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• In reply to: Bill Frantz

> [-] Mandatory access controls may be export controlled. Since I don't
> think we want to get into the export control mess, and we can achieve the
> security properties I think we need without providing full Orange Book
> B2/B3 mandatory access controls, we shouldn't go there.

Bill has a point, but let's be clear about the nature of the problem. As it happens, I've recently been looking into it.

The export of secure computer systems is controlled under section 5A002 of the commerce control list. The regs themselves may be found at http://w3.access.gpo.gov/bxa/ear/ear_data.html. There is a link at the bottom to the BXA home page. For those who want to do the cross-reference, the actual table of proscribed contries can be found at http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=bxa&docid=f:738spir.pdf

I recommend the postscript version, as the table did not survive ascification.

An excerpted chunk of the relevant current commerce department export control rules is attached below my signature. The key points to note are:

1. Mandatory access controls up to level B2 are perfectly okay. At B3 one begins to seriously consider covert channels.
2. The system must be certifiable. This is a rather stupid requirement, as any number of things in B2 requirements could be omitted to prevent this, and in a couple of cases omitting them would improve the security of the system.

Jonathan S. Shapiro, Ph. D.
Research Staff Member
IBM T.J. Watson Research Center
Email: shapj@us.ibm.com
Phone: +1 914 784 7085 (Tieline: 863)
Fax: +1 914 784 6576

Category 5 (Part 2) - Telecommunications and Infomation Security

                        Commerce Control List
                     Supplement No. 1 to Part 774

         CATEGORY 5 - TELECOMMUNICATIONS AND "INFORMATION SECURITY"

                   Part 2 - "Information Security"

              A.  SYSTEMS, EQUIPMENT AND COMPONENTS

5A002 Systems, equipment, application specific "assemblies", modules or integrated circuits for "information security", and specially designed components therefor.

License Requirements

Reason for Control: NS, AT, EI

Control(s)                      Country Chart

NS applies to entire entry       NS Column 1

AT applies to entire entry       AT Column 1

EI applies to encryption items transferred from the U.S. Munitions List to the Commerce Control List consistent with E.O. 13026 of November 15, 1996 (61 FR 58767) and pursuant to the Presidential Memorandum of that date. Refer to §742.15 of this subchapter.

1. Systems, equipment, application specific "assemblies", modules or integrated circuits for "information security", and specially designed components therefor:

a.6. Designed or modified to provide certified or certifiable "multilevel security" or user isolation at a level exceeding Class B2 of the Trusted Computer System Evaluation Criteria (TCSEC) or equivalent;

                          D.   Software

5D002 Information Security - "Software".

License Requirements

Reason for Control: NS, AT, EI

Control(s)                      Country Chart

NS applies to entire entry       NS Column 1

AT applies to entire entry       AT Column 1

EI applies to encryption items transferred from the U.S. Munitions List to the Commerce Control List consistent with E.O. 13026 of November 15, 1996 (61 FR 58767) and pursuant to the Presidential Memorandum of that date. Refer to §742.15 of the EAR.

1. "Software" specially designed or modified for the "development", "production" or "use" of equipment or "software" controlled by 5A002, 5B002 or 5D002.
2. "Software" specially designed or modified to support "technology" controlled by 5E002.
3. Specific "software" as follows:

c.1. "Software" having the characteristics, or performing or simulating the functions of the equipment controlled by 5A002 or 5B002;

c.2. "Software" to certify "software" controlled by 5D002.c.1.

5D992 "Information Security" "software" not controlled by 5D002.

License Requirements

Reason for Control: AT

Control(s)                   Country Chart

AT applies to 5D992.a.1       AT Column 1

AT applies to 5D992.a.2, AT Column 2 b.2 and c

c. "Software" designed or modified to protect against malicious computer damage, e.g., viruses.

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• In reply to: Bill Frantz