On Mon, Jun 24, 2013 at 10:14:19PM +0000, Gary Buhrmaster wrote:
On Mon, Jun 24, 2013 at 9:37 PM, Jamie Bowden <jamie@photon.com> wrote: ....
Actually, you CAN do that, but you have to apply for ITAR exceptions. EXIM is complex and you really want a good legal team who are familiar with it hand holding you through it (and on extended retainer going forward...).
We used to joke that our export control officer was the "designated felon" (in the case that the process/decision was wrong, that person was the one going to go to prison (and note the US Govt takes ITAR controls very very seriously; do not guess, do not even think about guessing; do not even think that the words in the regs mean what you think they mean)).
This is especially true in the case of even civilian crypto gear. Have lawyer(s) with experience in this stuff to bird-dog everything you do. It may seem like a lot of money, until you look at the fines and jail time you may wind up with if you drop a stitch somewhere. Then it all becomes quite reasonable. -- Mike Andrews, W5EGO mikea@mikea.ath.cx Tired old sysadmin