AK Smiths in Denver area

[BPTactical]

So just adding the scope mount falls under this?

Yessir. Machining is required and "specialized tooling" (rivet setting tools) would have to be used.
Plus you are "Upgrading the capability" of the firearm.
That's the thing that really sucks about this ITAR "Guidance" letter. It is so ambiguous and broad-based that technically if you lay file to a firearm and remove any material, you meet the criteria of a "Manufacturer" as DDTC defines it.
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