We do not have an ECCN number. The following is information based on this request.
Is the solution as SAAS? Yes
Does the IT solution contain or use any encryption functionalities? Yes, OpenSSL and AWS Encryption.
OpenSSL, as open-source software, falls under export exemption TSU.
Reference 15 CFR Parts 734, 740, 742, 770, 772, and 774.
This information is derived from
3. Also in §740.13, to, in part, take into account the "open source"
approach to software development, unrestricted encryption source code
not subject to an express agreement for the payment of a licensing fee
or royalty for commercial production or sale of any product developed
using the source code can, without review, be released from "EI"
controls and exported and reexported under License Exception TSU.
Intellectual property protection (e.g., copyright, patent, or
trademark) would not, by itself, be construed as an express agreement
for the payment of a licensing fee or royalty for commercial
production or sale of any product developed using the source code. To
qualify, exporters must notify BXA of the Internet location (e.g., URL
or Internet address) or provide a copy of the source code by the time
of export. These notifications are only required for the initial
export; there are no notification requirements for end-users
subsequently using the source code.