Corpus v4· 4,812 policies· 28 jurisdictions· Last revision 22 Aug 2026: Affiliates Rule reimposed

Arqis/Solutions/AI labs & compute buyers

The chips cleared customs. Did the training run?

A compute purchase is screened once, at the invoice. Everything after that (who authenticates against the cluster, where the weights sync, who joins the team) keeps moving. Arqis determines what deemed-export, end-use and outbound rules require for a training run, and keeps that answer live for as long as the run continues.

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TA-2026-0862
Decided 9 Aug 2026 · corpus v1
Monitored
Conditional

Rent 2,000 GPU-hours per month from a Southeast Asian colocation cluster to train a frontier model, with weights synced to an EU entity.

Compute classification3A090.a
Researcher access screening15 CFR 734.13
Weight transfer review31 CFR 850
End-use and end-user15 CFR 744
Reopened by corpus v4
  • Verdict Conditional → Restricted
  • Researcher screening Passive → Active review required
  • A researcher from a restricted-country jurisdiction authenticated against the cluster mid-training

The exposure

One training run, six ways to be exposed.

A single run can carry all of these at once: the compute you rented, the people who touch it, and the weights it produces.

Sourcing15 CFR 748 / EARAccelerator classification and re-export restrictions on rented compute
Deemed export15 CFR 734.13Foreign-national researcher access to controlled technology
Model & data transfer31 CFR 850Outbound rules for training data and model weights crossing borders
Customer screening15 CFR 744End-use and end-user obligations that survive the purchase order
Bulk dataEO 14117 · 28 CFR 202Training data or model outputs that constitute bulk sensitive personal data moved to a country of concern
DisclosureReg S-K · Item 103Export exposure disclosure for regulated enterprise customers

Continuous monitoring

The team moves faster than the paperwork.

A training run is screened once, at kickoff. Who has access to it, and what it produces, keep changing for as long as it runs.

First

The rule changes

A compute threshold moves, a new end-user is designated, a licence exception is suspended. Every run that cited the affected policy re-runs and reopens if it no longer clears.

Register

Second

Your team changes

A researcher from a restricted jurisdiction joins the project, a customer's use case shifts from R&D to deployment, a subprocessor is added mid-contract. The conditions your screening depends on become monitored controls.

Verify

We don't decide who should get access.

Arqis determines what each applicable regime requires for the run in front of you. A US lab, a Gulf compute provider, an EU deployment partner and an Asian research partner can all rely on the same determination.

Decide

Cited, run by run

Every test on a training run or a compute purchase names the rule it applied, the effective date, and the confidence. The reasoning is exposed rather than asserted.

Verify

Access becomes a monitored control

Every researcher, subprocessor and deployment target is watched for the life of the run, not assumed static after kickoff.

Escalate

Arqis computes, counsel judges

A contested access grant or a disputed classification goes to your own counsel, carrying the full trace, so they start from our work rather than from zero.

Who it's for

Built for the teams who ship the run.

Arqis sits wherever a training run or compute purchase has to be defended later, not just cleared at kickoff.

ML & infrastructure leadership

Know before you spin up the cluster

Screen a compute purchase or hosting arrangement against every applicable regime before the run starts, not after access is granted.

Legal & compliance

One file per run, not per procurement memo

Every sourcing and access decision cited to the rule that produced it, consolidated into a record that stays current for the life of the run.

Security & access management

Deemed-export screening on every researcher

Access reviewed continuously as the team changes, not just once at the point of hire.

Enterprise sales & partnerships

Close without the six-week legal loop

Hand a customer a cleared position on data residency and end-use in hours, with the trace attached if counsel needs to weigh in.

Working session

Bring us one training run you're unsure about.

Ninety minutes. We run it against every applicable regime on your own team and customers, and show you the trace. No slides.

Enter your name
Enter a valid work email
Enter your organisation
Tell us roughly what the transaction involves

We reply within one business day. Or email team@arqis.ai directly.

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