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Export & Sanctions Notice

Lucy in the Loop may include encryption. You are responsible for compliance with applicable export, re-export, and sanctions laws, including U.S. EAR and OFAC regulations and EU/UK measures. Do not download or use if you are a prohibited party or in a sanctioned destination. Publicly-available open source code may be subject to exceptions, but your specific use remains your responsibility.

Plain-English Overview (U.S. EAR Cat 5, Part 2 and OFAC)

Encryption (EAR Category 5, Part 2). Software that includes or uses encryption is generally controlled under the U.S. Export Administration Regulations (EAR). Most open-source encryption is eligible for License Exception ENC or is “mass market,” which typically allows export without a license to most destinations, but restrictions still apply for embargoed countries and prohibited end users.

What this means for you:

  • You should not export, re-export, or make available the software to embargoed jurisdictions (e.g., Cuba, Iran, North Korea, Syria, Crimea/ Donetsk/Luhansk regions) or to denied/restricted parties.
  • If you package binaries with encryption, you may need to rely on License Exception ENC or mass-market classification. When in doubt, consult counsel or BIS guidance.

OFAC Sanctions. The U.S. Treasury’s Office of Foreign Assets Control (OFAC) administers economic and trade sanctions. You must not provide services or software to persons or entities on OFAC sanctions lists, or to comprehensively sanctioned territories, without authorization.

Project stance:

  • We do not knowingly accept contributions or provide services to sanctioned or denied parties.
  • We may block participation from embargoed jurisdictions in community systems where feasible.

References:

  • EAR 742.15 (Encryption items) and Cat 5 Pt 2
  • BIS guidance on License Exception ENC and mass market
  • OFAC Sanctions lists and program summaries