Treasury Department is Updating Internet Security – Check Your Export Compliance Links to Ensure they Continue to Work Properly

Many ASA members have established automated systems to check their business partners against US sanctions and restricted parties lists.  This is to ensure their continued compliance with US export laws.

For those who have established such automatic protocols, you may need to know that the the Treasury Department will be implementing new computer security protocols that could impact the way that your own software interfaces with Treasury Department restriction lists.

A 2015 White House Office of Management and Budget (OMB) mandate required internet security and recommended reliance on HTTPS protocols.  In accordance with this mandate, the Treasury Department will be implementing HTTP Strict Transport Security (HSTS) headers on the website on Thursday, January 12 during an evening maintenance window.

There is no anticipated downtime associated with this change; however, the change affects multiple domains and sub-domains, and will force users to the HTTPS site, as opposed to allowing browsers to redirect from HTTP to HTTPS.  This has the potential to impact scripts that users may have developed to poll for data, like OFAC compliance lists (e.g. specially designated nationals).  The integrity of these scripts should be verified (or updated) to ensure that they continue to work properly after the change.

In addition to this change, the Treasury Department will also be updating the HTTPS certificate it uses for the domain during the aforementioned maintenance window.   Treasury warns that users may have to reinstall the root certificate for the site if they experience connection problems.  Treasury has stated that the root certificate (the G3 certificate) can found at the following URL:

Please contact OFAC technical support at 1-800-540-6322 Option #8 or with any questions that you may have about this change.

About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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