I am anything _but_ a lawyer, but ... On 2 May 97 at 1:35, Anil Das wrote:
These ECCNs (whatever that means) is in http://jya.com/774-ccl05.htm. 5A002 is for hardware modules that do encryption functions. 5D002 applies to software. I won't quote it here, but from my reading it lists only software designed or modified for certain purposes, such as putting it in a hardware module, for one.
Filling in the cross-references between 5D002 and 5A002 in the above URL, I read the following: a. Software having the same characteristics, or performing or simulating the functions of of equipment designed or modified to use "cryptography" employing digital or analog techniques to ensure "information security" is controlled. b. Software designed or modified to use such software is controlled. This is the clearest control of software "hooks" I have read in the reg. The software module performing encryption would fall under control due to (a) and the software designed with "hooks" for the encryption module would fall under control due to the restriction in (b). FWIW Scott