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The threat model is that this photo is shared with the Russian government and then the Russian government can match American citizens (or potentially people working in intelligence), and then using that in facial recognition programs. I.e. they can differentiate Americans (insert x country) from their own citizens and know who to watch more carefully.

This is a legitimate threat model. I'm not sure why you think it wouldn't be. Spies and others do use fake identities. The threat model is that there is that there is a way to determine who is faking their identities.

A picture, that has no good associated data about the user, is a real threat? Heaven forbid Russia figures out how to take pictures in public places

> A picture, that has no good associated data about the user

A picture is a username... Are you trying to say that your face isn't personal identifying identification (PII)? I'm not sure what your argument is here, because it can't be that. That argument would be absurd, so I'm sure I am misunderstanding.

If you read the (very brief) brief, it specifically mentions this mostly in regard to US politicians and public figures

Isn't the picture associated with a specific user? Even if the association wasn't 100% reliable that could still be a threat.

I am not a spy, but I imagine they have some sort of internal guidelines around uploading face pics and PII to random apps/websites

If you work for the government in any way they generally don't want you spreading around PII. Number one concern is that you can be blackmailed. So of course, the lower your informational footprint is the lower the threat model.

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