[Mozilla Enterprise] Mozilla in Embargo countries

[Stephen Dowdy]

On 7/17/19 12:14 PM, Mike Kaply wrote:
> Firefox and NSS are publicly available software not subject to the Export Administration Regulations (EAR) per EAR 734.3(b) and 734.7. Because Firefox is not subject to the EAR it does not have an Export Control Classification Number (ECCN). Mozilla has completed the notification for Firefox and NSS publicly available encryption source code per EAR 742.15(b).
> 
> The '''Export Notice''' can be found at
> 
> http://ftp.mozilla.org/pub/mozilla.org/security/export-notice
> 
> Note that we cannot provide legal advice on deploying Firefox in embargoed countries. For that, we recommend you consult your legal team.

I will add that just because the software is EAR doesn't mean it's okay.

(There are 3 branches of govt involved in Export Control
     Dept of State : ITAR
     Dept of Commerce : EAR
     ?i forget? : OFAC  (foreign commerce)

playing with the Embargoed Nations is not something you want to do lightly.

It might be fine for your customers to install themselves, but you can get in trouble by providing *support* (engaging in commercial ventures, doing the work, collaborating, answering technical questions)

In Summary: You're gonna need a good lawyer handling your export control issues.

Everyone you ask about this will be terse and ambiguous, because the laws are complex, contradictory, absurd, and violations can be expensive or result in jail time.

Wheeeeeeee!

--stephen


-- 
Stephen Dowdy  -  Systems Administrator  -  NCAR/RAL
303.497.2869   -  sdowdy at ucar.edu        -  http://www.ral.ucar.edu/~sdowdy/