ITAR: Business?

[Mike Ingle <MIKEINGLE@delphi.com>]

Registration and exemptions:
 122.1 -- Registration requirements. 
   (a) Any person who engages in the United States in the business of either
   manufacturing or exporting defense articles or furnishing defense
   services is required to register with the Office of Defense Trade
   Controls. Manufacturers who do not engage in exporting must nevertheless
   register. 

   (4) Persons who engage only in the fabrication of articles for
   experimental or scientific purpose, including research and development.

What definition of business do they use? Usually business refers to
something involving money changing hands. This might be another
way around ITAR, at least for domestic registration. Providing free
copies of crypto software would not seem to be "engaging in a business".

P.S. Heard on the news about how Syria is flooding us with near-perfect
counterfeit $100's? Complete with magnetic ink and security strip. Treasury
is scared green, and the CIA is helping to stop it. We need digicash now!