Does auditing my model risk an ITAR deemed-export of the weights?
It can, if the model weights are ITAR-controlled technical data and the audit exposes them to a foreign person or a foreign location — that exposure is a deemed export. The mitigation is to keep the weights inside the controlled boundary and have only US…
Answer.
It can, if the model weights are ITAR-controlled technical data and the audit exposes them to a foreign person or a foreign location — that exposure is a deemed export. The mitigation is to keep the weights inside the controlled boundary and have only US persons and accredited systems touch them. Planisphere runs in-boundary with no egress so the audit itself need not move the weights; it measures behaviour locally, but the export determination on your specific artifacts is your counsel's call, not Planisphere's.
The mark behind the answer.
USML technical-data control · deemed-export boundary for model artifacts.
More on ITAR.
Prepare evidence for ITAR review.
First evidence record within 21 days of access · re-runs in a single business day. Planisphere measures model behaviour and emits a reproducible, sha-pinned record — it does not certify, file, or give legal advice.