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Quora article on issues in US export of products using strong encryption => https://www.quora.com/What-regulatory-issues-have-to-be-cons...

I hate these regulations but EAR and ITAR with respect to crypto seem to be concerned with the key length and algorithm. Over a certain strength the software using the encryption seems to be still treated as a munition!? I've heard of people who ignore this getting huge fines.

And any export to Cuba, N. Kora, Sudan, Syria, and Iran is banned by OFAC (Office of Foreign Assets Control). Yes, the very countries that need Signal the most are banned!

Hopefully I'm wrong and we are free of regulatory issues in the US so I'm asking a serious question here - how does Signal solve this problem?



I think the US still requires cryptography products to be registered with the Department of Commerce, but that's about it for non-military products.


I've tried reading the regulations (but IANAL) and am almost certain that over a key-length for given algorithms its a munition and an export license or similar is required with regular updates.

And then still there is the issue of the OFAC banned countries list.

I'm hoping Signal's compliance can show other hackers how to also comply without hassle or fear.


I think this is the one: https://www.bis.doc.gov/index.php/documents/regulations-docs...

> You must submit a classification request or self-classification report to BIS for mass market encryption commodities and software eligible for the Cryptography Note employing a key length greater than 64 bits for the symmetric algorithm (or, for commodities and software not implementing any symmetric algorithms, employing a key length greater than 768 bits for asymmetric algorithms or greater than 128 bits for elliptic curve algorithms) in accordance with the requirements of § 740.17(b) of the EAR in order to be released from the “EI” and “NS” controls of ECCN 5A002 or 5D002.




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