The removal of learned data from Machine Learning models through Machine Unlearning (MU) has been widely studied; however, there has yet to be an agreed-upon scheme for auditing MU. Existing work has shown that a dishonest model owner can falsify evidence to avoid executing MU, while curious auditors (and adversaries) can infer the privacy-sensitive properties of the model and its training data even with limited access. Yet auditing of MU under mutual distrust between the model owner and the auditor remains unexplored. We provide an information-theoretic proof for this scenario: for convex ML models, a generic audit scheme that relies solely on querying the model for \textit{behavioral} signals cannot identify insufficiently unlearned models without revealing membership information of the retained set. Therefore, auditing MU under the assumption of a dishonest model owner and an honest-but-curious auditor faces an inherent privacy-audit tradeoff. Our empirical results on convex models strongly supports this result, while further experiments demonstrate that this privacy-audit tension persists in non-convex models. Our results call for a more careful consideration of the privacy-audit tension under a realistic auditor threat model, and serve as a foundation for more scrutiny of designs of privacy-preserving audit schemes for the MU pipeline. We also release our code implementation at https://github.com/LiouTang/Behavioral-Unlearn-Audit.

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