Re: Debian usage in Russia
Thank you very much!
Best regards, Yuri Trukhin
MTS Cloud Development Director | PJSC "MTS"
Mob: +79955002005 | Mail: trukhinyuri@mts.ru
Moscow, Andropova avenue, 18, building 9, floor 15, 1528
https://cloud.mts.ru
On 4/15/22, 18:52, "Andrew M.A. Cater" <amacater@einval.com> wrote:
Это внешнее сообщение! Будьте осторожны при открытии вложений и ссылок.
On Fri, Apr 15, 2022 at 02:19:56PM +0000, Трухин Юрий wrote:
> Good afternoon!
>
> We are planning to use Debian Source Code (all builds) (the “Software”) in Russia and have several questions related to Unrestricted Encryption Source Code Notification Commodity (https://www.debian.org/legal/notificationforarchive, “Notification”) and export restrictions of the US Export Control Act ("EAR").
>
> In your Notification you mention that Debian is free access code (accordingly we suppose that it can be EAR99 or Not subject to EAR). At the same time you refer to the exception TSU specified in Part 740.13 EAR (however, paragraph e(1) is missing in the text we saw https://www.ecfr.gov/current/title-15/subtitle-B/chapter-VII/subchapter-C/part-740/section-740.13). You also refer to the cryptography functionality thank can trigger exception ENC as well
>
> Accordingly we would like to know whether:
> (1) the Software can be freely distributed, including in Russia, due to being EAR99 or Not subject to EAR
> (2) the Software is subject to other ECCN (please specify, which one) and can be distributed only subject to exceptions (TSU, ENC or other - please specify)
>
> Thank you
>
>
> Best regards, Yuri Trukhin
> MTS Cloud Development Director | PJSC "MTS"
> Mob: +79955002005 | Mail: trukhinyuri@mts.ru<mailto:trukhinyuri@mts.ru>
> Moscow, Andropova avenue, 18, building 9, floor 15, 1528
> https://cloud.mts.ru
>
[Replying to the list - with a personal copy to Director Trukhin in the event that he is not subscribed to the
list. This is an exception to the normal list rules here].
Dear Yuri,
There has been a similar query in the Debian mailing lists at debian-project a few days ago. Let me see if I
can summarise the mailing list thread there.
The requirement to submit source code for scrutiny by US export authorities is an old one. It dates to
approximately 2000-2001.
The legal opinion then to Debian from US lawyers is at https://www.debian.org/legal/cryptoinmain.en.html
At one point, the Debian project was obliged to maintain cryptographic software in a separate "non-US" archive.
That hasn't been the case for approximately 15 years, if I recall correctly.
The requirement for review by the NSA went long ago with changes in US cryptographic policy.
As regards countries subject to US sanctions: Debian will not normally set up new official mirrors in places
like Syria or Cuba but this is academic (see below).
Various people have asked about ECCN over the years: it seems that our software is acceptable for US export
and import.
It appears that import and use in Russia would be acceptable under current Russian law:
https://www.debian.org/mirror/list suggests that there are already six mirrors within the Russian Federation.
One of these is an "official" country level mirror of Debian. [http://ftp.ru.debian.org]
Bandwidth may vary: I'd suggest contacting the administrators there to see how usable it is. You may also
find that a local university or higher education institution may already have a private Debian mirror.
ftp.ru.debian.org appears to be at campus.mephi.ru [National Research Nuclear University: MEphI] and the
administrator's email address is mirror-private@ut.mephi.ru .
All of this suggests that there is no particular problem either from Debian or from within Russia / from
the Russian authorities. Any situation may change: you will probably get the best information by talking to
Russians already using/adminstering/responsible for Debian systems.
https://www.debian.org/international/Russian suggests two Debian mailing lists. We also appreciate that not
all of our documentation, websites or Wiki pages are translated but https://www.debian.org/index.ru.html may
also give you useful information in Russian if this is of help to you.
With every good wish, as ever,
Andrew Cater
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