• (03/20/2024):

    (03/20/2024): Commerce Rule Advances U.S. National Security by Enhancing Coordination Between Commerce Export Controls and Treasury Sanctions

  • (03/14/2024):

    (03/14/2024): Commerce Updates Rules To Further Restrict Exports To Nigaragua Due To Foreign Policy Concerns

  • (3/07/2024):

    (3/07/2024): Chinese National Residing in California Arrested for Theft of Artificial Intelligence-Related Trade Secrets from Google

  • (3/05/2024):

    (3/05/2024): Two Defendants Arrested for Conspiring to Illegally Export Weapons to South Sudan

  • (3/01/2024):

    (3/01/2024): Russian International Money Launderer Pleads Guilty to Illicitly Procuring Large Quantities of U.S.-Manufactured Dual-Use, Military Grade Microelectronics for Russian Entities

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March 27-29, 2024, Update Conference on Export Controls and Policy, Washington, D.C. (2)

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April 23-24, 2024, Complying with U.S. Export Controls seminar, Los Angeles, CA

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In partnership with the Southern California District Export Council, BIS is offering a two-day in-person program that will cover the information exporters need to know to comply with U.S. export control requirements under the Export Administration Regulations. Click here for details.

 

   

 

≤ 56 symmetric, ≤ 512 asymmetric, and ≤ 112 bit elliptic curve

Category 5 Part 2 includes certain key length thresholds for cryptography. Specifically, 5A002.a says “in excess of 56 bits of symmetric key length, or equivalent”. This term is further defined in Technical Note 1 under 5A002.a and it means the following:

A “symmetric algorithm” employing a key length in excess of 56-bits is controlled in Category 5, Part 2. Therefore, items with a key length of 56 bits or less are not in 5A002.a.  Note that parity bits do not count towards the key length. Symmetric algorithms use an identical key for both encryption and decryption.

Asymmetric algorithms use different, mathematically related keys for encryption and decryption.
An “Asymmetric algorithm” is controlled in Category 5 Part 2 if the security of the algorithm is based on any of the following:

-          Factorisation of integers in excess of 512 bits (e.g., RSA);

-          Computation of discrete logarithms in a multiplicative group of a finite field of size greater than 512 bits (e.g., Diffie-Hellman over Z/pZ); or

-          Discrete logarithms in a group other than mentioned in paragraph b.2. in excess of 112 bits (e.g., Diffie-Hellman over an elliptic curve).

Therefore, items with a key length ≤ 56 symmetric, ≤ 512 asymmetric, and ≤ 112 bit elliptic curve are not classified in 5A002.a. In that case, you should review other entries in Category 5 Part 2 and other Categories on the CCL (e.g., Cat. 4 or Cat. 5, Part 1).  If it is not described in any other Category then it can be classified as EAR99.


 

 

 

   
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