New Proposed Rules for EAR and ITAR Data Security

On June 3, 2015, the State and Commerce Department issued proposed regulations to harmonize key terms used in the International Traffic In Arms Regulations ("ITAR") and the Export Administration Regulations ("EAR") to include the definition of the term "export".   By contrast, they also included what would not constitute an export.  As an important part of [...]

U.S. Export Controls and Data Storage in Non-US Locations

In accordance with the International Traffic in Arms Regulations (22 CFR 120-130 - herein, “ITAR”) technical data may not be exported to any Non-US Person, including to any location outside of the United States, without a specific authorization by the U.S. State Department. Managing the physical location of any servers used for email or data [...]

Changes Coming to Cloud Storage?

Up  until now, unless data is on a US-only cloud service, no US export controlled data could be on it – even if it is encrypted.    A couple of cloud service companies have attempted to fill this issue like Amazon (ref: It appears that things may change.  Below is an extraction from a proposed ruling: [...]

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