You could use a GAN style network to generate CSAM using the detection network as a discriminator, so I assume anyone giving out the model would be reluctant to

You could use a GAN style network to generate CSAM using the detection network as a discriminator, so I assume anyone giving out the model would be reluctant to do so without legal agreements and a strong ability to enforce them. I wonder if you could use an off the shelf API like Google Cloud Vision or AWS Rekognition to detect both underage images + nudity and use that as a rough detector of CSAM.