ITARs effects

[Adam Shostack]

I cross posted the ITAR proposed rev pointers to Firewalls.  In
addition to an entertaining rant, Marcus posted this:

----- Forwarded message from Marcus J. Ranum -----

>From mjr at mail.clark.net  Thu Dec 12 17:38:57 1996
Message-Id: <199612122240.RAA10556 at mail.clark.net>
Comments: Authenticated sender is <mjr at mail.clark.net.>
From: "Marcus J. Ranum" <mjr at mail.clark.net>
Organization: V-ONE Corp Baltimore office
To: adam at homeport.org
Date: Thu, 12 Dec 1996 17:42:00 +0000
Subject: that doc....
Priority: normal
X-mailer: Pegasus Mail for Win32 (v2.42a)


You posted a pointer to that document. It was quite interesting.
I see that the feds are making INDIVIDUALS responsible for
ENFORCING export laws!!!  Read carefully:

(9) Export of encryption software. The export of encryption source
code and object code software controlled for EI reasons under ECCN
5D002 on the Commerce Control List (see Supplement No. 1 to part 774
of the EAR) includes downloading or causing the downloading, of such
software to locations (including electronic bulletin boards and
Internet file transfer protocol and World Wide Web sites) outside the
U.S., and making such software available for transfer outside the
United States, over radio, electromagnetic, photo optical, or
photoelectric communications facilities accessible to persons outside
the United States, including transfers from electronic bulletin boards
and Internet file transfer protocol and World Wide Web sites, or any
cryptographic software subject to controls under this regulation
unless the person making software available takes precautions as
adequate to prevent unauthorized transfer of such code outside the
United States. This provision applies both to the uploading and
downloading of such software. For purposes of this paragraph, the
following shall constitute adequate precautions to prevent
unauthorized transfer: 

This implies that putting something up for FTP == export. Holy
shit.

mjr.
-----
Marcus J. Ranum, Chief Scientist, V-ONE Corporation
Work:       http://www.v-one.com
Personal:   http://www.clark.net/pub/mjr
"I'll have time to be laid back when I'm laid out on a slab"

----- End of forwarded message from Marcus J. Ranum -----