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ARTICLE · 26 JULY 2018

Export Control Reminder: Semi-Annual Encryption Reporting Deadline 8/1/18

August 1, 2018, is the deadline for submitting semi-annual reports for certain ENC Restricted encryption items exported or re-exported between January 1 and June 30, 2018...

United StatesInternational Law

August 1, 2018, is the deadline for submitting semi-annual reports for certain ENC Restricted encryption items exported or re-exported between January 1 and June 30, 2018, pursuant to paragraphs (b)(2) and (b)(3)(iii) of License Exception ENC (15 CFR 740.17). The encryption items subject to the semi-annual reporting requirement include, but are not limited to, network infrastructure items, items with an open cryptographic interface, certain encryption source code and encryption items performing vulnerability or forensic analyses.

Certain "network infrastructure" items (including WAN, MAN, VPN, backhaul or long-haul equipment, certain satellite infrastructure, media gateways and terrestrial wireless infrastructure) may no longer be subject to the semi-annual reporting requirement due to changes to the encryption controls under the US Export Administration Regulations (EAR), effective September 20, 2016. In addition, network infrastructure items no longer require a

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