Great article highlighting an important issue. My only quibble with the article is that I think it is important to separate the issues related to device manufacture and approval which has everything to do with the IMEI number and the issues around identity and surveillance which has more to do with the IMSI number and SIM as you correctly point out.

As such blocking IMEI numbers has little if anything to do with security as terrorists or criminals have no particular bias to using fake phones. I would also be wary of the argument that if you are not a terrorist, you have nothing to fear from surveillance. It assumes that governments will always use surveillance in the public interest and/or that it will never be abused by elements within government outside of prescribed uses of that information.

Blocking devices based on IMEI numbers is a legitimate response by government and the regulator to ensure that devices conform to national safety standards. However it is also worth asking the question of why there are so many counterfeit phones in Kenya. Do high import tariffs on mobile phones contribute to the counterfeit phone market?

Finally, on a related note, I think the mandatory registration of SIM cards is a practice has not been debated at all from a privacy perspective. The rationale that mandatory SIM card registration assists in crime investigation and leads to a drop in crime has not been backed up by any evidence that I am aware of. This needs to be balanced against the potential for using this information to compromise individual right to privacy. More about this at http://manypossibilities.net/2012/09/35-reasons-to-worry-about-privacy-in-africa/

Government and regulator decisions like IMEI blocking and mandatory SIM registration are issues that deserve public scrutiny and debate. Hats off to you for addressing this important issue.

-Steve