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Illinois Enacts Artificial Intelligence Safety Measures Act

By Reena Bajowala, Mikaela Shaw Masoudpour & Andrew (Drew) W. Berube on July 17, 2026
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On July 6, 2026, Illinois Governor, JB Pritzker, signed the Artificial Intelligence Safety Measures Act (the Act), imposing governance, transparency, audit, and incident-reporting obligations on developers of advanced AI models. The Act focuses on “frontier models” and places the most obligations on “large frontier developers” with annual gross revenues exceeding $500 million. The Act takes effect Jan. 1, 2027, with many substantive compliance obligations beginning in 2028. 

Click here to read the full GT Alert.

Photo of Reena Bajowala Reena Bajowala

Reena R. Bajowala has deep experience with data security, information technology, and privacy law issues, and litigating class, collective, and plan-wide litigation. She is a Certified Information Privacy Technologist (CIPT), a Certified Information Privacy Professional – US (CIPP/US) and a Certified Information Privacy

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Reena R. Bajowala has deep experience with data security, information technology, and privacy law issues, and litigating class, collective, and plan-wide litigation. She is a Certified Information Privacy Technologist (CIPT), a Certified Information Privacy Professional – US (CIPP/US) and a Certified Information Privacy Manager (CIPM). Through a competitive process, she was selected as a 2021-2023 Fellow of the American Bar Association’s Business Law Section with the Cyberspace Law Subcommittee.

When faced with a data breach, including in business email compromise, ransomware, or wire transfer fraud scenarios, clients turn to Reena to investigate, remediate, and comply with legal obligations. She regularly conducts risk assessments, develops privacy and information security compliance programs, and leads proactive planning for potential data security incidents, including drafting incident response plans, communications plans, and conducting tabletop exercises. In addition, Reena helps evaluate legal risks relating to emerging technologies, including artificial intelligence, connected devices, and drones.

Reena assists Employee Retirement Income Security Act (ERISA) benefit plan sponsors with implementing cybersecurity policies and service provider management programs. The Department of Labor’s current emphasis on cybersecurity allows Reena to utilize her combined decade-plus ERISA and benefit plan counseling and litigation experience and her deep cybersecurity and vendor management practice.

Reena has wide-ranging litigation and trial experience, including over 100 days of first-chair trial experience. She represents buyers and providers of IT services regarding issues ranging from billing and performance disputes arising from Master Services Agreements and Service Level Agreements to copyright and licensing disputes pursuant to Software Licensing and SaaS agreements. Reena also works to protect the interests of companies during software audits.

With a broad-based background in complex dispute resolution, Reena understands the intricacies of class, collective, and plan-wide litigation in the employment and consumer fraud spaces. She has deep experience with lawsuits involving ERISA, having represented plan sponsors and service providers in both benefits and fiduciary matters.

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Photo of Mikaela Shaw Masoudpour Mikaela Shaw Masoudpour

Mikaela Shaw Masoudpour is a trusted advisor to companies from startups to Fortune 100 in a wide range of employment matters, from strategic employment counseling and internal investigations to proactive audits and compensation analyses to litigation. She provides pragmatic, timely advice to employers…

Mikaela Shaw Masoudpour is a trusted advisor to companies from startups to Fortune 100 in a wide range of employment matters, from strategic employment counseling and internal investigations to proactive audits and compensation analyses to litigation. She provides pragmatic, timely advice to employers for their pressing workplace issues, including hiring, leave and disability, remote work, performance management, pay equity, restrictive covenants, wage and hour, workplace policies, and labor relations.

When litigation does occur, Mikaela regularly represents clients in courts and before administrative agencies in individual and class claims under Title VII of the Civil Rights Act of 1964, the Family and Medical Leave Act, Americans with Disabilities Act, Age Discrimination in Employment Act, the Fair Labor Standards Act, the Equal Pay Act, federal labor laws, and other employment statutes. She leverages her deep courtroom experience to assist employers with litigation prevention and crisis management.

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Photo of Andrew (Drew) W. Berube Andrew (Drew) W. Berube

Drew Berube focuses on data privacy, technology, and corporate matters. He is a Certified Information Privacy Professional in the United States (CIPP/US), Europe (CIPP/E), and Canada (CIPP/C) and advises clients on compliance with various privacy laws, including the European Union’s General Data Protection…

Drew Berube focuses on data privacy, technology, and corporate matters. He is a Certified Information Privacy Professional in the United States (CIPP/US), Europe (CIPP/E), and Canada (CIPP/C) and advises clients on compliance with various privacy laws, including the European Union’s General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the California Privacy Rights Act (CPRA). He assists organizations in safeguarding sensitive data and navigating the legal and regulatory landscape of data protection before and after security incidents. His work includes drafting and reviewing data protection agreements, privacy disclosures, website privacy policies, and terms of use.

In the corporate realm, Drew is involved in drafting and negotiating mergers and acquisitions, venture capital financings, and commercial agreements. He prepares various documents including purchase agreements, assignment agreements, master services agreements, data protection addendums, and shareholder agreements. Drew also provides guidance on corporate restructurings, market standards in venture capital and private equity financings, and regulatory best practices.

Drew’s experience extends to due diligence in acquisitions, privacy, and security matters, ensuring clients are informed about potential risks. He has represented clients in de-SPAC processes and has experience in general commercial litigation.

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  • Posted in:
    Privacy & Data Security
  • Blog:
    Data Privacy Dish
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source
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