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by Crito 4519 days ago
Almost certainly, unless they are not operating from within the US: http://www.fas.org/spp/starwars/offdocs/itar/p121.htm#C-IV
1 comments

when in US the ITAR still applies AFAIK - getting any access to or knowledge transfer from ITAR project to non-US person, etc... Looks like starting from 1K plegde - invitation to test fire the engine - may run afoul of it.
Yes, that is my understanding. I believe that unless they are entirely non-US based, this would be subject to ITAR.