Guidance for ECCN 3A981 with respect to controls on fingerprint analysis equipment

The intent of ECCN 3A981 is to control automated fingerprint identification and retrieval systems and equipment specifically configured to support it. Automated fingerprint identification is the process of automatically matching one or many unknown fingerprints against a database of known and unknown prints. In practice, these systems enable police or law enforcement customers to capture fingerprints electronically, encode prints into searchable files, and accurately compare a set of fingerprints to a database containing potentially millions of prints in seconds.

Thus this ECCN is aimed at entire systems and support equipment that would be useful for large scale identification systems, which include devices such as fingerprint scanning and booking stations that electronically capture single or multiple fingerprints. These capture stations can be fixed or portable. Scanners that convert paper finger print records into a digital form are not controlled in this ECCN unless they have been specifically modified or configured for the scanning of fingerprints and are not general purpose scanners even if marketed for fingerprinting. Cameras for photographing fingerprints (either recorded or latent) are not controlled by this ECCN unless they have been specifically modified or configured to photograph fingerprints. Also controlled in this ECCN would be parts and accessories that are unique to the above equipment.

The intent of this entry is not to control automated fingerprint verification equipment which is a closely-related technique used in applications such as attendance and access control systems. This equipment matches fingerprints against a known limited database or compares or verifies a claimed identity. For example, an intruder might claim to be an employee by presenting his PIN or ID card and the system would seek to verify his identity using his fingerprint, and based on that result grant or not grant access. Examples of this type of equipment, which are not controlled in this ECCN, include door locks and portal entries, thumb readers on laptop computers, or a finger print reader incorporated into industrial equipment or vehicles to assure only approved users can operate the equipment.

Additionally, this entry does not control general purpose equipment such as optical comparators, magnifying glasses, or stereoscopic microscopes. For sensors/readers that, depending on the end user, may be incorporated into a laptop, a door lock, or a scanner for an automated finger print identification system, an official commodity classification (see Section 748.3 of the EAR) is recommended.