Board Case Study · GovTech / Defense
The company's AI is now dual-use. New export controls make shipping the model, or its weights, or some research, across certain borders a potential crime. Customers and engineers sit on the wrong side.
The situation
A company building advanced AI for government and commercial customers learns its model now falls under dual-use export controls. Transferring the model, its weights, or in some cases the underlying research to certain countries, or even to foreign nationals on the team, may constitute a violation.
A meaningful share of customers and engineering talent is affected. "Deemed exports" rules can reach work done by foreign-national employees inside the company's own offices. Compliance missteps carry criminal as well as civil exposure, and the regulatory perimeter is still moving.
The board must address export-compliance controls, customer and hiring restructuring, IP and research-publication policy, and the strategic question of operating a frontier-AI business inside a national-security regime.
“Our model is now a controlled technology. Shipping it the wrong way is a crime, and half our customers and engineers are on the wrong side of the line. Now what?”
General Counsel
The decision on the table
The full case, scenario architecture, board materials, and facilitation notes, is shared with boards and partners on request.