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Current crypto policy

  • Any crypto of any key length can be exported under a license exception, after a technical review, to non-government end users in any country except the seven "terrorist countries". Exports to governments can be approved under a license.
  • Retail crypto (i.e., crypto which does not require substantial support and is sold in tangible form through retail outlets, or which has been specifically designed for individual consumer use) of any key length can, after a technical review, be exported to any recipient in non-terrorist countries.
  • Unrestricted crypto source code (like most "open source" software) and publicly available commercial source code (like "community source" code) can be exported to any end-user under a license exception without a technical review. BXA must be given a copy or the URL of the source code. All other source code can be exported under license exception after a technial review to any non-government end-user. One may not, however, knowlingly export source code to a terrorist country, although source code may be posted on the WWW for downloading without the poster having to check whether it is downloaded from a terrorist country.
  • Any crypto can be (re)exported to foreign subsidiaries of US firms without a technical review. Foreign nationals working in the US no longer require an export license to work for US firms on encryption.
  • The regulations implement the December 1998 Wassenaar changes (notably, export of 56-bits and 64-bits (for mass-market products) crypto to non-terrorist countries).
  • Post-export reporting is required for exporting certain products above 64 bits to non-US entities.
  • Since 19 October 2000, a further liberalization of export controls is effective, triggered by changes in the EU export regulations (see the Federal Register Vol. 65, No. 203, pp. 62600-10, available at BXA). The liberalization was announced by the Clinton administration on 17 July 2000. A license exception is introduced for export of any crypto product to any end user (so, the distinction between government and non-government end users is dropped) in the 15 EU countries, Australia, Czech Republic, Hungary, Japan, New Zealand, Norway, Poland, and Switzerland. Also, US exporters can ship products immediately after filing a commodity classification request, without waiting for the technical-review results or the previously used 30-day delay period.

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UNC SILS
Prof. Greg Newby