Question: Network Switches with dormant Encryption only activated by a license key Purchased separately. In this case the switch is kicked out of 5A002 due to the cryptographic activation requirement. Is the switch now classified as 5A991 and does does the higher control now move to the license itself? Answer 1: You are on the […]
Question: Hello – Can anybody confirm if the following criteria would automatically qualify items under 5A002/5D002: Interfacing to a cryptographic library – (i) direct call or (ii) call to a service like TLS or a (iii) general-purpose system? Thanks. Answer 1: No, not automatically, but this is definitely a reason to evaluate an item for […]
Question: We have equipment that qualifies for License Exception ENC under 740.17(b)(2) and a scenario where we have a sales rep in a non-Supplement 3 country that is a privately owned. We would like to send them some equipment for demonstration purposes which would ultimately be returned to the U.S. Normally we would utilize ENC […]
Question: Companies operate worldwide and use different types of software to connect and communicate with their staff including Russia or China. It appears some of the systems may have codes related to 5D002.c.1 and 5D992.c. Is that something for them to be concerned about? They are not selling, shipping, or transferring any product only using […]
Question: Encryption rookie question: The actual ECCN for an item does not change – I get that – so let’s say it’s 5A002.a.1. My question is about the other element (whatever it’s called) where it is either a1, a2, b1, b2, b3, b4 under EAR 740.17. It that also “permanent” once assigned, or can […]
Question: Hoping for guidance from the membership. Here is the basic scenario: A “family” of “restricted” encryption items /740.17(b)(2) products is authorized on the Encryption Licensing Arrangement – various models in the family The 400 model, is exported under the Encryption Licensing Arrangement The product fails and customer wants a replacement. Two scenarios: o The […]
Question: I would appreciate feedback from the membership about how do you conduct your classification analysis for products that contain encryption. how do you communicate with your Engineering team, Program Management, etc the encryption regulations so that they help you conduct the proper classification evaluation. I’m currently using a home-made “Encryption Review Questionnaire” a question/answer […]
Question: Our I.T. team is contemplating adding encryption to all laptops andI’m concerned for those who travel frequently outside the U.S. Would any members have a listing of countries where traveling with a laptop protected by encryption (encrypting sensitive business data and programs such as e-mail) is restricted or not allowed ? Thanks.
Question: A question related to the semi-annual encryption report as described inEAR 740.17(e). This section states “Semi-annual reporting is requiredfor exports to all destinations other than Canada, and for reexports fromCanada…” We have an encryption software product (5D002 but approved to uselicense exception ENC) that needs to be included on the report. In a fewinstances, […]
Question: Has anyone had any experience with or have knowledge about the new Chinaimport reg. for encryption items? I read about it in Baker McKenzieJan. 2010 newsletter and could find very little else about it. It lists 9categories of items, but also says if you have knowledge that there isencryption in your product you need […]
S.KOREAN ENCRYPTION EXPORT CONTROLS: Does anyone know if there are export controls on encryption in South Korea (e.g. requiring an export license to ship from South Korea)? If yes, do you have any idea where there may be an English version of the export regulations?
The Encryption Regulations on the BIS Website are confusing. Is anyone willing to share a write-up or presentation that summarizes, in some detail, the requirement of the encryption regulations?
