motion to dismiss. MTN subsequently sought permission to appeal. MTN stated that the ruling did not mean that it had lost the case or that the court had found that it had violated the law. Zobay court decision

Two related ATA cases, Chand v. MTN and Davis v. MTN Irancell, were filed in the U.S. District Court for the District of Columbia in March 2022. MTN’s published disclosures describe these cases as involving allegations concerning MTN’s investment in Irancell and alleged connections to attacks in Iraq and Afghanistan. MTN Group FY2025 Annual Financial Statements

U.S. Department of Justice investigation — 2025

In August 2025, MTN disclosed that it had been approached through its external U.S. counsel regarding a U.S. Department of Justice grand-jury investigation concerning MTN Group, its former subsidiary in Afghanistan and Irancell.

MTN said that it was cooperating with the Department of Justice and voluntarily responding to requests for information. The company also stated that it had not been charged with any violation of law. MTN exited its Afghanistan business in early 2024.

MTN’s disclosure makes it clear that the investigation is separate from the civil Anti-Terrorism Act proceedings. MTN has not stated that it has been charged with an offence.

U.S.-Origin Technology and Iran

A separate issue concerns the movement of U.S.-origin technology into Iran. In June 2012, Reuters reported that MTN Irancell had obtained U.S.-origin equipment, including products from Sun Microsystems, Hewlett-Packard and Cisco, through a network of technology companies in Iran and the Middle East.

In a follow-up investigation published in August 2012, Reuters reported that internal MTN documents appeared to show that MTN employees had discussed ways of obtaining U.S. technology for MTN Irancell despite U.S. sanctions. Reuters reported that the equipment included products from several U.S. technology companies and that MTN denied wrongdoing.

These were matters reported by Reuters, rather than a U.S. government enforcement finding that MTN had violated sanctions. The distinction is important: the Reuters reporting described evidence and allegations concerning the procurement of U.S.-origin technology, while MTN denied wrongdoing. The reporting should therefore not be presented as a finding by U.S. authorities that MTN violated sanctions.

Reuters, June 2012 — How an Iranian telecom got banned U.S. tech
Reuters, August 2012 — How a telecom giant got round sanctions on Iran

➼Telia — Uzbekistan

2007–2017 | Corruption, telecommunications licences and international enforcement

Telia Company AB’s operations in Uzbekistan became the subject of a major international foreign-bribery investigation. According to U.S. and Dutch enforcement authorities, Telia and its Uzbek subsidiary, Coscom LLC, paid more than $331 million in bribes between approximately 2007 and 2010 to an Uzbek government official who had influence over the country’s telecommunications regulator. Telia and Coscom made the payments to enter and expand Telia’s telecommunications business in Uzbekistan.

The U.S. Department of Justice stated that Telia and Coscom structured and concealed the payments through various transactions, including payments to a shell company beneficially owned by the Uzbek official. The payments enabled Telia and Coscom to obtain telecommunications business and valuable telecom assets and to continue operating in the Uzbek market.

The matter resulted in coordinated enforcement proceedings in the United States and the Netherlands. On 21 September 2017, Coscom pleaded guilty in the United States to conspiracy to violate the anti-bribery provisions of the Foreign Corrupt Practices Act (FCPA), while Telia entered into a deferred prosecution agreement and admitted participating in the charged conspiracy. Telia also reached related resolutions with the U.S. Securities and Exchange Commission and the Dutch Public Prosecution Service.

The combined U.S. and Dutch criminal and regulatory resolution totalled $965,773,949 and included criminal penalties, forfeiture, disgorgement and prejudgment interest. Telia also agreed to strengthen its internal controls and cooperate with the authorities’ continuing investigations. Telia Company AB and Its Uzbek Subsidiary Enter Into a Global Foreign Bribery Resolution of More Than $965 Million for Corrupt Payments in Uzbekistan

Corporate Compliance and Regulatory Risk

The case illustrates a different form of telecommunications-sector corporate exposure from the sanctions, surveillance and human-rights matters discussed elsewhere in this article. Here, the principal risks involved corruption, regulatory influence, telecommunications licences, third-party payments, internal controls, corporate governance and exposure to foreign anti-bribery laws.

The Telia case also demonstrates how telecommunications licences and access to regulated markets can create significant compliance risks where government officials or politically connected intermediaries have influence over market entry or regulatory decisions.

African Union — Digital Infrastructure and Surveillance Risk

2020 | Security cameras, digital infrastructure and suspected cyber-espionage

A further example shows how corporate and infrastructure-related risk can extend beyond conventional telecommunications networks.

In December 2020, Reuters reported suspicious activity at the African Union (AU) headquarters in Addis Ababa. Technology staff found suspected Chinese hackers siphoning footage from the organisation’s security-camera servers. An internal AU memorandum reviewed by Reuters said the cameras covered offices, parking areas, corridors and meeting rooms. Information from Japanese cyber researchers reportedly prompted the investigation.

Reuters also reported that Chinese workers had built the AU’s conference centre and that Chinese technicians continued to assist with the organisation’s digital infrastructure. The Chinese mission to the AU denied that the organisation had reported being hacked and rejected the allegations.

The incident illustrates a broader corporate and infrastructure-security issue. Organisations that rely on externally supplied or maintained digital infrastructure may also need to consider data access, cybersecurity, surveillance capabilities, supply-chain security and control over networked systems.

The report does not establish that the infrastructure supplier was responsible for the alleged cyber intrusion. Rather, it illustrates why organisations may need to consider cybersecurity and control of digital infrastructure when assessing telecommunications and technology projects.

Source: Reuters, “Exclusive-Suspected Chinese hackers stole camera footage from African Union – memo,” 16 December 2020. The Reuters report is reproduced on EMFSA with attribution to Reuters: EMFSA — African Union camera-footage report

Corporate risk is not necessarily the same thing as corporate wrongdoing.

Vodafone provides a different perspective. Its corporate reporting identifies network shutdowns and law-enforcement assistance as human-rights issues and describes procedures for responding to government demands for communications data and network restrictions. Its reporting also illustrates how telecommunications companies may disclose activities involving countries subject to sanctions, even where the company does not operate directly in those countries.

 Vodafone, Annual Report/Form 20-F 

Company Disclosures 

Telecommunications companies operate within increasingly complex financial, sustainability and regulatory reporting frameworks. Depending on the applicable rules and the materiality of an event, companies may need to disclose significant legal, regulatory, operational or financial risks in their corporate reporting. Issues such as surveillance, human-rights litigation, network shutdowns, sanctions and other regulatory matters can therefore have consequences beyond the immediate legal issue. They may also affect a company’s operations, finances, reputation and reporting obligations.

IFRS Foundation resources

AI Disclosure

AI tools helped prepare this article through language editing, formatting, editorial assistance and research-support tasks. The author reviewed the sources and factual claims, reviewed and approved the final article, and remains responsible for its accuracy, interpretation and presentation.

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The Cheltenham Cell Mast Case – Steven Thomas challenged the installation of a 15-meter telecommunications mast in Cheltenham’s Central Conservation Area. The case: [2025] EWCA Civ 259.

Mr. Thomas opposed the mast due to concerns about EMFs, particularly their effects on individuals with medical implants like pacemakers. The legal challenge was prompted by the decision of the Cheltenham Borough Council that the development did not need prior approval.

High Court Judgment (2024)

The High Court ruled in [2024] EWHC 1035 (Admin) that the council made an error by failing to consider the potential impact of EMF on individuals with medical implants. However, it denied relief, ruling that the final decision would have remained unchanged even if the issue had been addressed.

Court of Appeal Decision (2025)

Thomas appealed the ruling, but in [2025] EWCA Civ 259, the Court of Appeal upheld the decision. While the council had made a procedural error, it did not affect the approval of the mast. The appeal was dismissed, and the decision of the council stood.

Full case details

Case background

Winning the Battle but Losing the War

•The battle was won: The Cheltenham Cell Mast Case proved that Cheltenham Borough Council made a procedural error by failing to consider the impact of EMFs on individuals with medical implants.

•The war was lost: Despite this, the court did not overturn the decision by the council or stop the approval of the mast.

Public Health Concerns

This case underscores the need for local authorities to consider public health concerns, particularly for potentially vulnerable individuals, in telecom planning. However, it also shows that if the overall outcome is deemed justified, procedural errors may not change the final decision.

ICNIRP and RF- EMF Exposure Risks for Implants

RF- EMFs can interfere with active implants. This is acknowledged by the International Commission on Non-Ionizing Radiation Protection (ICNIRP). ICNIRP considers such exposures outside the scope of its guidelines. Medical professionals and manufacturers are mostly responsible for the management. (Ref: Guidelines for Limiting Exposure to Electromagnetic Fields (100 kHz to 300 GHz))

Everyday Devices

Smartphones, wearables, and audio devices emit electromagnetic fields. These fields can affect medical implants. For example, Apple advises users with pacemakers or defibrillators to maintain a safe distance from their devices. (Apple Support).

Key Takeaways:

• Councils should consider EMFs and medical implants—this case confirms that failing to do so can lead to legal challenges.
• However, overlooking these concerns may not always overturn a decision. The court ruled that officials would have approved the mast regardless.
• Future legal challenges may have a stronger case if it can be shown that the outcome could have been different had EMF risks regarding implants been considered.
• This case could set a legal precedent, encouraging councils to take specific EMF-related health concerns more seriously in planning decisions.

Disclaimer: This article is for informational purposes only and does not constitute legal advice. Readers should consult a qualified legal professional for specific legal concerns.

Related https://www.emfsa.co.za/research-and-studies/titanium-exposure-and-human-health/

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Public safety is paramount.

Link to the newsletter:

https://mailchi.mp/emfsa/public-safety-modulation-legal-alan

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The judge has ruled in favor of the government.

Date of judgment 8 March 2023.

We note (as per the judgment):

•”A judicial review is not an appropriate vehicle for determining contested scientific material”

•”Not a case in which the High Court should intervene in respect of a decision that involves issues of technical scientific judgment.”

•”The government has adopted a precautionary approach in its messaging. Although it believes 5G is safe, out of an abundance of caution and on conservative principles it has suggested that those who are worried could, for example unplug the router at night, or not sleep with their mobile phone by their bed and to use their device further away from their body.”

•“Finally, I observe that the individual complaints of adverse health effects may give rise to private law claims for personal injury if those concerned are able to obtain the necessary medical and scientific evidence on causation, and identify appropriate defendants. This may be a more appropriate route than a judicial review and human rights claim, but, of course, that is a matter on which the claimants should seek their own legal advice.” (Lang J)”

Judgment:

https://www.bailii.org/ew/cases/EWHC/Admin/2023/495.pdf

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THE UPPER TRIBUNAL
(ADMINISTRATIVE APPEALS CHAMBER)
UPPER TRIBUNAL CASE NO: UA-2022-000328-HS
[2022] UKUT 193 (AAC)
EAM V EAST SUSSEX COUNTY COUNCIL
Decided following an oral hearing on 11 July 2022

The decision is: the local authority must secure that an EHC plan is prepared and
maintained for the child.

Excerpt:

H. The child is disabled

I. The provision of a wired internet connection is educational provision

27. The child’s problem with electro-magnetic radiation affects her life generally and
    limits her normal day-to-day activities – the Equality Act test. It applies at school, at
    home, and when she is out in the world. When at school, her problems with
    communication and making use of the computers are a direct result of the use of wifi
    in schools. The only solution available has to be provided in the school. It is not
    transferable to any other location, although it may need to be replicated elsewhere. I
    cannot see what other provision would be effective to avoid the problem or overcome
    its consequences.
28. This is not simply a case of a child being unwell and finding it difficult to
    concentrate. There was evidence from two educational psychologists both of whom
    found her and her parents credible in describing her symptoms. The tribunal
    (paragraph 47) accepted their evidence too and described her symptoms as
    ‘debilitating when they occur’, which they did to such an extent that she ‘was out of
    education for a whole academic year.’ Those symptoms were not unique to a school
    environment. But when they occurred in that environment they arose from the school’s
    choice of the medium for providing education. In those circumstances, some provision
    is required to render the education effective.

Authorised for issue on 18 July 2022

Edward Jacobs, Upper Tribunal Judge

More on the topic:

Upper Tribunal requires council to secure EHCP for student who is hypersensitive to Wi-Fi signals

https://www.localgovernmentlawyer.co.uk/education-law/394-education-news/51400-upper-tribunal-requires-council-to-secure-ehcp-for-student-who-is-hypersensitive-to-wi-fi-signals

Related:

The post UK Upper Tribunal: Education, Health and Care Plan for an Electrohypersensitive Child appeared first on EMFSA.

The WHO (2006) explains how the use of the words guidelines and standards has substantially different implications for public health and EMF radiation protection enforcement:

1. Guidelines are voluntary instruments of instructions and recommendations that are not legally mandated and therefore have no legal standing.

2. Standards are the mandatory, compulsory and legally binding instruments, i.e., laws, acts, regulations, ordinances and decrees.

They require procedures and systems to exist in order to ensure compliance with mandatory standards, i.e., an agency is mandated to check compliance through calculations and measurements in the workplace, residence and other vulnerable areas.

In summary, a standard has mandatory and legally binding instruments, monitoring and enforcement systems.

Identified were municipalities advertising having a “standard” in the form of a Telecommunications bylaw however, the municipalities purposefully do not meet the criteria to qualify as a standard but instead as a guideline.

We shall use the simple example of traffic law and bylaws. Every vehicle within the municipality must be registered and be licensed. The operating of said vehicles requires the operator to have a license that must be renewed and updated regularly. Different zones have different operating requirements such as speed, emissions, weight class, noise etc.…. There is a monitoring system through cameras, traffic inspector officials, and the public.

Finally, there is enforcement in place through fines, inspections, confiscation and court appearances. 

Furthermore, outside parties can obtain access to verifying the operations of the standard and contribute to efficacy, enhancement and progressive development.

The WHO states there is to be no internationally mandated EMF radiation standard but recommends that countries adopt their health-based EMF radiation standard from the large selection of international guidelines published, based on their tolerance of risk value toward accrued benefits to health. It could be argued that EMF radiation protection and interpretation would fall into existing legislation in South Africa with there being no national EMF radiation exposure safety standard in the country. The argument is based on the false sense of safety associated with the lack of a standard and consequently lack of surveillance of EMF exposure to the public.

Because it cannot be denied that there is the potential of harm from exposure to EMF radiation, legally binding exposure standards have been established in many countries worldwide.

Source: https://bit.ly/3HkQ4vh

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Press Release:

https://phiremedical.org/wp-content/uploads/2022/06/Press-Release-EHS-Social-Worker-granted-long-term-ill-health-pension-UK-Named.pdf

The post 59 year old social worker wins ‘early ill health retirement’ for disabling ‘Electromagnetic Hypersensitivity (EHS) appeared first on EMFSA.

The link to the webinar is available to members at https://www.buymeacoffee.com/EMFSA/webinar-eht-vs-fcc-context-applicable-sa

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Excerpt from the ruling:

We grant the petitions in part and remand to the Commission. The Commission failed to provide a reasoned explanation for its determination that its guidelines adequately protect against the harmful effects of exposure to radiofrequency radiation unrelated to cancer.

It must, in particular, (i) provide a reasoned explanation for its decision to retain its testing procedures for determining whether cell phones and other portable electronic devices comply with its guidelines, (ii) address the impacts of RF radiation on children, the health of long-term exposure to RF radiation, the ubiquity of wireless devices, and other technological developments that have occurred since the Commission last updated its guidelines, and (iii) address the impacts of RF radiation on the environment.

To be clear, we take no position in the scientific debate regarding the health and environmental effects of RF radiation—we merely conclude that the Commission’s cursory analysis of material record evidence was insufficient as a matter of law.

Background https://ehtrust.org/in-historic-decision-federal-court-finds-fcc-failed-to-explain-why-it-ignored-scientific-evidence-showing-harm-from-wireless-radiation/

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The publication is available from https://shop.icrc.org/icrc-position-on-autonomous-weapon-systems-pdf-en

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