Unlocking EAR Treatment of Software Releases and Access Information Transfers: Navigating 734.15 / 734.19 and the Encryption Nexus
Bob Bowen
Export and Trade Compliance Counsel
ServiceNow
Michelle Aragon
Senior Manager, Trade Compliance
Leonardo DRS
In September 2023, the BIS amended EAR provisions on the release of software and access information related to software. These amendments have changed the EAR landscape related to the concept of release as that term applies to software and related access information. This panel will examine these changes and the impact that they have on software-related activities subject to the EAR.