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Letter to IOM on article 40 of IHR

We write to you on behalf of the Public Health Protection Network of Kurdistan region of Iraq. Let us first thank you for the extraordinary work that you have done during the difficult time of the COVID-19 pandemic.

The people of Kurdistan and Iraq are very fortunate to have you as partners to help with open arms during these very challenging times. The services you provided as part of your four strategic priority areas in responding to COVID-19 are crucial in saving lives and livelihood. Such services are particularly important given the inability of the health system to respond to such a great shock as a pandemic.

We also wanted to highlight two observations or your kind attention that we summarise below:


  1. The authorities in Kurdistan Regional Government (KRG) have been charging travellers for COVID-19 testing at entry points at borders. We believe that practice is a grave violation of people's right to mobility. Furthermore, it is a violation of article 40 of the International Health Regulation (IHR) 2005. In addition, we are concerned that the resources that are made available through those charges are not collected in a transparent manner and there are allegations of corruption in relation to those charges.

  2. We are surprised that the excellent services that you have provided so far were restricted to the governorates of Erbil and Duhok in the KRG. As you are aware, the majority of cases at the level of not only the kRG but also Iraq were recorded in Sulaymaniyah governorate. We are puzzled by the fact that Sulaymaniyah is almost absent from your reports. Such absence is particularly concerning given the relatively large movement of people across the borders with Iran.

We would be grateful for your attention to these two points. We are also looking forward to collaborating with you further over the next coming months.

Yours sincerely Public Health Protection Network --

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