News & Analysis as of

Exports Encryption

Torres Trade Law, PLLC

Persistent Errors in the Export Classification of Software Products

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Many companies, particularly Software-as-a-Service (“SaaS”) and start-up companies, continue to struggle with the concept of export control classification of items with encryption functionality. This ongoing confusion is...more

Cooley LLP

Export Control Reminder: Encryption Reporting Deadline Is February 1, 2023

Cooley LLP on

The deadline for submitting reports regarding certain exports of encryption items under the US Export Administration Regulations (EAR) is February 1, 2023. Two types of reports are subject to the deadline...more

Cooley LLP

Export Control Reminder: Semiannual Encryption Reporting Deadline Is August 1, 2022

Cooley LLP on

August 1, 2022 is the deadline for submitting semiannual reports for certain encryption items exported or re-exported between January 1 and June 30, 2022, pursuant to paragraphs (b)(2) and (b)(3)(iii) of License Exception ENC...more

American Conference Institute (ACI)

[Webinar] Complimentary Webinar on U.S.-China Export & Cyber Controls - June 30th, 1:00 pm - 2:00 pm EDT

With six months into the Biden Administration, American Conference Institute invites you to join one-hour Complimentary Webinar on U.S.-China Export & Cyber Controls, which will take place on June 30th at 1:00pm EDT. The...more

Wilson Sonsini Goodrich & Rosati

U.S. Department of Commerce's Bureau of Industry and Security Relaxes Several Classification and Reporting Requirements for...

As of March 29, 2021, the U.S. Department of Commerce's Bureau of Industry and Security (BIS) has implemented significant modifications to the Export Administration Regulations (EAR) that relax requirements on the...more

Wiley Rein LLP

Commerce Eases Encryption Export Controls, Reporting Requirements

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On March 29, 2021, the Department of Commerce’s Bureau of Industry and Security (BIS) issued a final rule implementing certain changes in the Export Administration Regulations (EAR) agreed upon in December 2019 by governments...more

Cooley LLP

Alert - Export Control Reminder: Encryption Reporting Deadline February 1, 2021

Cooley LLP on

February 1, 2021, is the deadline for submitting reports regarding certain exports of encryption items under the US Export Administration Regulations (EAR). Two types of reports are subject to the deadline: 1. Annual...more

Pillsbury Winthrop Shaw Pittman LLP

China Publishes Import License List and Export Control List for Commercial Encryption

The Encryption Export List is the first list of controlled items after the issuance and implementation of China’s new Export Control Law. Under the previous legal regime, China imposed export licensing requirements on the...more

American Conference Institute (ACI)

[Virtual Event] U.S. Export & Reexport Compliance For Canadian Operations - January 26th - 27th, 9:00 am - 5:00 pm EST

For a whole decade, ACI’s U.S. Export & Reexport Compliance for Canadian Operations conference continues to stand apart as the only practical, comprehensive event of its kind for the export compliance community in Canada. ...more

Cooley LLP

Alert: 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, pursuant to paragraphs (b)(2) and (b)(3)(iii) of License Exception...more

Williams Mullen

State Dept. Adopts ITAR Amendment on Use of End-to-End Encryption in International Data...

Williams Mullen on

The State Department has adopted an important new ITAR amendment confirming that if controlled technical data is encrypted using end-to-end encryption, the transfer of such data outside the U.S. is not considered an export...more

Akin Gump Strauss Hauer & Feld LLP

Red Notice Newsletter - December 2019

IN THIS ISSUE • Anticorruption Developments • Export Control Sanctions and Customs Enforcement • Export Control and Sanctions Developments • Global Investigations Resources • Writing and Speaking Engagements ...more

Sheppard Mullin Richter & Hampton LLP

From CFIUS, With Love: The FIRRMA Regulations

The most pressing question around the new FIRRMA regulations is “Will my transaction be covered?” To provide a bit of guidance on that point, we present an illustration from our upcoming Second Edition of The CFIUS Book due...more

Cooley LLP

Alert: Export Control Reminder: Encryption Reporting Deadline February 1, 2020

Cooley LLP on

The new year brings with it the reporting deadlines for exports of encryption items under the US Export Administration Regulations. February 1, 2020, is the deadline for submitting annual self-classification reports for...more

Stinson - Government Contracting Matters

New Changes to the ITAR Focus on Unclassified Technical Data And the release of “Access Information”

As part of its years-long project to update and revise the International Traffic in Arms Regulations (ITAR) and better align them with the Export Control Regulations, the Department of State (DoS) recently amended the ITAR...more

Dechert LLP

Cloud Solutions Allowed for Encrypted, Unclassified Defense Data

Dechert LLP on

The State Department’s Directorate of Defense Trade Controls (“DDTC”) published an interim final rule on December 26, 2019, bringing the International Traffic in Arms Regulations’ (“ITAR”) treatment of encrypted electronic...more

Akin Gump Strauss Hauer & Feld LLP

DDTC Publishes ITAR Carve-out for Encrypted Technical Data and Software, and Further Harmonizes Definitions Common to the ITAR and...

• On December 26, 2019, DDTC published an interim final rule that would allow, under certain conditions, encrypted technical data and software that is subject to the ITAR to be sent, shipped or stored outside the United...more

Hogan Lovells

The grand "finale" of China's Encryption Law

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Two years on since the first draft, the final act of the legislative passage saga of the long-awaited People's Republic of China Encryption Law ended with its promulgation on 26 October 2019. It will take effect on 1 January...more

Kelley Drye & Warren LLP

UK Unpacks Encryption Controls

Despite the fact that export controls on dual-use goods derive from international agreements such as the Wassenaar Arrangement, significant differences can be seen as controls are implemented by different countries. The same...more

Akin Gump Strauss Hauer & Feld LLP

EU Trade Update

• European Commission publishes survey on concept of “Specially Designed for Military Use,” and issues request for input for possible EU commercial policy measures targeting the United States • Netherlands introduces...more

Cooley LLP

Alert: Export Control Reminder: Encryption Reporting Deadline 2/1/18

Cooley LLP on

The new year brings with it the reporting deadlines for exports of encryption items under the US Export Administration Regulations. February 1, 2018, is the deadline for submitting annual self-classification reports for...more

Kelley Drye & Warren LLP

Time to Review Your Encryption Classifications – BIS Updates Primary Purpose Exemption

The Bureau of Industry and Security (BIS) recently published changes to its encryption regulations in an effort to simplify the text and focus the scope of controls. The biggest change is that Note 4, the “primary purpose...more

Hogan Lovells

Managing global telecom supply chains – What telecommunications companies need to know about trade control laws

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Maintaining a global supply chain brings its share of commercial, financial, and regulatory risks. Increasingly, telecommunications companies with global operations and suppliers are finding that U.S. trade control laws...more

Cooley LLP

Alert: Export Control Reminder: Encryption Reporting Deadline 2/1/17

Cooley LLP on

The new year brings with it the reporting deadlines for exports of encryption items under the US Export Administration Regulations (“EAR”). February 1, 2017 is the deadline for submitting annual self-classification reports...more

Skadden, Arps, Slate, Meagher & Flom LLP

US Implements Regulation Changes for Encryption Products, Software and Technology

On September 20, 2016, the Bureau of Industry and Security (BIS) of the U.S. Commerce Department amended the Export Administration Regulations (EAR) and the list of goods, software and technology that are controlled under the...more

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