Great Circle Associates Firewalls
(April 1997)
 

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Subject: Re: encryption exports
From: Adam Shostack <adam @ homeport . org>
Date: Tue, 15 Apr 1997 20:55:03 -0500 (EST)
To: sgcccdc @ citec . qld . gov . au (Colin Campbell)
Cc: firewalls @ GreatCircle . COM
In-reply-to: <199704152258 . IAA08066 @ guru . citec . qld . gov . au> from Colin Campbell at "Apr 16, 97 08:58:24 am"

Colin Campbell wrote:

| Can someone illuminate me (and possibly others) on the exportability
| of RC4-based systems.

See www.bxa.doc.gov for the regulations themselves. They explicitly
mention rc2 and rc4 with keylengths of 40 bits or less getting
expidited treatment.

| Here's what I know.
| 
| There are several VPN products around using RC4 encryption. In all 
| cases the "international" version uses 40-bits and the "domestic"
| 128-bits.
| 
| Now my questions:
| 
| 1) Is 128-bit RC4 exportable from the US to a gov't/financial body?

	Probably not.  As I understand it, they're approving to 64,
and not longer for general purpose systems.  The special case for a
bank disappeared with the move from State dept to Commerce Dept
control, probably in a political bid to get banks to buy GAKware.
There was never an exception for foriegn governments written into the
law.

	112 bit 3des was not exportable to US employees of a US
company operating overseas.

	Don't buy in the US.  Import what you need, and depriciate it.

| 2) If I have a head office in the US and branch offices elsewhere in
|    the world what are the export restrictions?

	Buy foriegn is my advice.

| 3) If I have a branch office in the US and I am a gov't body, what
|    if any, are the export restrictions?

	Are you a US or Foriegn government?  If you are thinking about
Australian government stuff, stick it in a diplomatic pouch and move
it as you will.  You think the Soviets left their crypto gear in the
US because of some US law?

Adam


-- 
"It is seldom that liberty of any kind is lost all at once."
					               -Hume




References:
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From: Woody Weaver <woody @ softiron . com>
Next: Phrack 50 is out
From: "Michael Cunningham" <Michael . Cunningham @ voicenet . com>
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From: Colin Campbell <sgcccdc @ citec . qld . gov . au>
Next: Re: encryption exports
From: Frederick M Avolio <avolio @ tis . com>

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