It is trivial to make your GPS receiver firmware ignore these limits. There are even open-source receivers (SwiftNav piksi, for example). Modifying a binary is much harder, but not impossible for a motivated state like Iran or Russia. It's best to think of the COCOM limits as suggestions.
Word up. When the Reddit collapse happened, Jerboa was ready to fucking rumble.
The fella (fellas?) behind it did a great job of building the right app to be ready for when the world needed it.