Export Compliance News

  • A New Landscape for Information Technology Export Controls: Part 3 – Export Controls on Information Security

    There is no question that the EAR is as clear as mud when it comes to establishing and maintaining controls on hardware and software used for information security.  Even the officials at the Bureau of Industry and Security admit that the rules are exceedingly complex.  We’ve had basically the same structure of controls (i.e., Category 5 Part II, 740.17, odds and ends sprinkled over a few more sections of the EAR) since 2010...
  • A New Landscape for Information Technology Export Controls: Part 2 – Export Controls on Telecommunications

    For many years, Category 5 Part 1 remained largely unchanged in the Commerce Control List (CCL). Telecom hardware products (switches, routers, storage devices, etc.) on the market typically use encryption for user authentication and remote management as well as for data transmissions over private and public networks and thus were classified as “encryption products” ...

  • A New Landscape for Information Technology Export Controls: Part 1 - Introduction

    2020 has brought in a new wave of U.S. export controls and other significant actions that have an effect on global trade in telecommunications and information security products.  New export controls on hardware, software and related technical data have been imposed as part of efforts to identify and restrict “emerging technologies” in the telecom space...