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.
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