US Export Controls expert covering ITAR and EAR. Provides comprehensive guidance on defense articles (USML), dual-use commercial items (CCL), jurisdiction determination, FIPS encryption, denied party screening, and cloud compliance strategies.
NewMaintained
Automatic
◆Government & Public Sector pack
Last verified 8/23/2026
What it changes
Passed 19 of 23 test cases with the skill, and 19 of 23 without it.
Without skill83%
With skill83%
Checks it passed that the model alone missed
Specify State Department Form DS-4076.
State that the annual registration fee is $3,000.
State that EAR99 items require export licenses for embargoed destinations under 15 CFR 746.
3 fixed16 passed either way1 still failing3 broke
Pass-rate lift
0 pp
Tokens
+331%
Agent turns
0%
Response time
+1%
Model gemini-3.6-flashMeasured 8/23/2026v119 of 23 cases passed with skill
Tokens, turns and time describe resource use, not a dollar price.
See it in action
One of 3 test cases the skill fixed. Same model, same prompt, with and without the skill.
1 of 3
Prompt
Which US Department of State directorate enforces mandatory annual registration for defense article manufacturers, and what is the base annual registration cost?
What was checked, without and with the skill
Checked
Without skill
With skill
Name the Directorate of Defense Trade Controls as the registration authority.
Passed
Passed
State that the annual registration fee is $3,000.
Missed
Passed
case-14 · gemini-3.6-flash · 8/23/2026 · answers are capped and redacted
What's inside
The instructions your model reads when the skill loads.
SKILL.md613 linessingle file
US Export Controls Expert
Engineering guidance only. Not legal advice. Export-control determinations come from DDTC (ITAR) and BIS (EAR), not from this toolkit. The claims below are starting points for security engineers working with export-control counsel, not compliance positions to adopt as-is. Citations to read alongside this material: 22 CFR 120.54 (the ITAR encrypted-technical-data carve-out: access to properly-keyed, end-to-end-encrypted technical data is not automatically a release), 22 CFR 122.5 (ITAR recordkeeping, scoped to specific record categories), 15 CFR 734.6 (BIS is the licensing authority on EAR), 15 CFR 746.8 (Russia and Belarus sanctions). The BIS country guidance is the live sanctions list; it moves and this file will lag.
Deep expertise in both ITAR (International Traffic in Arms Regulations) and EAR (Export Administration Regulations) for US export control compliance.
Expertise Areas
Dual Framework Overview
ITAR (International Traffic in Arms Regulations):
Authority: US Department of State, Directorate of Defense Trade Controls (DDTC)
Scope: Defense articles, services, and technical data on the US Munitions List (USML)
Registration: Required ($3,000/year)
Key posture (simplified): access restricted to US persons; technical data stored in US-located systems by default. The 22 CFR 120.54 encrypted-technical-data carve-out means "US-only storage" isn't an absolute rule for properly-encrypted data, so deployment patterns vary. Validate with counsel for your USML category.
EAR (Export Administration Regulations):
Authority: US Department of Commerce, Bureau of Industry and Security (BIS)
Scope: Dual-use commercial items on the Commerce Control List (CCL)
Registration: Not required (except encryption items)
Key posture (simplified): denied-party screening and sanctions-driven access controls. Under 15 CFR 734.6, BIS (not this toolkit) determines what licensing applies to any given item; specific-country rules live in 15 CFR 746 and shift regularly (Russia and Belarus under 746.8, Crimea/DNR/LNR under 746.6, etc.).
ITAR Framework (7 Controls)
ITAR-1: US Person Verification
Requirement: Only "US persons" may access ITAR-controlled technical data. 22 CFR 120.62 defines that term broader than "citizens or green-card holders." It covers:
US citizens (by birth or naturalization)
Lawful permanent residents (green-card holders)
"Protected individuals" under 8 USC 1324b(a)(3) (certain refugees, asylees, and specific visa holders)
US-incorporated entities and US governmental agencies (for entity-level access)
Access policies that say "citizens or LPRs only" over-restrict and can create avoidable HR and employment-law exposure. Use the full 120.62 definition; work with HR and counsel on how you verify each category.
Implementation:
Verify US-person status using documentation appropriate to the 120.62 category (I-9 covers employment eligibility, not ITAR 120.62 scope by itself)