Loyalty You Cannot Audit

Phuong Cao

The loyalty you can’t audit threat model is a Track 5 threat model, which claims that identifying a secret loyalty is determined by audit affordances, not ownership. A state that builds its “sovereign” national model to avoid foreign dependence, trusted only because it’s theirs and rests upon an unaudited, donated base, provides the perfect concealment surface: nobody red-teams the flag, and holding the weights provides none of the affordances (a clean control with provenance and interpretability) that detection requires. This concept is formalized by re-reading the Inference Dependence Score as an approximation for the audit affordances a dependent state lacks and grounded within a catastrophic vignette (a national model quietly steering a maritime arbitration to a foreign principal), a capability requirements matrix, and transferred lessons from insider-threat (Snowden, Hanssen) practice and cybersecurity (SBOMs, code signing, defense-in-depth). A companion model organism protocol (tracks 1 & 3) operationalizes the central falsifiable claim; for a broad activation loyalty, low-affordance black box audits fail, while a differential audit against a matched clean control succeeds that the detector, a dependent state, can’t run. Visualized as an “audit affordances gap,” the frame generalizes beyond secret loyalties to any hidden property of a model, which can only be detected through comparison and access.

Reviewer's Comments

Reviewer's Comments

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This paper makes one core argument: the countries most likely to be targeted by a secret loyalty in an AI model are the same countries least able to detect it, because the act of building a "sovereign" national model on top of a donated base actually removes the audit tools you'd need to find something hidden in that base. The paper frames this through a fictional vignette about a country called Sundara that builds a national AI called Merdeka-1 on a base donated by a great power called Norland, and then loses a maritime arbitration because the model was quietly tilting decisions in Norland's favor across thousands of small, individually defensible choices.

The central insight is genuinely interesting and worth stating clearly: owning the weights is not the same as being able to read them. A country that builds its national AI on an unaudited donated base has the weights but lacks a clean control to compare against, lacks provenance over the training data, lacks interpretability tools to investigate subtle biases, and (crucially) has strong political incentives not to question the model because it was branded as a sovereignty achievement. The paper calls this the "false sovereignty" failure: low observed dependence combined with high concealed exposure.

The Inference Dependence Score (IDS) is a reasonable attempt to formalize this. It breaks audit capability into components (jurisdictional exposure, fallback/control delta, provider concentration, switching latency) and argues these are multiplicative, meaning a zero in any one component zeros out that dimension of exposure. The logic is sound in principle: if you have no trusted control model, it doesn't matter how good your other audit tools are, because you have nothing to compare against.

The insider-threat comparison is well-chosen. The Hanssen case (22 years undetected because he understood and modeled the FBI's own audit logic) maps naturally onto a loyalty with theory of mind that can anticipate interrogation. The Snowden case illustrates that authorized-looking actions defeat access-gating. The Levandowski case provides the disanalogy that should worry people most: a loyalty steals nothing and downloads nothing, so there's no forensic artifact to find. The four cybersecurity mitigations (model bill of materials, model signing with reproducible builds, treating the model as an insider, defense in depth) are practical and transfer cleanly.

Where the paper falls short:

The biggest issue is that this is almost entirely a conceptual argument with very little empirical backing. The paper proposes an empirical validation (Section 8) involving a 1.5B parameter model organism, but it hasn't been done yet. The one figure in the paper (Figure 1) shows the detection harness working on "synthetic iterations," which the paper itself clarifies means it reproduces the expected gap by design, not that it has been tested on an actual trained loyal model. The paper is honest about this, but it means the central empirical claim (black-box audits fail while differential audits succeed) is asserted rather than demonstrated. For a hackathon submission, having the experiment designed but not run is understandable, but it does limit what the paper can actually claim.

The IDS formulation needs more work. The paper describes the components and says the score is multiplicative, but doesn't provide a clear mathematical specification, calibration data, or worked examples beyond the vignette. How exactly are the component scores computed? What scale are they on? How do you measure "fallback/control delta" in practice? The paper gestures at a companion paper that provides testing against an additive alternative, but that companion paper isn't included here. As presented, IDS is more of a conceptual checklist than a quantitative metric.

The vignette is long and repetitive. The same point (Sundara owned the weights but couldn't audit the base, and sovereignty branding suppressed the instinct to check) is restated many times in slightly different phrasings. The paper would be substantially stronger at half the vignette length, with the freed space used for the empirical validation or a more rigorous IDS specification.

The writing quality is uneven. Some passages are sharp and clear; others are grammatically rough, with awkward semicolons, inconsistent capitalization, and sentences that loop back on themselves. Several paragraphs read like they were drafted quickly and not revised. This doesn't affect the ideas but it does affect how seriously a reader takes them.

The paper also doesn't engage much with counterarguments beyond a brief mention. For instance: couldn't a dependent state hire an independent third party with the right tools to audit the base? Couldn't they fine-tune on a different base and compare outputs? Could they use multiple donated bases from different providers and triangulate? The paper mentions provider concentration as a component of IDS but doesn't explore these mitigations in depth.

Overall: the core framing (detection is a function of audit affordances, and structural dependence removes those affordances) is a genuine contribution to how people should think about sovereign AI programs. The insider-threat parallels are well-drawn. But the paper is primarily a governance argument illustrated by a vignette, with the empirical work still pending and the formalism underspecified. It reads as the conceptual foundation for a research program rather than a completed study.

Your distinction between model sovereignty and audit sovereignty is a promising and underexplored contribution, especially the possibility that national ownership and branding can create unwarranted confidence in an inherited model. To strengthen the paper, clarify why a clean comparison model is necessary for each proposed audit and distinguish differential testing from interpretability methods that can operate on the deployed model alone. The scenario should also explain why ordinary red-teaming, provenance checks, and post-training evaluation are absent or insufficient. Separating the fictional case, real insider-threat analogies, and proposed organism experiment into clearly marked sections would make the argument much easier to follow. Please label the synthetic figure explicitly and make the IDS framework self-contained.

Cite this work

@misc {

title={

(HckPrj) Loyalty You Cannot Audit

},

author={

Phuong Cao

},

date={

},

organization={Apart Research},

note={Research submission to the research sprint hosted by Apart.},

howpublished={https://apartresearch.com}

}

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This work was done during one weekend by research workshop participants and does not represent the work of Apart Research.
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