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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

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