Hi,

I have a question about distribution of software which is based on OpenSSL libraries 
considering US export regulations.

We are planning to use OpenSSL library to develop a program with functionality similar 
to that of HTTPS client/server. We will be linking our code (static or dynamic - any 
will do) with the OpenSSL libraries. We will not have any encryption code of our own 
but only be using APIs/functions from OpenSSL.

We are planning to create two versions of our program -  one for US customers and one 
for export out of US. The exportable version will only support exportable/weak 
ciphers. Although it will be linking to the OpenSSL library, at runtime it will only 
support key legnths which are allowed under the export control regulations. (i.e. the 
OpenSSL APIs/functions will be called with restricted key legnths. I am assuming that 
we can initialize OpenSSL library at startup or hard-code values in our code to 
support only weak ciphers and limit the key length).

Will this satisfy the export requirements? Is an export license or review by the 
authorities required for this kind of application? 

I was told that even though our program is only supporting limited key lengths, it can 
not be exported as it is linking to OpenSSL which has the logic to support larger key 
lengths and strong ciphers. 

Some more info. We are a US based company and will be exporting out of US. We will not 
be making any changes to OpenSSL code and our code can not be open source.

I am sure this must be very common scenario, but haven't found any clear answers.

Thanks
Viral

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