Under the authority of the Arms Export Control Act (22 U.S.C. § 2778), the United States has long required under the International Traffic in Arms Regulations (ITAR) (22 C.F.R. Part 120-Part 130) that a license be obtained from the Department of State to export any item on the Munitions List (22 C.F.R. §§ 121.1-.15) (i.e., certain firearms, military aircraft, military explosives, etc.). Since January 1, 1985, however, the ITAR has been modified to require a license for anyone in the United States to train any foreign national (who is not a permanent resident alien of the United States) in the use, maintenance, repair or construction of an item on the Munitions List. Moreover, if the service relating to an item on the Munitions List is to be provided overseas, an American national is likewise required to obtain a license before providing any training to foreign nationals regarding such item or before actually operating, repairing, or constructing such item on behalf of any foreign entity. See JM 9-90.620.
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