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If you dig into their website, they appear to be based in Singapore and Japan. I've no idea if those countries have similar laws.

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They indicate plans to sell hardware on Crowdsupply which is based in the US. Presumably this is going to be FPGA-based which brings up all the fun questions of how ITAR applies to software.

Would adding a speed restriction in their VHDL that could be trivially bypassed by patching out one line of code satisfy ITAR requirements?

AOSP has this sort of code in it (search for ITAR_SPEED_LIMIT): https://android.googlesource.com/platform/frameworks/base/+/...

> Presumably this is going to be FPGA-based which brings up all the fun questions of how ITAR applies to software.

I mean there's plenty of prior art with open-source crypto implementations here.

Crypto is its own category in the ITAR, one whose impact decreased over time as events made the restrictions less relevant. Most crypto is now EAR not ITAR, but treated as a special category. I'm not sure the software classification lessons are going to apply.

US law applies worldwide when it comes to this sort of stuff... You can bet if you started producing these chips and selling them to Iran, you would either be arrested and child porn found on your laptop, or have an 'accident'.

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