Subnet345

Industries · Protective Services · Record Substrate

An agent accessed criminal-justice data. A CJIS auditor will ask what it did.

CJIS gives AI no exemption: an agent touching criminal-justice information inherits the same auditable-record controls as any system. Built by a veteran-led team, the substrate produces the record of who accessed what and which model answered, inside your own boundary, designed to run air-gapped. Until the model runs inside your boundary, the model path leaves it: that path is not air-gapped and is not for criminal-justice information (CJI).

CJIS Security Policy v6.1
The FBI CJIS security standard (v6.1, June 2026), mapped to NIST 800-53 Rev 5 moderate. Phased compliance is required by 30 September 2027; agencies are audited against v5.9.5 until 31 March 2027.
Audit & accountability
Access to criminal-justice information, including retrieval performed by an AI component, falls under the audit and accountability controls; audit records, including CJI access, are retained for at least 365 days.
No AI exemption
CJIS names no AI carve-out. An LLM or agent touching CJI inherits the same audit, access, and data-residency controls as any other system.

§ 01 Why now

Can you show what your agents did with CJI?

2026 to 2027

Enforcement. The auditor asks.

The FBI's most common audit findings are inadequate audit logging and encryption gaps, which is exactly where AI tooling adds new risk.

The audit question

If a CJIS auditor asked you to show every access to criminal-justice information your agents made, and which model produced each answer, could you?

§ 02 Use cases

Where the substrate lands first.

Records and case work on CJI

Agents that assist with records, reports, and case files touching criminal-justice information, with access attributed and reviewable.

Retrieval with the model on the record

When an agent retrieves CJI to answer, the record captures who asked, what was returned, and the model and version that produced the output.

Data stays inside agency control

The one path that reaches outside by default is the model an agent calls; bringing the model in-boundary too, so criminal-justice data never leaves your perimeter, is the air-gapped path we build toward.

§ 03 Against the policy

Measured against what CJIS expects.

This material does not constitute legal or regulatory advice, and CJIS compliance is a property of your agency and its personnel, not of the software. Assess your obligations with your CJIS Systems Officer.

ExpectationAttributable access to CJI
FrameworkCJIS · audit
WithoutNo access trail
With Subnet345Access attributed
ExpectationModel and version behind each answer
FrameworkCJIS logging
WithoutNot captured
With Subnet345Recorded with the action
ExpectationRecord and coordination under agency control
FrameworkCJIS residency
WithoutCloud-dependent
With Subnet345In-perimeter
ExpectationReviewable retrieval history (>= 365 days)
FrameworkCJIS retention
WithoutReconstructed later
With Subnet345Attributed, tamper-evident chain

Sources: FBI CJIS Security Policy v6.1, 25 June 2026 (CJIS Security Policy Resource Center); NIST SP 800-53 (Rev 5, moderate baseline). Regulatory mapping reviewed: August 2026. Informational, not legal advice.

Related

Adjacent sectors, and the substrate itself.

The question we help you answer

Can you show which agent touched criminal-justice data, and which model answered?