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Yes, irrespective of country where its manufactured, if there are compliance requirements around an un-openable box, then some process becomes required.

But I think the GP's question is: "Whether it would be cheaper" - in the sense whether such an expensive QA process could have been averted by having a more trustworthy partner. One whom you're not on a race hack after hack.



The point is that if the devices are sensitive with compliance requirements then you must be able to verify them irrespective of who you hired to manufacture them.

You cannot just trust the word of a contractor on this because it's your ass on the line.


The point is that the process was to assure the device wasn't tampered AFTER shipped from manufacturer. Nobody thought it could already have been modified so early in the process. This is the eternal cat and mouse game. When I started in IT in 90s it was assumed that company network was quite safe and you didn't always need passwords, maybe for critical resources only.


I would think that, logically, and as illustrated, "the device wasn't tampered AFTER shipped from manufacturer" means after YOU have shipped it to customers. The anti-tampering system is to prevent modifications in the field.


The manufacturer shipped the device to us from China. We were already customer. The device would already have been locked. We would customize it some more (injecting cryptographic keys, application, placing our labels on the device) and then send them to merchants. The merchants were never customers, they would get it on loan from us. This was the only way to do it as the device could not be re-used with other acquirer so it only functioned as long as the merchant had valid merchant account with us.




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