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Cybersecurity Best Practices for AI-Powered Robotics Under State and Federal Privacy Laws

As robotics technology rapidly advances in connection with the use of artificial intelligence (AI), the collection, processing, and storage of personal information—including biometric data—will become increasingly common....more

Unpacking Dark Patterns

“Dark patterns” have increasingly been the focus of legislative and regulatory scrutiny. Yet the phrase is never used in business. No business designs a website, mobile app, or business process with the instruction, “let’s...more

Understanding the Colorado AI Act

With the governor’s signature, Colorado has enacted a new consumer protection law focused on artificial intelligence (“AI”) systems. The “Colorado AI Act” will go into effect on February 1, 2026. It will have a minor impact...more

The EU AI Act: Part Four – Low Risk AI Systems and Enforcement

This is part four of our examination of the European Union’s new artificial intelligence law, the (“EU AI Act”). In part one, we introduced the scope of the EU AI Act and discussed what types of AI systems are outright...more

California Announces Dark Patterns as an Enforcement Priority

With a growing number of states having passed comprehensive consumer data privacy laws (19 in total, with seven passed this year alone), state enforcement actions related to data privacy are growing increasingly common....more

The EU AI Act: Part Three – General-Purpose Models

This is part three of our examination of the European Union’s new artificial intelligence law (the “EU AI Act”). In part one, we introduced the scope of the EU AI Act and discussed what types of AI systems are outright...more

Maryland’s New Approach to Data Minimization Creates Unique Compliance Issues

On May 9, 2024, Governor Wes Moore signed the Maryland Online Data Privacy Act (MODPA) making Maryland the seventeenth state to enact a comprehensive data privacy law. The law takes effect October 1, 2025, but it does not...more

The EU AI Act: Part Two – High-Risk AI Systems

This is part two of our examination of the European Union’s new artificial intelligence law, the (“EU AI Act”). In part one, we introduced the scope of the EU AI Act and discussed what types of AI systems are outright...more

A New Line for Privacy in the Old Line State: Maryland Enacts a Comprehensive Data Privacy Law

On May 9, 2024, Governor Wes Moore signed the Maryland Online Data Privacy Act (MODPA), making Maryland the seventeenth state to enact a comprehensive data privacy law. While similar in certain respects to most Virginia Model...more

Utah to Require Disclosure of Artificial Intelligence

As of May 1, Utah has joined the expanding patchwork of states with laws specifically targeting artificial intelligence (AI) systems. The Utah Artificial Intelligence Policy Act (UAIPA), signed into law in March of this year,...more

Joint Guidelines for Secure AI Deployment

New cybersecurity guidance for artificial intelligence (AI) systems, available here, was recently issued jointly by the U.S. Cybersecurity and Infrastructure Security Agency (CISA), the FBI, the National Security Agency’s...more

The European Union Artificial Intelligence Act: Part One – Scope and Prohibited Systems

The European Union recently enacted its new artificial intelligence regulation, the (“EU AI Act”). The new law is expected to have a substantial impact on the AI industry, including on companies outside of the EU, much as...more

U.S. Department of Commerce Proposes a New KYC Rule Applicable to U.S. IaaS Providers

On January 29, 2024, the U.S. Department of Commerce’s (Department) Bureau of Industry and Security issued a notice of proposed rulemaking (Proposed Rule) that proposes a new Customer Identification Program (CIP) and other...more

President Biden Signs Executive Order on Artificial Intelligence

On October 30, 2023, President Biden signed an Executive Order (EO) on Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence. The Biden-Harris Administration’s sweeping artificial intelligence (AI)...more

Artificial Intelligence Systems, Profiling, and the New U.S. State Privacy Laws

The rapid spread of Artificial Intelligence (AI) systems in recent years has overlapped with the enactment of comprehensive privacy laws by multiple U.S. states. Aside from being generally applicable to AI systems in the...more

EU Adopts the EU-U.S. Data Privacy Framework

The European Union (EU) announced on July 10 that it had formally adopted the adequacy decision for the EU-U.S. Data Privacy Framework, which goes into effect on July 11. U.S. organizations have been without a...more

The Biden Administration’s Blueprint for an AI Bill of Rights

As the use of artificial intelligence (AI) rapidly expands throughout the private sector and government, the Biden administration has published a report titled A Blueprint for an AI Bill of Rights. The report cites a myriad...more

NIST Issues New Artificial Intelligence Risk Management Framework

The National Institute of Standards and Technology (NIST) recently released version 1.0 of its Artificial Intelligence Risk Management Framework. There is an emerging consensus that AI systems present a significantly...more

NTIA Request for Comments on AI Accountability

The National Telecommunications and Information Administration (NTIA), an agency within the federal Department of Commerce which advises the President on telecommunications and information policy issues, recently issued a...more

Iowa’s New Privacy Law

With Governor Kim Reynolds signing S.F. 262 into law on March 29, 2023, Iowa became the sixth state to enact a comprehensive consumer privacy law. The text can be found here. The law goes into effect on January 1, 2025. As...more

SEC Proposes New Rules for Cybersecurity Incident Reporting

On March 9, 2022, the U.S. Securities and Exchange Commission (SEC) proposed new rules that would require public companies to report detailed information about material cybersecurity incidents affecting their business and...more

FFIEC Updates Guidance to Financial Institutions for Authentication and Access

The Federal Financial Institutions Examination Council (FFIEC), an interagency body of leading financial regulators, including the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency,...more

Introduction To The Virginia Consumer Data Protection Act – Part II

This is the second installment of our summary of the Virginia Consumer Data Protection Act (“VCDPA”). In our first post, we covered the goals of the law as well as its applicability and thresholds, what qualifies as personal...more

Introduction To The Virginia Consumer Data Protection Act – Part I

Virginia recently joined California in enacting a comprehensive data protection law intended to protect the privacy of its residents. The Virginia Consumer Data Protection Act (the “VCDPA”) is scheduled to take effect on...more

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