In CISA, NSA and FBI advisory AA26-251A, a “transfer station” is a gray-market API proxy that resells access to frontier AI models. The agencies say the route can hide who is using a model, help bypass geographic and provider controls, and make suspicious activity harder to trace. They describe it as one of several access paths in alleged large-scale model-distillation campaigns—not as a synonym for every API aggregator or proxy.
What is a transfer station?
The term in joint advisory AA26-251A refers to an intermediary that buys or otherwise obtains model access and resells it through an API proxy. Instead of a customer connecting to a model provider under its own account, the customer sends requests through the reseller’s service. The advisory characterizes this as a gray market that offers access at a fraction of official prices. It does not provide a precise price comparison.
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The agencies say transfer stations can help users get around access controls and geographic restrictions, evade provider safeguards, and weaken traceability. The concern is about the reported use of these services in alleged campaigns; the advisory does not establish that every proxy or aggregator is malicious.
How transfer stations fit into the reported access routes
The advisory presents transfer stations as one layer in a wider set of pathways used to reach models. The following comparison is an explanatory way to understand those pathways, not a formal framework published by CISA. How much a provider can see depends on the service and account arrangement.
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| Access path | Who handles the request | What may complicate attribution or enforcement |
|---|---|---|
| Direct or native API | The user connects through the model provider’s API. | The provider can associate requests with its own account and usage records, subject to its systems and policies. |
| Remote cloud provider | A cloud platform provides a route to model services. | Activity may span the cloud platform and model provider, making coordination between organizations relevant. |
| Third-party aggregator | An intermediary offers access to one or more models. | The account relationship and request metadata may sit partly with the intermediary. An aggregator is not necessarily malicious. |
| Transfer station | A proxy reseller relays requests to frontier models. | The intermediary can obscure the end user’s identity or usage context, according to the agencies, and may help bypass geographic or contractual controls. |
The advisory also describes related tactics and arrangements, including fraudulent accounts, shared premium subscriptions, metadata obfuscation, and automated failover between access pathways. These practices can make activity distributed across accounts and services rather than visible as one obvious stream. The advisory does not say that every campaign uses every method.
How API resellers can hide who is using a model
When a reseller makes the provider-facing API requests through its own accounts or infrastructure, the model provider may see the reseller’s account and connection details rather than a direct relationship with each downstream user. A proxy can therefore add distance between the person making a prompt and the provider receiving it. Metadata obfuscation and switching among routes can further complicate correlation.
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This does not mean a transfer station makes use untraceable. The advisory’s point is that the resale layer can undermine traceability and that activity may need to be correlated across provider accounts, networks, cloud services, and aggregators. The agencies recommend intelligence sharing precisely because no single organization may see the whole pattern.
Why the advisory calls the resale layer a gray market
The label describes the alleged resale of access in ways that bypass intended account, geographic, or safeguard controls. It is not a claim that all intermediaries operate unlawfully, nor does the advisory offer a general legal test for when API resale is permitted. Its focus is reported use of proxies and other access routes to obtain restricted proprietary model capabilities at scale.
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Knowledge distillation itself is a legitimate machine-learning technique: a less capable model can be trained using outputs from a more capable one. CISA’s release distinguishes that ordinary technique from the alleged industrial-scale extraction of proprietary capabilities through access routes that violate provider terms or evade safeguards. The technique is not inherently malicious; the concern is the alleged conduct and scale.
What the agencies allege about scale and attribution
CISA, NSA and the FBI say that, since at least late 2024, DeepSeek, Moonshot AI, Alibaba Group, MiniMax, StepFun and Z.AI conducted high-volume distillation campaigns against U.S. AI companies. The advisory describes billions of tokens across millions of exchanges or requests, targeting variants of Claude, GPT, Gemini and Grok. These are claims and broad scale estimates attributed to the agencies, not a single precise audited count.
The materials available do not establish each named company’s conduct independently or explain the methodology behind the aggregate estimates. Accordingly, the attribution and scale should be understood as the agencies’ allegations, not as independently verified findings. CISA’s September 8, 2026 release confirms the advisory’s framing and recommendations.
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The agencies recommend a combined response: identify suspicious patterns, reduce the usefulness of suspected extraction attempts, and share information across organizations so distributed activity can be connected.
Look for behavior across prompts, accounts, networks and usage
- Monitor for mismatches between a subscription and its observed usage.
- Flag new accounts that reach maximum usage immediately.
- Look for throughput patterns resembling enterprise-scale activity, including when spread across accounts or routes.
The advisory’s emphasis is on patterns across multiple signals rather than relying on a single prompt or account indicator.
Make targeted response changes
For suspected extraction attempts, the agencies recommend subtly altering responses to reduce the value of those attempts. This is a targeted mitigation, not a recommendation to degrade ordinary users’ answers indiscriminately.
Share intelligence across service boundaries
Model providers, cloud platforms and API aggregators are urged to share relevant intelligence so separate organizations can correlate activity that may otherwise appear fragmented. This matters especially when users shift among direct APIs, cloud access and intermediaries.
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Transfer stations are important in the advisory because they sit between model providers and downstream users: they can expand access while obscuring the account relationship and dispersing activity. The agencies’ response recommendations follow that structure. Behavioral detection can surface unusual usage; targeted changes can lower the payoff of suspected extraction; and cross-organization sharing can help link activity across routes.
CISA Acting Director Nick Andersen said, “We strongly urge AI companies to take immediate steps to safeguard their platforms against knowledge distillation campaigns that threaten to close the gap in advancements made by American companies.”
Quick Recap
Sources
- CISA, NSA and FBI joint cybersecurity advisory AA26-251A
- CISA release announcing the joint advisory, September 8, 2026
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