I've spent quite a bit of time reviewing the current regulations and talking on the phone with BIS in the past month about encryption export as part of a contra

I've spent quite a bit of time reviewing the current regulations and talking on the phone with BIS in the past month about encryption export as part of a contract, it can be complicated or quite simple, depending entirely on things like: Is it infosec software, or a game/kitchen recipe app? Is it using "standardized" algorithms? Can they or the key sizes be changed by the end user? Can the encryption functionality be easily repurposed? Binaries or source code? Which destination country(s)? Who is the intended end user (government vs private entities)? As there can be significant civil and even criminal penalties for exporting an item without complying with the regulations, the best thing to do in all cases is to call BIS[1] and ask to speak with an export counselor, specifically ask about encryption and you'll get routed to someone who knows the regulations and can tell you exactly what your specific software will require to comply. > What's the status with the US crypto export paperwork that Apple apparently requires for all crypto-enabled apps, even if they just use iOS builtin URL classes with https urls? Apple (last time I checked) directs developers to obtain an Encryption Registration Number at minimum, but there can be additional "classification" and reporting requirements depending on the factors I listed above. > In fact it seems strange to require non-US developers, who purchased an iOS developer program account from a non-US Apple company, to register with US government for "export" when all they want to do is publish their app on a non-US app store. An export counselor could give a definitive answer but this is likely because the encryption they're using in iOS/OS X is still considered a U.S. controlled item for export purposes, regardless of where they are or where the software using it ends up being sold. That software may end up being considered a U.S. controlled item itself. I've been told by BIS that re-exporting a U.S. controlled item from a foreign country without complying with U.S. export regulations can come back to bite you down the road, among other things they can completely deny a foreign entity the ability to export or import things to/from the U.S. if they decide export regs have been ignored. [1] https://www.bis.doc.gov/index.php/about-bis/contact-bis https://www.bis.doc.gov/index.php/about-bis/contact-bis