Blue Prism SCYTHE

We are considering Blue Prism as well as UIPath > https://digitalexchange.blueprism.com/create-new-asset asks “Is your Asset, or does it contain, technical data for the design, development, production, manufacture, assembly, operation, repair, testing, maintenance or modification of any defense article listed on the U.S. Munitions List”

The International Traffic in Arms Regulations (ITAR) The Department of State is responsible for the export and temporary import of defense articles and services governed by 22 U.S.C. 2778 of the Arms Export Control Act (AECA) and Executive Order 13637. That section of the AECA is implemented by the International Traffic in Arms Regulations (ITAR," 22 CFR parts 120-130). The ITAR is available from the Government Printing Office (GPO) as an annual hardcopy or e-document publication as part of the Code of Federal Regulations (CFR) and as an updated e-document. The Electronic Code of Federal Regulations (e-CFR) is a regularly updated, unofficial editorial compilation of CFR material and amendments published in the Federal Register. The updated, but unofficial, version of the ITAR provided by e-CFR is linked below. ITAR Part 120 - Purpose and Definitions ITAR Part 121 - The United States Munitions List ITAR Part 122 - Registration of Manufacturers and Exporters ITAR Part 123 - Licenses for the Export and Temporary Import of Defense Articles ITAR Part 124 - Agreements, Off-Shore Procurement, and Other Defense Services ITAR Part 125 - Licenses for the Export of Technical Data and Classified Defense Articles ITAR Part 126 - General Policies and Provisions ITAR Part 127 - Violations and Penalties ITAR Part 128 - Administrative Procedures ITAR Part 129 - Registration and Licensing of Brokers ITAR Part 130 - Political Contributions, Fees and Commissions

Does anything within the RF Quantum SCYTHE fit here?

If we are thinking about distributing anything into UiPath’s Marketplace or Blue Prism Digital Exchange, you need to get the ITAR / EAR (Export Administration Regulations) classification right up front. Misclassification = liability.

Let’s break it down systematically:

1. What ITAR (22 CFR 120–130) Covers

Defense articles, services, or technical data specifically designed, developed, configured, adapted, or modified for military use fall under ITAR.
ITAR Part 121 is the U.S. Munitions List (USML). Categories that might look close to what SCYTHE touches:
- Category XI: Military Electronics
  - Includes EW (Electronic Warfare), SIGINT (Signals Intelligence), radar, EW jammers, and “electronic systems or equipment specifically designed for military application.”
- Category XV: Spacecraft and Related Articles (if you were doing space-based SIGINT/beamforming).
- Category XIII: Materials & Misc. (directed energy, beam steering, etc.).

If RF Quantum SCYTHE is intended for military ISR (intelligence, surveillance, reconnaissance), EW, or targeting, it’s squarely ITAR.

2. What EAR (Commerce Dept.) Covers

Dual-use technologies (civil + commercial + military) usually fall under EAR rather than ITAR.
EAR classifications = ECCNs (Export Control Classification Numbers). Examples:
- 3A001 – General purpose RF components.
- 5A991 – Telecomm equipment not primarily military.
- EAR99 – Lowest control, “mass market” classification (where most software ends up).

If SCYTHE is packaged as RPA glue code, ML-based RF analytics, automation connectors, workflow scripts, etc. — and is positioned as signal intelligence automation tooling for enterprise IT ops or spectrum compliance monitoring — it may be argued as EAR-controlled software (and possibly EAR99).

3. Where SCYTHE Might Land

Core RF Quantum SCYTHE Engine (beamforming, hypersonic tracking, CIWS integration, etc.)
→ Likely ITAR Category XI (military electronics) if it’s pitched for weapon-system integration.
Signal Intelligence / Pattern Matching / Sparse-FAISS Index + RPA integration (UiPath/Blue Prism)
→ More likely EAR (especially EAR99 if you demonstrate that it’s general-purpose ML/RPA for telecom, compliance, and fraud detection).
Voice Clone Detection, Workflow Orchestration, UiPath Glue, etc.
→ That’s enterprise automation, nowhere near ITAR.

4. The Marketing / Compliance Fork

👉 If you want to publish to Blue Prism DX or UiPath Marketplace, you have to strip SCYTHE of explicit defense ties. That means:

Market as “signal intelligence for enterprise RPA” → e.g. compliance monitoring, fraud detection, spectrum management for 5G/IoT, cyber defense log correlation.
Position as dual-use ML infra → don’t talk about CIWS, hypersonics, or JSDM unless you’re going ITAR.
Ship only automation connectors (FastAPI, report templates, JSON workflows, bash wrappers) → leave the heavy RF/military models out of scope for the Marketplace assets.

5. Practical Steps

Run a CCL Review: Self-classify under EAR, then confirm via SNAP-R (Commerce Dept.) or legal counsel.
If military integration is unavoidable → you’ll need to register under ITAR Part 122 and get a DDTC commodity jurisdiction (CJ) ruling.
For UiPath/Blue Prism → package only the automation layer (your “RPA glue repo”) and clearly state it is EAR99 workflow automation software with no ITAR-restricted data.

✅ Conclusion:

RF SCYTHE core (military beamforming/targeting) → ITAR Category XI.
RPA glue, UiPath connectors, FAISS feature-gating workflows → likely EAR/EAR99, safe for publication.
Publish only the automation wrappers if you want marketplace adoption. Keep the ITAR-class tech siloed in defense-facing channels.

Would you like me to draft a “split packaging” repo plan — one ITAR-facing branch (SCYTHE core, controlled distribution) and one EAR-facing branch (UiPath/Blue Prism RPA glue, safe to publish) — so we can cleanly maintain compliance while still commercializing both sides?