🚀 go-pugleaf

moore@cs.utah.edu (Tim Moore) writes:
> By the way, is this stuff really a law or is 
> it regulations draw up by bureaucrats in the executive branch? 

It is the set of regulations, enforced by the Department of State, that 
regulate international arms traffic.  The DoS was given the authority to 
promulgate such regulations by Congress.

> My point is that some of terms, as quoted by PKP, are ambiguous and 
> imply that a whole range of activities are forbidden by ITAR.

A whole range of activities are indeed forbidden by ITAR.

> I interpret the PKP letter by itself to claim that almost any 
> international activity related to cryptography is forbidden.

This is correct.  There are particular exceptions (such as the use of crypto 
technology for authentication but not encipherment), but in general you need 
the same kinds of licenses to import & export cryptographic technology as you 
do other kinds of weapons, such as bombers, tanks, or missiles.

> I'm having a hard time swallowing it. 

Chuckle.  Sigh.  I gather you've never had the pleasure of doing business 
with the government in areas that have military or intelligence implications.

> Exporting classified information isn't a just a violation of ITAR; it's 
> espionage.

Correct.  RSA and DES aren't classified, so this doesn't apply.  However, 
many things that aren't classified are nonetheless considered a matter of 
national security--remember the VAX export fiascos of a decade or so ago?

> Maybe you could reveal how exporting this information 
> doesn't violate ITAR since the passages quoted by PKP would seem to 
> forbid it. 

As I remember, ITAR explicitly does not apply to technical data which has 
been published in publically available media (books, magazines, etc.).

> if I can't implement the IDEA cipher based on a description in a 
> European conference proceedings, I'm worried.  Can you tell me, David, 
> from your reading of the law, that I can do that without violating 
> import/export regulations? 

You can implement it to your heart's content--you just can't then transport 
it out of the country without an arms license.



Amanda Walker
InterCon Systems Corporation