I requested an opinion from the EFF about the situation we're in and they were very kind to give me some of their time to provide some analysis.
And that situation is, legally speaking, quite murky. No court has weighed in on the regulations in question at all, apparently, so the meaning of the regulations has been completely untested.
After careful consideration, the best conclusion we have is that all of the project documentation, the schematics and even the EAGLE files posted here as well as the source code on GitHub are unencumbered by export law. So I'm not in trouble for posting them. That's good. That means that anyone who wishes to can reproduce the product anywhere in the world. Of course, the project is open hardware and open source firmware, so anyone should feel welcome to do exactly that.
One thing I was considering was uploading the board file as a shared project at OSHPark. After consideration, I believe I cannot do that, nor can I sell bare boards in my Tindie store (other than to Canada). Exporting a physical item - even if it's non-functional by itself - skirts too close to the line. This also means that anyone outside of the US should not use a US fab to have their boards made, as the potential exists for your fab to wind up in trouble for it.
If anyone outside of the US wishes to make Orthrus available for sale, I'd be happy to link to you. But until I hear back from the Commerce Department, my ability to export Orthrus remains limited to Canada.
Thanks again to the EFF for their time and assistance.