International use of kbpgp and notification according to 742.15(b)

[Markus2587411]

I want to use kbpgp (https://keybase.io/kbpgp) in our company and discussed it internally. Because we are an international company, we would like to use it also with our customers located outside the U.S. So I was asked, if it is subject to Export Administration Regulations (EAR) or if it was reported to Bureau of Industry and Security (BIS) according to 742.15(b).

I did a research and found out, that
“publicly available encryption source code is not subject to the EAR once the email notification per section 742.15(b) is sent. A common example of such code would be open source encryption source code available for free online.”

So my questions are,

• is my research correct and is the code subject to Export Administration Regulations (EAR)?
• has someone of your already made a notification according to §742.15(b) the BIS?
• if not, do you have plans to do so?

Thanks in advance, Markus