US ITAR and EAR - Export Control and Data Security
Encryption, storage, cloud and travel – US ITAR and EAR - Export Control and Data Security

US ITAR and EAR - Export Control and Data Security ITAR 120.54(c) and EAR 734.18(c): Allow access to ciphertext by service providers only where the encryption carve-out is met

The ability to access technical data or technology in encrypted form that satisfies the carve-out is not a release or export (120.54(c); 734.18(c)). This is what allows foreign-national staff of a hosting or managed service provider to administer storage that holds controlled data: they may handle ciphertext, but they must not hold access information. Selection and contracting of cloud, backup, email and collaboration services for controlled data should therefore test key custody and the location conditions, not only the provider's nationality claims.

Maintained by Gerard BlokdykVerified against the published standard Control text last updated

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