Clouded By Uncertainty
Cloud Computing, IT Systems, and Export Compliance
WorldECR: The Journal of Export Controls and Sanctions
November 2012

Big Data is here. Every day, companies of all sizes collect and store reams of information related to every aspect of their businesses in electronic storage systems. For some companies, collecting and storing data is their business. To manage the perpetual information influx, many corporations are turning to “cloud computing” – that is, storing data, as well as software and computing applications, on remote servers accessible via the Internet  – as the most cost-effective and efficient solution. But while “the cloud” has much to recommend it, it also carries potential pitfalls, particularly with respect to export control laws.

This article will help exporters understand how to properly handle controlled data in compliance with International Traffic in Arms Regulations (ITAR) and Export Administration Regulations (EAR), and why it is in every company’s best interest to consult with experienced export compliance counsel before sending information out into the electronic ether.