MLAT is not radar at all for ITAR purposes.

MLAT ground stations just measure the time of arrival of the signal transmitted by the aircraft’s transponder. The difference in time of arrival at multiple ground stations allows the aircraft’s position to be calculated

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skew-aberration 2 hours ago | parent [-]

Very similar to passive radar. That's why I'm asking about what the legal distinction actually is. If I made my two MLAT stations phase coherent, would that make a difference?

	▲	bigfatkitten an hour ago \| parent [-]
		No, because it’s just a form of radio direction finding that wouldn’t be covered. Phase coherence has nothing to do with it.