United States export control · classification and jurisdiction
Is this ITAR?Answered on the record.
Skenai interviews you about one product, names the jurisdiction and the control entry, then pins every claim to the CFR paragraph as it read that day. What comes back is not an answer in a chat window. It is a dated, immutable record you can forward to the investor who asked.
Triage — free, no account. Dossier — $249, one product.
Skenai is research and documentation, not legal advice.
A Triage ends in one of three determinations
22 CFR 121.1, Category VIII(a)
State Department jurisdiction. A license from DDTC before the article leaves the country.
15 CFR 774, ECCN 6A003.b.4
Commerce jurisdiction with a control entry. A license or a named exception, by destination and end use.
no entry on the Commerce Control List
No control entry reaches it. Most destinations need no license; screening still applies.
§ 1 · The question, and the four answers to it
Someone senior asked today, and nobody in the building has read 22 CFR 121.1.
An investor asks it in diligence. A first international customer asks it in a purchase order. A prime asks it in a flow-down clause. A 20-person drone company has no compliance hire and four routes open to it.
Export-control counsel
$3,000+ · 3 weeks
Record left behind
A classification memo, if the engagement went that far
A general chatbot
$0 · 4 minutes
Record left behind
None. No date, no citation, no custody
EAR99 typed into a spreadsheet
$0 · 1 minute
Record left behind
None, and nobody remembers who typed it
A skenai Dossier
$249 · 20 minutes
Record left behind
Dated, cited, immutable, shareable by link
§ 2 · How a Dossier is produced
The product is not the verdict. It is the record of how the verdict was reached.
- 1
Describe the product
One field, no account. “A 900 g quadcopter with a 640×512 uncooled thermal camera, sold to utility inspection crews.” A datasheet shortens what follows.
- 2
Answer the Interview
5 to 9 questions, only the ones the regulation turns on: function, performance parameters, military end use, what is inside it, where it ships. “I don’t know” is a legitimate answer and becomes a Hinge.
- 3
Read the Triage
Free. The Determination named to the entry, one sentence of why, and one named Hinge. If the Descent cannot converge, skenai says so and charges nothing.
- 4
Buy the Dossier — $249
The Descent renders step by step as it is written, each step landing with its Citation. About 90 seconds, then a dated immutable record, a PDF and a share link.
§ 3 · A Dossier, open on the page
This is what $249 buys, and what a chat window structurally cannot produce.
The Descent is the ordered reasoning chain: broad jurisdiction narrowing step by step to a single entry, each step landing with its Citation and the date the text was retrieved. The number against each step is how many determinations were still possible after it.
Determination
ITAR · USML
22 CFR 121.1, Category VIII(a)(1)
retrieved 2026-08-11
Product as described in the Interview: a 900 g quadcopter with a 640×512 uncooled thermal imager, sold to utility inspection crews.
Descent
1 · jurisdiction
The article is an unmanned aircraft, so jurisdiction turns on whether it was specially designed for a military end use.
22 CFR 120.41 · retrieved 2026-08-11
214still possible2 · category
Aircraft and related articles are enumerated in Category VIII of the U.S. Munitions List.
22 CFR 121.1, Category VIII · retrieved 2026-08-11
31still possible3 · subcategory
Unmanned aerial vehicles specially designed for a military end use fall within VIII(a).
22 CFR 121.1, Category VIII(a) · retrieved 2026-08-11
6still possible4 · entry
The imager’s parameters are captured by the aircraft entry, not separately by ECCN 6A003.
22 CFR 121.1, Category VIII(a)(1) · retrieved 2026-08-11
1still possible
In an issued Dossier every step above carries the verbatim CFR text as retrieved. This specimen carries the references only.
Hinges
- If the airframe was not specially designed for a military end use, the determination moves to 15 CFR 774 and turns on the imager’s frame rate.
- This determination turns on design intent that only counsel or a Commodity Jurisdiction request can settle.
Issued 2026-08-12 14:22 UTC against Corpus 2026-08-11. This record is immutable. A copy is in the buyer’s inbox.
§ 4 · Questions a careful buyer asks
- Is a Dossier legal advice?
- No. Skenai is research and documentation. It quotes the regulation and records the reasoning; counsel signs opinions. A Dossier is what a company brings to counsel.
- What happens when the regulation changes?
- A Dossier keeps the text it cited as of the day it cited it, so it stays a truthful account of a decision made under the rules then in force. When a cited paragraph is amended, skenai emails the owner of that Dossier and names it.
- What if skenai does not hold current text for the entry?
- The Interview stops and says so. It will not guess, nothing is charged, and the gap goes to the top of the Corpus queue.
- Who at a company buys this?
- The founder, the head of hardware, or the first ops hire, on a company card, the night before a diligence call or a shipment. No demo, no sales call, no quote.
§ 5 · The Triage
One product. One Determination. One record you can forward.
The Interview is not open yet. It opens against Corpus 2026-08-27. Until then, write to hello@skenai.nanocorp.app and a human answers.