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The important lesson from the Jonathan Erickson (Dr. Dobbs) piece is that a simple application filing averted the panic that ensued when he received a "charging letter" from U.S. export enforcement officials. 88% of all export applications qualify for exceptions given to ?mass market? or ?unrestricted? (retail) products. The government has evolved a lot in the last decades. Prior to 1996, encryption was controlled as a weapon under ITAR. Today it is handled by the US Dept. of Commerce who work hard to balance the dual-use (security and industrial) nature of encryption technology. The law is far from perfect, but having recently attended the BIS Update Conference in Washington, DC, I came away with a renewed appreciation for the difficulty of this mission. The US government has even made it easy for open source projects to comply (under license exception TSU). I agree that there's no need to panic, but companies and developers should always ?know their code? - which in this case means being aware of any encryption (including open source) that is being incorporated into an application, device or system (whether in use or dormant).
Eran Strod
Black Duck Software - Posted by: ECS-BD Posted on: 10/27/09 You are currently: a Guest | Members login | Terms of Use
managing dual-use encryption
ECS-BD | 10/27/09
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