FW: [xacml] Groups - Export Control - U.S. (EC-US)

From
John Tolbert
Date
2009-05-19T22:59:00+00:00
ID
Thread
FW: [xacml] Groups - Export Control - U.S. (EC-US)
Replies inline...
>Section 2.2, about subject nationality: It uses "RECOMMENDED" for the
use of ISO country codes. Maybe this should be MUST to make it more
interoperable?

JT: We had thought that it might be better to leave it up to
implementers to decide if they should use 2- or 3-letter country codes.
>Also, it's unclear to me whether the "nationality" attribute lists only
those nations where the subject is currently a citizen, or all
nationalities the subject has possessed. It doesn't say the latter, but
I am asking because there is also a "current-nationality". What's the
difference? Is the difference that current nationality is single valued
while "nationality" may be multi valued. But then, why would the most
recently assigned nationality be special?

JT:  Current nationality is used for EAR; all nationalities are
considered for ITAR.  We would expect that all nationalities would be
returned in a bag of attribute values for ITAR decisions.
>Section 2.2.3, the location attribute: Do you need a value for if the
subject is located outside any country, like on international waters?
BTW, the same about citizenship. there are people who have no
citizenship.

JT: It is my understanding that you couldn't legally ship to
"international waters" or to a person without citizenship status.  Cases
where null values in those attributes occur should yield a "Deny"
decision.
>BTW, the location attribute may be difficult to authenticate securely
since it very easy to proxy a network connection through a middle man
located wherever in the world.

JT: Agreed.  We're hoping that mechanisms that provide better assurance
will be developed.
>2.2.5: what is the definition of a "US person". Maybe you can refer to
some EC law which defines it?

JT:  See http://www.access.gpo.gov/bis/ear/pdf/744.pdf
>General: Would it be good if there were some general text which
explains why these attributes are sufficient and/or useful for the
purposes of export control?

JT: See http://www.bis.doc.gov/licensing/exportingbasics.htm.  This is a
really good resource.

Thanks