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- Newsgroups: sci.crypt
- Path: sparky!uunet!rosevax!texan!bill
- From: bill@texan.rosemount.com (William Hawkins)
- Subject: Re: Exporting password protection
- Message-ID: <1992Dec21.065550.16784@rosevax.rosemount.com>
- Sender: news@rosevax.rosemount.com (USENET News administrator)
- Nntp-Posting-Host: texan
- Organization: Rosemount, Inc.
- Distribution: usa
- Date: Mon, 21 Dec 1992 06:55:50 GMT
- Lines: 47
-
-
- Thanks to you who have replied to my query on exporting password
- protection. You are correct that it is a matter for Commerce,
- and not State, but that is the problem.
-
- In July of '92, the Department of State, Bureau of Politico-
- Military Affairs, issued an amendment to the International
- Traffic in Arms Regulations Munitions List. Basically, it says
- that a company wishing to export a mass market software product
- containing encryption may apply to DOS (State) for a transfer
- of jurisdiction to the Department of Commerce (DOC) IF the
- software is mass market (over the counter with no special
- training or support (process control systems require lots of
- training and support, but not for encryption)) AND the data
- encryption algorithm is RC4 and/or RC2 with a key space of 40
- bits. It is noted that RC4 and RC2 are proprietary to RSA
- Data Security, Inc. It must not be possible for both RC4 and
- RC2 to operate on the same data.
-
- If you can meet those criteria, you can be transferred to DOC
- in one to two weeks. The problem is that Commerce seems to
- think that anything that hides data requires an export license.
- Reading the words, it looks like rot13 would be prohibited
- without a license. Nor does it count that your non mass media
- software uses the *same* encryption algorithm as mass media
- software.
-
- One kind of DOC license requires the recipient of the software
- to swear that the software will not be exported to anyone on
- the restricted list. You can imagine how much trouble it must
- be to keep up with the list. Think about it. The list is made
- for geographical boundaries. When is the last time that a piece
- of geography threatened you? Iran is on the forbidden list. Are
- there any citizens of Iran outside the geographical borders of
- that country? Do they have access to encryption techniques? I
- do not mean to pick on Iran, but only to show that the borders
- have nothing to do with access to information.
-
- We will, of course, comply with the law of the land, as interpreted
- by the nearest bureaucrat. By way of disclaimer, it is not my job
- to find out what the bureaucracy requires; I only sit on the
- sidelines and watch it all go by.
-
- Today is the 21'st. News arrives from the 15'th, so I still
- invite email replies.
-
- bill@texan.rosemount.com Minneapolis, MN (612) 895-2085
-