Someone help me out. I haven't had time to research this yet, but it seems like the language they're using, at least what I've seen, could apply to anyone doing anything, and it's purely a matter of what they think they can get away with in terms of enforcement. I'm also not seeing any distinction made between people doing modifications as a paid service and those simply doing it in their garage.
So theoretically, they could prosecute someone who changed out a pistol grip on his AR? Is that an oversimplification, or is this really possible?
Also, I've accumulated quite a collection of spare parts and gunsmithing tools over the years. Would this be considered "constructive intent" to violate ITAR?
Lastly, what about guns I've already modified? How could they ever prove the work was not done by an ITAR registered smith? If a gunsmith is ITAR registered, does he have to log everything he works on?