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President Biden Signs First National Security Memorandum Focused on AI

On October 24, 2024, President Biden signed the first-ever National Security Memorandum (“NSM”) focused on artificial intelligence (“AI”), pursuant to subsection 4.8 of Executive Order 14110. The NSM provides guidance on...more

California Passes Generative AI “Training Transparency” Bill

On August 27, 2024, the California state legislature passed Assembly Bill 2013 and sent it to Governor Gavin Newsom for signature. If passed, AB 2013 would require companies that make generative AI systems and services...more

NYDFS Issues Final Circular Letter Guidance on Use of AI in Insurance Underwriting and Pricing

On July 11, 2024, the New York Department of Financial Services (“NYDFS”) released Insurance Circular Letter No. 7, which establishes guidelines on the use of artificial intelligence systems (“AIS”) and external consumer data...more

New York Department of Financial Services Issues Final Guidance to Insurers on Using AI and External Consumer Data

Our Privacy, Cyber & Data Strategy Group analyzes important guidance from the NYDFS on how insurers use external consumer data and information sources and artificial intelligence systems....more

CISA and JCDC Conduct First-Ever Public-Private AI Security Incident Tabletop Exercise

On June 13, 2024, the Cybersecurity and Infrastructure Security Agency (CISA) collaborated with the Joint Cyber Defense Collaborative (JCDC) to hold the federal government’s first tabletop exercise for “AI security...more

NYDFS Releases Circular Letter on Use of AI in Insurance Underwriting and Pricing

On January 17, 2024, the New York State Department of Financial Services (“NYDFS”) issued a proposed circular letter for comment regarding the “Use of Artificial Intelligence Systems and External Consumer Data and Information...more

EU’s Highest Court Issues Major AI Decision With Wide-Reaching Impact

On 7 December 2023, the Court of Justice of the European Union (CJEU) issued an important decision on how the GDPR governs AI-assisted decisions. The case arose in the financial services context, with the court holding that...more

New Final AI Regulation from Colorado Department of Insurance—Others Likely to Follow Suit

Our Privacy, Cyber & Data Strategy Group considers the nationwide repercussions of Colorado’s new regulation of insurers’ use of artificial intelligence models to prevent race-based discrimination....more

FTC Launches Investigation into Creator of ChatGPT

In mid-July, the Federal Trade Commission (FTC) reportedly opened an investigation into OpenAI, the maker of ChatGPT, sending the company an extensive Civil Investigative Demand (CID). While FTC investigations are normally...more

Help! My Business Wants to Start Using ChatGPT!

Corporate legal departments are increasingly receiving requests from business clients to use ChatGPT or similar “generative AI” tools in their operations. These requests can be urgent, with business clients demanding...more

AI Regulation in the U.S.: What’s Coming, and What Companies Need to Do in 2023

Artificial intelligence (AI) is expanding into more industries (often in surprising ways) and has inevitably caught the attention of federal and state regulators. Our Privacy, Cyber & Data Strategy Team summarizes the...more

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