ITAR Amended to Allow Personal Use Exemptions

Today's Federal Register contains a notice from the Department of
State, Bureau of Political Military Affairs, announcing final rule of
an amendment to the International Traffic in Arms Regulation (ITAR)
allowing U.S. persons to temporarily export cryptographic products for
personal use without the need for an export license.  The product must
not be intended for copying, demonstration, marketing, sale, re-export,
or transfer of ownership or control.  It must remain in the possession
of the exporting person, which includes being locked in a hotel room or
safe.  While in transit, it must be with the person's accompanying
baggage.  Exports to certain countries are prohibited -- currently
Cuba, Iran, Iraq, Libya, North Korea, Sudan, and Syria.  The exporter
must maintain records of each temporary export for five years.  See
Federal Register, Vol. 61, No. 33, Friday, February 16, 1996, Public
Notice 2294, pp. 6111-6113.

Since we don't need a license, what records are we supposed to keep?


| Today's Federal Register contains a notice from the Department of
| State, Bureau of Political Military Affairs, announcing final rule of
| an amendment to the International Traffic in Arms Regulation (ITAR)
| allowing U.S. persons to temporarily export cryptographic products for
* personal use without the need for an export license.  The product must
| not be intended for copying, demonstration, marketing, sale, re-export,
| or transfer of ownership or control.  It must remain in the possession
| of the exporting person, which includes being locked in a hotel room or
| safe.  While in transit, it must be with the person's accompanying
| baggage.  Exports to certain countries are prohibited -- currently
| Cuba, Iran, Iraq, Libya, North Korea, Sudan, and Syria.  The exporter
* must maintain records of each temporary export for five years.  See
| Federal Register, Vol. 61, No. 33, Friday, February 16, 1996, Public
| Notice 2294, pp. 6111-6113.

-- 
"It is seldom that liberty of any kind is lost all at once."
					               -Hume

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>>>>> "Adam" == Adam Shostack <adam@homeport.org> writes:

Adam> Since we don't need a license, what records are we supposed to
Adam> keep?

When IBM internally transfer crypto-software to locations outside US
they have to keep

* Name of sender + receiver
* date of transmission
* method of transmission


I'd assume that with this personal-use exection you have to keep the
date of your travel and the location(s) you traveled to.  (Your name
might be something you remember without keeping track of it ;-)

Olmur
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