FYI.
> Begin forwarded message: > > From: IETF Administration LLC Board of Directors Chair > <[email protected]> > Subject: Compliance with Recent U.S. Export Regulations > Date: 30 May 2019 at 17:29:37 BST > To: "IETF Announcement List" <[email protected]> > Reply-To: [email protected] > > The IETF LLC is based in the United States and as such must comply with U.S. > law, as well as the laws of other countries as applicable. The U.S. > Department of Commerce’s Bureau of Industry and Security (BIS) recently > announced a rule that placed Huawei and certain Huawei affiliates on the > “Entity List” -- a list of companies that are subject to special licensing > requirements under the U.S. Export Administration Regulations (EAR).[1] > Subsequently, on May 20, 2019, the BIS issued a “Temporary General License,” > adjusting some of these requirements for a period of 90 days.[2] The rules > issued on May 20th specifically cite 5G-related standardization work in the > IETF as an area subject to the new temporary license.[3] > > The EAR generally do not apply to information that is published or that is > submitted in connection with a process that is intended to result in open > publications or presentations.[4] Given the public nature of IETF, IRTF, and > IAB activities and the fact that our output is freely published online, the > EAR are thus largely inapplicable to our materials and activities. So, the > addition of Huawei and Huawei affiliates to the Entity List -- an action > which affects only materials that would otherwise be governed by the EAR -- > has little impact on the IETF. > > After consultation with legal counsel, we have concluded that, given current > circumstances, we see no need to change our existing practices. We will > continue to monitor the situation carefully, and will work with counsel and > the IETF leadership teams to address any “corner cases” that may emerge and > raise unique concerns. For IETF contributors that believe they may be > affected, we recommend you consult your own legal counsel. > > Regards, > Jason Livingood > Chair, IETF LLC Board > [email protected] > > [1] > https://www.federalregister.gov/documents/2019/05/21/2019-10616/addition-of-entities-to-the-entity-list > > [2] > https://www.commerce.gov/news/press-releases/2019/05/department-commerce-issues-limited-exemptions-huawei-products > > [3] > https://www.bis.doc.gov/index.php/documents/regulations-docs/2396-temporary-general-license-rule/file > > [4] See 15 CFR § 734.7(a)(4) and (a)(5) at > https://www.law.cornell.edu/cfr/text/15/734.7 > > ++++++++++ How to Contact the IETF LLC ++++++++++ > Executive Director: [email protected] > Sponsorship: [email protected] > Board: [email protected] > > ++++++++++ General IETF LLC Board Background ++++++++++ > About the IETF LLC: https://www.ietf.org/about/administration/
