You should ask your lawyers to read the license that comes with OpenSSL. If they claim to need "official" answers, ask them why, and ask them how they would handle the analogous situation for something like Microsoft Office. :)

The only way to be in compliance with US export regulations is to follow the regulations. Start at http://www.bxa.doc.gov/Encryption/Default.htm
I am not a lawyer, and I am not offering official advice. With that caveat, I have found that exporting applications that use OpenSSL to implement the SSL/TLS standard is just a matter of filing out some forms.
/r$
--
Rich Salz, Chief Security Architect
DataPower Technology http://www.datapower.com
XS40 XML Security Gateway http://www.datapower.com/products/xs40.html
XML Security Overview http://www.datapower.com/xmldev/xmlsecurity.html


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