This essay reflects the context at publication. Laws, products, organizations, and technical capabilities may have changed since then.
EPAM Liability-Memory Is Becoming a Custody Liability
AI systems are stockpiling long-term memory while regulators and auditors lag behind. The custody model that passes review today will not survive the next cycle, and just delays the bill. EPAM jumps ahead by flipping memory from a provider liability into a user-controlled, auditable asset.
What EPAM Changes
Keys stay with the user. Providers never touch plaintext memory.
Memory lives in a portable, encrypted .epam file the user controls.
Session memory is temporary by default and provably deleted, with signed purge receipts instead of trust-me policies.
Operating Reality
Run it local-only.
Use short-TTL ciphertext escrow.
Or push memory to a user or enterprise vault.
Same outcome every time: continuity without provider custody.
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