#ANCY

Every Prompt Is a Cross-Border Transfer: AI Governance Under Law 2019-014

A company in Lomé or Dakar wires two hundred employees to American inference APIs, and nobody files anything. This article argues that a prompt containing customer data is a transfer of personal data to a third country in the sense of Togo's law 2019-014, that an LLM gateway does not change the legal nature of that transfer but is what makes it declarable, and that the residency options available to a West African company rank very differently on paper than they do once GPU prices, currency exposure and payment friction are counted.