DID assignment VoIP regulations

[Annie S.]

I am having difficulty finding documentation on the legality of assigning DID's from another country to agents/employees in a different country. Can any of you point me in the direction of documentation? I have looked at VoIP regulations for the countries I'm interested in but they seem geared more towards VoIP providers and selling a number out of country. 

Specifically I want to know if it is legal or not legal to assign a US or UK based +e164 number to an agent/employee physically located in Germany. 

Thanks!

[R0g22]

Assigning an extension to an agent/employee remains local to you and to the VoIP solution that you have. Now, the issue would be if you are trying to do something like TEHO. If you are not sure, look up and read about TEHO and whether Germany has any regulations or not. Most countries restrict PSTN/ITSP based calls over internet to save ISP's from taking a loss.

[Annie S.]

Thanks for your reply. I'm looking for information on the legality of assigning a DID (not extension) to someone physically in Germany where the DID assigned is a +44 (UK) or +1 (US) number, not TEHO. 

[R0g22]

What do you mean when you say "Assigning a DID physically" ? DID's are assigned to circuits by service providers. Do you have service providers in Germany that assign UK based DID's to your circuits ? That's highly unlikely.

[Annie S.]

So I run a global Cisco telephony solution. I have DID's all around the globe. I have local SIP trunks in multiple locations around the globe. Blocks of numbers, etc. 

I want to know if it is legal or illegal to assign a US or UK number (that we own) to an employee physically located in Germany. So they will be making inbound/outbound calls from their location in Germany through a UK or US SIP trunk with a UK or US CID. 

[R0g22]

That's is what I am trying to understand. You own a DID that is fine. How is a ISP in Germany allocating a UK DID on a German telephony system ? You need to first understand this before looking into the legal aspect of things.
People in Germany can call out locally to UK or US via a UK or US DID using a UK or US based trunks. That is TEHO.
Germany users calling to UK or US numbers through local circuits is International dialing.

[Annie S.]

I don't think you're understanding what I am saying.. 

I run a CUCM environment, I have SIP trunks in multiple locations - for this example let's say I have a US SIP trunk. Let's also say I have 50 DID's in US.

Is it legal to assign a number to a user in Germany via Jabber with a +1 number when they are physically located in Germany. There is NO ISP involved in this question. 

Call flow - Germany User w/Jabber physically located in Germany -> Jabber registration back to US. SIP trunk in US. +1206....... number assigned to the user. 

Inbound calls will come in via +1206.. on the US SIP trunk, and ring the agents Jabber setup physically located in Germany. 

Is this legal and if not can someone point me in the direction of documentation to support it?

[R0g22]

Ok, let's take it a step back. Seems like you are more concerned with being legal or not rather than understanding how it actually works ? Can you answer the following for me please ?

1. Where is your DC that hosts your CUCM ? Is it local to Germany or US etc ?
2. Are you agents/phones/Jabber local to where the CUCM is ?
3. If not, how are they connected ? Remotely over WAN ?

[Annie S.]

Yes, I am only concerned about the legality and since I am unable to find any documentation online, I wanted to check with the larger community to see if someone could point me in the correct direction. 

DC - US

Agent location - in this example the employee is in Germany. 

Expressway or VPN

[R0g22]

Ok. So, what do the Telecom regulations in Germany say about softphones/remote clients registering over MRA/VPN and making calls Internationally bypassing the PSTN in Germany ? This is Toll Bypass and you are effectively doing TEHO here.
I am not aware about German regulations but the countries restricting Teho define the restriction as - If the PSTN is in the US and a VoIP endpoint is in Germany and if connection results in revenue loss to source telecom service providers, the connection gets considered restricted.

Whether it is legal or not, Cisco does not tell that. TEHO is just a solution. Being legal or not is something that will be defined by your country's Telecom laws. Read here on more about TEHO -
https://www.cisco.com/c/dam/en_us/about/ciscoitatwork/downloads/ciscoitatwork/pdf/Cisco_IT_Case_Study_TEHO.pdf

What you effectively need to do is this -

Jabber in Germany >> MRA/VPN >> CUCM >> Local Germany GW >> Germany PSTN >> US PSTN

The above is LEGAL.

[Annie S.]

"So, what do the Telecom regulations in Germany say about softphones/remote clients registering over MRA/VPN and making calls Internationally bypassing the PSTN in Germany?"

Again, this is my question. I am unable to find documentation and was hoping someone on this forum has knowledge of the issue and can point me towards documentation that they have previously found.

[R0g22]

I would let someone else chime in here if it's about the documentation. I don't have any German related documentation in hand. Maybe try emailing your Telcom guys ? A quick google search should be able to help you get to your telecom govt website which should have something to contact them.

[Annie S.]

I am the "Telecom guy" and I am not looking for if it's legal in the US (where I am) I'm looking for information regarding Germany, which is convoluted at best and is usually in German and Google Translate is not good for the nuances of SIP/VoIP. Additionally I don't speak German and have emailed the gov agency with no success. 

[R0g22]

That's a bummer. You will then have to wait around and luckily if there is someone on CSC who has done deployments in Germany specifically. And I understand. You only need to worry about regulations in Germany since that is the source.
Let me tag a couple of guys who might be able to help.

@Ayodeji Okanlawon

@Jaime Valencia

[Ayodeji Okanlawon]

Hi Annie and thanks to @R0g22 for the help he has provided so far.

I dont have any documentation but what I know is that we do this currently and we are a large company, so I am sure we wont be doing this if it was illegal.

We have employees in Germany and we sometimes assign other countries DDI to them. We use this especially for our sales team who need to provide a local presence number for the country they are dialling. For example, someone based in Germany will present a CLI of +33XXXX when dialing France and +1XXXXX when dialing US and +46 when dialing sweden.

Hope this helps