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RE: No liberalization for source code, API's

daemon@ATHENA.MIT.EDU (Trei, Peter)
Mon Sep 20 10:34:53 1999

Message-ID: <D104150098E6D111B7830000F8D90AE8E62A76@exna02.securitydynamics.com>
From: "Trei, Peter" <ptrei@rsasecurity.com>
To: cryptography@c2.net, cypherpunks@cyberpass.net,
        "'Greg Broiles'" <gbroiles@netbox.com>
Cc: "Trei, Peter" <ptrei@rsasecurity.com>
Date: Mon, 20 Sep 1999 10:24:59 -0400
MIME-Version: 1.0
Content-Type: text/plain



> ----------
> Greg Broiles[SMTP:gbroiles@netbox.com] wrote:
> Subject: 	No liberalization for source code, API's
> 
> There's been some discussion of this in the press, but not much discussion
> 
> of the specifics. BXA has published a "question-and-answer" document 
> discussing the anticipated regulations; it's available at 
> <http://www.bxa.doc.gov/Encryption/q&a99.htm>, and John Young has archived
> 
> a copy at <http://cryptome.org/bxa091699.htm>.
> 
	[...]
> Also, their thinking about API's seems to have become more nuanced; they 
> now envision two classes of API's which are treated differently for export
> 
> purposes, to wit -
> 
>  >How does the update to encryption policy affect the export of
>  >cryptographic application programming interfaces (CAPIs)?
>  >
>  >Cryptographic interfaces are divided into two classes: Open
> Cryptographic
>  >Interfaces (OCI) andClosed Cryptographic Interfaces (CCI). OCI's are
>  >considered crypto-with-a-hole because they permit a customer or other
> party
>  >to insert cryptography into an encryption item. OCI's will continue to
> be
>  >reviewed on a case-by-case basis through the licensing process.
>  >
>  >CCI's contain a mechanism (such as a digital signing key) that prevents
> a
>  >customer or other party from inserting cryptography into an encryption
> item.
>  >After a technical review of the binding mechanism, these products will
> be
>  >eligible for export under a license exception. If destined to a
> commercial
>  >enduser, the additional signing can take place under a license exception
>  >after a technical review. If destined to a foreign government or
> military
>  >entity, the additional signing requires a license.
>  >
>  >We intend to discuss this issue with industry as we consult on the
>  >implementation of this regulation.
> 
So, has MS-CAPI changed from a CCI to an OCI, now that 
people can replace the _NSAKEY with their own, and use
any strength crypto components they wish?

Peter Trei
ptrei@rsasecurity.com

Disclaimer: I am not speaking for my employer.



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