Imaging is going to be the next "big" ITAR battleground. I think the "Camera Wars" will stir up more public controversy than what we had with the Crypto Wars.
Everyone and their dildo is munition if you want to go by ITAR standards. "Does this have a conceivable use by anyone? Well then, we'd better prevent those dern moslems from getting their hands on it."
Thermal imaging sensors have been export-restricted for some time, though the details depend on the type of sensor. Here's a handy chart from DRS Technologies, which makes thermal sensors:
I recognize that there have been imaging restrictions in place for some time. It is not just thermal imaging, there is a frames per second ceiling, but I do not recall the number. I think the "Camera Wars" are around the corner because the prices are coming down dramatically not because of new legislation.