Export Compliance Notice
Devu can be exported worldwide under the 'ENC' Mass Marketing. The ECCN is 5A992. Austria, Australia, Belgium, Canada, Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Japan, Luxembourg, Netherlands, New Zealand, Norway, Poland, Portugal, Spain, Sweden, Switzerland, United Kingdom Outside the EU and eight other countries, Devu is restricted for export to certain government end-users as defined below. The Devu products are available worldwide for consumer only export unless country of persons are listed as part of the sanctioned countries and denied parties.

Exports to U.S. Subsidiaries & Foreign Companies
Wholly-owned subsidiaries of U.S. companies may export all Ceelox secure products to any country other than the sanctioned countries listed below. Under previous ENC export regulations, U.S. company subsidiaries and foreign companies in financial and medical industries were eligible to purchase SyncITBaby, BioBaby and BioBaby Server Edition. Any Ceelox customers who purchased Devu licenses under these exemptions may continue to buy under the new regulations. Under ENC rules, export licenses are not required. The ECCN is 5A992.


Sanctioned Countries and Denied Parties
The following are countries where sales of strong encryption technology are prohibited. Cuba, Iran, Iraq, Libya, North Korea, Sudan, Syria The U.S. Departments of State, Treasury and Commerce maintain lists of companies, organizations, and individuals with which U.S. companies are prohibited from trading. Ceelox is required to screen all export sales against these lists. Orders may be cancelled based on screening results.


Definition of "Government end-user"
Definition of "Government end-user" as applied to encryption items.

A government end-user is any foreign central, regional or local government department, agency, or other entity performing governmental functions; including governmental research institutions, governmental corporations or their separate business units (as defined in part 772 of the EAR) which are engaged in the manufacture or distribution of items or services controlled on the Wassenaar Munitions List, and international governmental organizations. This term does not include: utilities (including telecommunications companies and Internet service providers); banks and financial institutions; transportation; broadcast or entertainment; educational organizations; civil health and medical organizations; retail or wholesale firms; and manufacturing or industrial entities not engaged in the manufacture or distribution of items or services controlled on the Wassenaar Munitions List.


Encryption Export Policy Information
For more information, see the following U.S. government web sites.

U.S. Department of Commerce
Bureau of Industry and Security