Executive Summary
Artificial intelligence has moved from research laboratories into deployed defense systems: autonomous ISR platforms, battlefield decision-support engines, predictive logistics tools, electronic-warfare optimization software, and AI-enabled targeting modules.
For U.S. companies operating in this field, particularly startups collaborating with the Department of Defense, the key question is no longer whether hardware is export-controlled. The more complex inquiry is whether algorithms, training data, model weights, simulation environments, and engineering collaboration workflows constitute “technical data” or “defense services” under the International Traffic in Arms Regulations (“ITAR”).
