ITAA members sell frequently foreign government and associated agencies. ITAA notes some minor inconsistencies between the previous regulations and the Final Rule. ITAA believes there is sufficient evidence of wide availability of cryptographic products, which seems to obviate the need for the current policy embodied in the Final Rule. In summary, ITAA and its members support the important steps towards liberalization embodied in the Final Rule. The Final Rule represents substantial improvement over previously existing export control regulatory regimes.
Further work remains.
Even absent an urgently needed response to the European Union initiative, additional effort now should be targeted toward greater simplification of the Final Rule. Implementation processes are still a matter of great concern and warrant careful scrutiny. ITAA believes that the progress in the Final Rule holds out the promise of a solution without the need for congressional action. On behalf of its members, ITAA pledges to work constructively to explore all avenues to ensure that legitimate national security concerns are addressed while providing for the means of continued American technological leadership. Harris N. Miller President ITAA 1616 N. Ft.