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Article #4790

Export restrictions of anti-virus software?

#4790
From: Vesselin Bontchev
Date: Wed, 06 Jan 1993 20:57
68 lines
3168 bytes
The following was provided by Robert Heuman from Canada in one of the
newsgroups (sci.crypt, I think). It seems to imply that some kinds of
anti-virus programs are restricted from export in Canada. I would be
very interested whether similar export restrictions exist for the USA.
Please note that I am interested -only- in export restrictions of
anti-virus software, not in export restrictions of cryptographic
software. Could somebody in the USA who has access to the full text of
ITAR verify that? Please, if you find something, post the exact
reference and quote, if possible. Thanks.

Regards,
Vesselin

Date Entered: 12-22-92 10:34
I was asked to supply information re export control over anti-virus 
software, since I stated it was restricted in some cases.

The exact information follows:

Source: A Guide to Canada's Export Controls, January 1, 1992

Page 25, item 1150.Information Security

NOTE: The embargo status of "information security" equipment, 
"software", systems, application specific "assemblies", modules, 
integrated circuits, components or functions is defined in this 
Category even if they are components or "assemblies" or other 
equipment.


Page 25, item 1154. Software

1154.a.c.3. "Software" designed or modified to protect against 
malicious computer damage, e.g., viruses.


Page 1, General "Software: Note

This List does not embargo "software" which is either:
1. Generally available to the public by being:
    a. sold from stock at retail selling points, without restriction,
       by means of:
        1. Over the counter transactions
        2. Mail order transactions
        3. Telephone call transactions _AND_
    b. Designed for installation by the user without further 
       substantial support by the supplier, _OR_
2. "In the public domain".

A check with Ottawa resulted in the statement that F-PROT was export 
restricted (controlled) as shareware did not meet the criteria of this 
general "software" note... Therefore SCAN by McAfee also would not 
meet the requirements.

I believe a similar restriction will be found in the US regs, as 
Canada's are based in good measure on the US regs, and this specific 
restriction was added at the request of the US gov't.

Bob
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Vesselin Vladimirov Bontchev          Virus Test Center, University of Hamburg
Tel.:+49-40-54715-224, Fax: +49-40-54715-226      Fachbereich Informatik - AGN
< PGP 2.1 public key available on request. > Vogt-Koelln-Strasse 30, rm. 107 C
e-mail: bontchev@fbihh.informatik.uni-hamburg.de    D-2000 Hamburg 54, Germany
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From: bontchev@fbihh.informatik.uni-hamburg.de (Vesselin Bontchev)
Newsgroups: comp.virus
Subject: Export restrictions of anti-virus software?
Message-ID: <0021.9301071651.AA16031@barnabas.cert.org>
Date: 6 Jan 93 20:57:29 GMT
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