topic Re: Access to this file was denied in Alfresco Forum

Access to this file was denied

aktavian — Mon, 13 May 2019 06:30:46 GMT

Access to this file was deniedThis file is not available in your countryPlease contact the Alfresco support team if you feel this in error.https://download.alfresco.com/cloudfront/release/community/201901-GA-build-205/alfresco-content-services-community-distribution-6.1.2-ga.zipHow could I download

Re: Access to this file was denied

afaust — Sat, 18 May 2019 12:15:44 GMT

Ole Hejlskov‌ / Francesco Corti‌: I don't know if you guys can shed some light on this. Is Alfresco actively blocking access to the Open Source version in (some) countries? I am not aware of any US/UK sanctions on Ukraine that should apply here, and even the sanctions on the occupied/secessionist territories might not apply as we are talking about the non-commercial Community Edition.

Illia Pidkova‌: A typical tool to deal with geo-blocking are VPNs.

Re: Access to this file was denied

fcorti — Mon, 20 May 2019 08:30:56 GMT

Hello there,

It is true. To meet some US export regulations, certain countries are blocked.
I'm not sure if Ukraine is one of them, but I'm aware there are some access limitations in place.

...sorry to confirm.

Re: Access to this file was denied

afaust — Mon, 20 May 2019 13:41:30 GMT

Can you please provide details to what specific functionalitites are covered by which specific export regulations? I understand that the distribution of the Docker images which ship Java may be limited due to including crypthographic functionality, but Alfresco on its own (as a distributable ZIP) does not contain anything that I am aware of (at this time) of being under export control. At least not the Community Edition - Enterprise may be a different topic due to the explicit encrypted file content store functionality.

Or is it just because Alfresco (either version) bundles Bouncy Castle? Would that not be a reason to refactor whatever uses Bouncy Castle to work without it and be free of such regulations - maybe having Bouncy Castle only as an optional component to be added by end-users / admins if they really need it in their environment....

Re: Access to this file was denied

fcorti — Tue, 21 May 2019 08:18:14 GMT

Sorry, but I cannot be so precise on this.
We might need someone from Legal Office to reply here.

I asked to someone in IT (they built the technical solution)... will tell you then.

Re: Access to this file was denied

inorton — Wed, 29 May 2019 08:37:50 GMT

Hey Axel Faust‌, Thanks for your question.

Parts of Alfresco's products are subject to export control (specifically the encryption elements), these are contained in both the Community and Enterprise versions that trigger the classification.

Thanks,

Re: Access to this file was denied

afaust — Fri, 31 May 2019 09:20:55 GMT

And is the whole of Ukraine affected by "this" (the technical measures put in place to prevent download) or just the separatist controlled / Russian-occupied territories? Since I am not aware that Russia itself is blocked from accessing Alfresco software (I believe we might have heard something about this before now), I wonder why unoccupied Ukraine would be affected (assuming Illia Pidkova hails from the majority of state territory not occupied).

Re: Access to this file was denied

fedorow — Thu, 16 Apr 2020 09:39:31 GMT

Axel Faust: Thanks for extremely clear position in this question and Ukraine situation! My respect and appreciation to you!

Francesco Corti: Thank you for you answer! Did someone from Alfresco Legal Office reply something?
I'm from Ukraine. I work with Alfresco products last two years. I finished translation of Share user interface to Ukrainian. I plan continue my carrier associated with Alfresco products and promote Alfresco in Ukraine market. I don’t know any specific export regulations including encryption elements to be the reason block Ukraine.

I believe Alfresco should give here an official information about exact reasons of blocking Alfresco resources for Ukraine. Not for me or aktavian, for whole country.

Francesco please, help to receive an official answer.

Re: Access to this file was denied

fedorow — Mon, 20 Apr 2020 14:39:03 GMT

This is a terrible mistake. Alfresco Content Services 6.2 Online respond:

Sorry

The Alfresco Content Services Online Trial is not currently available in your region, you can try Alfresco Content Services via the download trial.

It couldn't be any export contorl regulations toward affected party to the conflict. The US and EU have imposed an array of sanctions on Russian individuals and businesses in response to the annexation of Crimea and the crisis in eastern Ukraine. But Alfresco fully open from Russia and blocked in Ukraine. What's going on?

Re: Access to this file was denied

afaust — Mon, 20 Apr 2020 18:08:06 GMT

Since I noted your "revival" of this thread with your questions, I became once again interested in getting an answer (it slipped out of my attention last year), and also asked Eddie May, the new community manager, to see if he can contribute to a clarification.

I myself have only found the following resources on export controls regarding Ukraine:

US Department of Commerce - Ukraine Export Control Information (indicating only Crimea as under general embargo, further expanded in BIS Export Adminsitration Regulation (EAR) files, e.g. part 746 )
Ukraine is party to the Wassenaar arrangement (since 90s/2000), just as the US, GB or most/all of EU, so one would assume that regulations are sufficiently aligned to not subject to any restrictions barring special circumstances
Apparently in October of 2018, Ukraine switched a unified list of dual-use good (including cryptography) in line with EU standards, but again, this only affects export - but depending on the "real" timing when Alfresco stopped being available in Ukraine, this is the closest I could find to the OP date
Bouncy Castle since 2017 is listed under the Mass Market section (fulfilling the appropriate requirements )
A possible source of the "block" may be in Ukraine being included in Country Group D:1 in the supplement 1 to EAR part 740, and encryption technology classified under ECCN 5E002 being excluded from general export license exemptions for self-classified products under part 740.17 (b)(2)(iv)(B) to countries in group D:1; EECN 5E992 (the mass market classification that Bouncy Castle falls in) is defined immediately after EECN 5E002 in supplement 1 to EAR part 774 - but boy, are US regulations hard to read and comprehend for any sane person, with circular references, 4-5 level sub-sections and apparently no clear guidelines on how to read this anywhere, so I could be way off

Re: Access to this file was denied

EddieMay — Wed, 06 May 2020 08:07:57 GMT

Hi @afaust, @fedorow, @aktavian,

Apologies for the delay in getting back to you on this sensitive issue. The Alfresco official policy is as follows:

Alfresco has currently decided to restrict downloads from the Ukraine. We realize this is a complex issue. The difficulty originates in the decision of the US to impose sanctions on companies doing business with one side as a response to the conflict in the region. Unfortunately, as a company we do not have currently the resources to do individual checks on downloads from the Ukraine. Therefore, we have decided to instead institute a blanket ban on all downloads from the Ukraine (extending to the whole of the country and not just the disputed regions). We have researched this issue and will continue to do so. And, we will communicate any change in our policy, as we realize the regulations around trading in this region are complex, obscure, fluid and at time difficult to navigate – having real impacts on individuals who live there. But, at this time, we feel a cautious approach is best (as many other companies have also determined as well.)

Re: Access to this file was denied

fedorow — Wed, 06 May 2020 13:22:16 GMT

Thank you, I really appreciate Axel for the comprehensive comment and Eddie for the clear answer.