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ARTICLE · 30 JULY 2020

Export Control Reminder: Semi-Annual Encryption Reporting Deadline August 1

Cooley LLP
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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,...

United StatesInternational Law
Kevin King
Kevin King
Rebecca Ross
Rebecca Ross
Karen Tsai
Karen Tsai
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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 ENC (15 CFR 740.17). The encryption items subject to the semi-annual reporting requirement include:

  • certain network infrastructure items
  • certain encryption source code that is not publicly available
  • items that have been specifically designed, modified, adapted or customized for "government end-users"
  • commodities and software for quantum cryptography
  • cryptanalytic items and items with an open cryptographic interface
  • commodities and software that provide penetration capabilities that are capable of attacking, denying, disrupting or otherwise impairing the use of cyber infrastructure or networks

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