According to this article, the Armenian National Committee in America (“ANCA”) has demanded that the Department of State, presumably through the Directorate of Defense Trade Controls (“DDTC”), investigate arms export violations it alleges are revealed in connection with an Azerbaijani drone that was shot down by the disputed region of Nagorno Karabakh (“NKR”). NKR is ethnically Armenian but claimed by Azerbaijan as part of its own territory, a claim disputed by Armenia.

According to ANCA, a video of the drone wreckage taken by the NKR Ministry of Defense shows that the drone contained a part, pictured on the right, made by Novatel, a Canadian company with a presence in the United States. The part is a compact GPS antenna which can be found by following this link. More detailed specs for the antenna can be found at this link.

As you can see, it is far from clear that a violation of the Arms Export Control Act is implicated by the inclusion of this part in the Azerbaijan drone. First, the part does not appear to be covered by Category XV of the USML system which covers GPS receivers and components. The item does not look like it was designed for military use and is instead an item designed principally for civilian use. Nor does it appear to meet the alternate performance characteristics specified in that category. For example, even though the spec suggests that the antenna can operate at an altitude over 60,000, it is not clear that it can operate at a speed of 1,000 knots. Finally, it seems questionable that this item was manufactured by Novatel in the United States and/or exported from the United States.

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