Export Control Reminder: Semi-Annual Encryption Reporting Deadline August 1

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August 1, 2020, is the deadline for submitting semi-annual reports for certain encryption items exported or re-exported between January 1 and June 30, 2020,...
United States International Law
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August 1, 2020, is the deadline for submitting semi-annual reports for certain encryption items exported or re-exported between January 1 and June 30, 2020, pursuant to paragraphs (b)(2) and (b)(3)(iii) of License Exception ENC (15 CFR 740.17). The encryption items subject to the semi-annual reporting requirement include:

  • certain network infrastructure items
  • certain encryption source code that is not publicly available
  • items that have been specifically designed, modified, adapted or customized for "government end-users"
  • commodities and software for quantum cryptography
  • cryptanalytic items and items with an open cryptographic interface
  • commodities and software that provide penetration capabilities that are capable of attacking, denying, disrupting or otherwise impairing the use of cyber infrastructure or networks
  • items that perform advanced network vulnerability or digital forensics analysis
  • encryption technology classified under Export Control Classification Number (ECCN) 5E002

Note that the semi-annual reporting requirement does not apply to encryption items authorized for export under paragraph (b)(1) of License Exception ENC, including mass market products classified under ECCN 5A992 or 5D992.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Export Control Reminder: Semi-Annual Encryption Reporting Deadline August 1

United States International Law

Contributor

Cooley LLP logo
Clients partner with Cooley on transformative deals, complex IP and regulatory matters, and high-stakes litigation, where innovation meets the law. Cooley has nearly 1,400 lawyers across 18 offices in the United States, Asia and Europe, and a total workforce of more than 3,000.
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