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OFAC regulates international trade. Isn't Tor's publication an act of pure speech, rather than commerce? They're not charging for it, and they aren't physically moving any goods across borders. How could Tor be subject to any restrictions here?

(not a lawyer, just someone who naively thought the Crypto Wars ended in the 90s)



I'm not sure that's why I'm asking.


Encryption isn’t ITAR.




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