FAQ: Can I export protected documents to countries outside the USA?

Export licensing of encryption/decryption engines are covered in the Wassenaar agreement (formerly Cocom) where encryption systems are classified as dual-use goods that may be subject to export licensing controls.

As far as we are aware, there are no export restrictions on the Viewer application software that we provide, from the UK, USA, Canada, Australia and so on. This is because Wassenaar does not mention pure decryption systems. It is possible that some states may operate Import restrictions on such systems, but we have not been made aware of any difficulties experienced by our customers on this point.

The situation is different for the Writer program (used to encrypt the pdf documents).

In this case, LockLizard is compliant with UK (and hence Wassenaar) regulation in that our software does not allow a customer to vary the algorithm used, introduce their own algorithm(s) or key lengths. The software is available publicly and may be purchased freely over the Internet or by postal service through our operations system. As a result, we do not need to apply for an export license, or make a declaration of export listing the credentials of the purchasing party. At the same time we do not, and your contract with us forbids you to, export the Writer application to any country that is on the proscribed list as published from time to time by the national security agencies or trade organizations. A typical example of a country that cannot currently be exported to is Iraq.

Again, it is possible that nation states may forbid the import of encryption systems without an appropriate license. In the 1990s China operated import control over cryptographic mechanisms, but we understand that the policy was modified to allow for the introduction of ‘strong’ encryption as provided by Microsoft (the Microsoft Cryptographic Services Provider) which can offer encryption strengths equivalent to our own, US government recommended systems.

Our viewer software is publicly accessible from many sites globally, and we have not become aware of any restrictions placed upon its use by any nation state. Indeed, it is used by a number of governments to secure information they wish to distribute.

Export licensing of encryption/decryption engines are covered in the Wassenaar agreement (formerly Cocom) where encryption systems are classified as dual-use goods that may be subject to export licensing controls.

As far as we are aware, there are no export restrictions on the Viewer application software that we provide, from the UK, USA, Canada, Australia and so on. This is because Wassenaar does not mention pure decryption systems. It is possible that some states may operate Import restrictions on such systems, but we have not been made aware of any difficulties experienced by our customers on this point.

The situation is different for the Writer program (used to encrypt the pdf documents).

In this case, LockLizard is compliant with UK (and hence Wassenaar) regulation in that our software does not allow a customer to vary the algorithm used, introduce their own algorithm(s) or key lengths. The software is available publicly and may be purchased freely over the Internet or by postal service through our operations system. As a result, we do not need to apply for an export license, or make a declaration of export listing the credentials of the purchasing party. At the same time we do not, and your contract with us forbids you to, export the Writer application to any country that is on the proscribed list as published from time to time by the national security agencies or trade organizations. A typical example of a country that cannot currently be exported to is Iraq.

Again, it is possible that nation states may forbid the import of encryption systems without an appropriate license. In the 1990s China operated import control over cryptographic mechanisms, but we understand that the policy was modified to allow for the introduction of ‘strong’ encryption as provided by Microsoft (the Microsoft Cryptographic Services Provider) which can offer encryption strengths equivalent to our own, US government recommended systems.

Our viewer software is publicly accessible from many sites globally, and we have not become aware of any restrictions placed upon its use by any nation state. Indeed, it is used by a number of governments to secure information they wish to distribute.