Hi there,
An anonymous opinion from inside the Defence Dept holds that electronic bits on a wire do not constitute goods, and as a result if you ship electronically, you are not subject to the regulations. If you ship a CD or floppy or other physical media containing software, you violate the regulations.
Watch out for those anonymous opinions; I received exactly the opposite opinion when I spoke to the Defence Signals Directorate about the issue (back in 1994) -- after specifically asking about a few hypothetical cases. Of course, either opinion may be correct, which is the real problem!
I'll add this to the SSLeay legality FAQ - standard disclaimers apply of course, obtain professional legal advice before exporting SSLeay.
Definitely ... what a pain, however :-(. Best of luck! Matthew. -- Matthew Gream -- matt@lust.bio.uts.edu.au.