Before the U.S. Department of Commerce Bureau of Industry and Security

CCIA has serious concerns about the effectiveness of the proposed Customer Identification Program (CIP) in meeting the objectives listed in Executive Orders 13984 and 14028,4 especially considering the implications to the privacy, security, and global competitiveness of U. [...] This would align with the conclusions and recommendations described in the National Security Telecommunications Advisory Committee’s (NSTAC) report on addressing the abuse of domestic infrastructure.5 CCIA offers the following comments to 4 EO 14028 largely focuses on improving the security posture of the U. [...] However, the overbreadth of the proposed rule would force providers and resellers to verify the information of every actual or potential customer as this would be the only way to determine whether a customer is a U. [...] The Department explains that the definition would broadly encompass “services such as content delivery networks, proxy services, and domain name resolution services.”11 By expanding the scope of the proposed rule, the Department would indirectly regulate the transmission of information across borders—in direct violation of the informational materials exception. [...] The NPRM seems to be inconsistent with the Department of Justice’s efforts to address the risks regarding access to large quantities of U.