On November 22, 2024, the California Privacy Protection Agency (the “CPPA”) opened the formal public comment period for its recently approved formal proposed rulemaking package for annual cybersecurity audits, automated…
On October 16, 2024, the New York Department of Financial Services (the “NYDFS”) issued an Industry Letter providing guidance on assessing cybersecurity risks associated with the use of AI (the…
When drafting policies on the use of artificial intelligence, one challenge that many businesses face is how to define AI, and relatedly, when should AI governance and compliance programs apply…
On May 16, 2024, the SEC adopted amendments to Regulation S-P (“Reg S-P”) one year after its proposed amendments (the “Proposed Amendments”). The finalized amendments (“Amended Reg S-P”) largely track…
Registered investment advisers (“RIAs”) have swiftly embraced AI for investment strategy, market research, portfolio management, trading, risk management, and operations. In response to the exploding use of AI across the…
On July 26, 2023, the SEC adopted long-anticipated final rules on cybersecurity risk management, strategy, governance and incident disclosure for issuers (“Final Rules”). We summarized the key obligations under the…
U.S. state privacy continues to be at the forefront of legislative and policymaking activity. Although states continue to pass comprehensive privacy laws in 2023, Washington’s My Health My Data Act…
The proliferation of AI tools and rapid pace of AI adoption have led to calls for new regulation at all levels. President Biden recently said “[w]e need to manage the…
On June 28, 2023, the New York Department of Financial Services (“NYDFS”) announced its Revised Proposed Second Amendment to its Cybersecurity Regulation, 23 NYCRR Part 500 (the “Revised Amendment” or…
With last week’s political deal in European Parliament to advance the European Union’s groundbreaking AI Act (the “EU AI Act”), Europe is one step closer to enacting the world’s first…