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Significant Update to US Encryption Export Rules (and Other Commerce Control List Changes)

By Alexandra Baj on October 4, 2016
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On September 20, the US Department of Commerce (DOC) published a final rule revising the Commerce Control List (CCL) and other sections of the Export Administration Regulations (EAR).  This rule implements revisions decided at the December 2015 Wassenaar Arrangement plenary meeting, but also includes additional updates to the EAR.  The final rule revises 58 Export Control Classification Numbers (ECCNs), adds two ECCNs, and revises license exception eligibility for seven ECCNs.  The changes center on ECCNs controlled for national security reasons, but the most significant changes are to DOC’s encryption rules, which last saw major changes in June 2010.  The DOC changes took effect at the September 20 publication of this final rule.  For more information, please see our advisory.

Photo of Alexandra Baj Alexandra Baj

Alex Baj’s practice primarily involves export controls and economic sanctions laws and regulations, anti-corruption investigations and compliance, international trade, and security clearance issues. Alex advises clients on export control and economic sanctions laws and regulations, including the Export Administration Regulations (EAR), International…

Alex Baj’s practice primarily involves export controls and economic sanctions laws and regulations, anti-corruption investigations and compliance, international trade, and security clearance issues. Alex advises clients on export control and economic sanctions laws and regulations, including the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), US sanctions regulations administered by the Office of Foreign Assets Control (OFAC), and nuclear export controls under the jurisdiction of the Nuclear Regulatory Commission (NRC).  Alex specializes in the development and implementation of export and anti-corruption compliance policies and procedures and training, internal investigations and voluntary disclosures under the EAR, the ITAR, and OFAC rules, due diligence for mergers and acquisitions, and on encryption and cybersecurity export controls.  Her clients include companies involved in defense, aerospace, software, semiconductor, and uranium processing industries.

Read Alex’s full bio.

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  • Posted in:
    Antitrust, Competition and Trade
  • Blog:
    International Compliance Blog
  • Organization:
    Steptoe LLP

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