On December 18, 2025, President Trump signed the 2026 National Defense Authorization Act (“NDAA”), a sweeping defense spending bill that brings a number of changes to the U.S. outbound investment security program, U.S. economic sanctions, and biotechnology restrictions relating to federal procurement. First, the NDAA includes the Comprehensive Outbound Investment National Security (“COINS”) Act, which provides
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New York’s RAISE Act vs. California’s TFAIA: What Companies Need to Know
As states continue to grapple with establishing regulatory frameworks for the most powerful artificial intelligence (“AI”) systems, New York has joined California in targeting frontier AI models with the Responsible AI Safety and Education Act (the “RAISE Act” or the “Act”).[1] Signed into law on December 19, 2025 by Governor Hochul, the Act creates
The DMA High Level Group Endorses Joint Paper on the Regulation of AI
On December 12, 2025, the Digital Markets Act (“DMA”) High-Level Group (“HLG”)[1] endorsed a joint paper on the regulatory interplay on AI-related issues.[2] This paper assesses how to best implement the different legal frameworks that govern AI systems. It underlines the importance of achieving a coherent and consistent implementation of these frameworks and
President Trump Signs Executive Order Seeking to Preempt State AI Regulation
For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.
On December 11, 2025, President Donald Trump signed an executive order titled Establishing A National Policy Framework For Artificial Intelligence (the “Order”)[1]. The Order’s policy objective
Preparing an Annual Report on Form 20-F – Guide for 2026
Form 20-F is the form used for an annual report of a foreign private issuer (“FPI”) filed with the U.S. Securities and Exchange Commission (the “SEC” or the “Commission”). This alert memorandum summarizes considerations that will affect the preparation of the annual report on Form 20-F for the year ending on December 31, 2025 (the
AI-Enabled Cyber Intrusions: What Two Recent Incidents Reveal for Corporate Counsel
This article was authored by Daniel Ilan, Rahul Mukhi, Prudence Buckland, and Melissa Faragasso from Cleary Gottlieb, and Brian Lichter and Elijah Seymour from Stroz Friedberg, a LevelBlue company.
Recent disclosures by Anthropic and OpenAI highlight a pivotal shift in the cyber threat landscape: AI is no longer merely a tool that aids attackers, in some cases, it
Reset or rollback: Unpacking the EU’s Digital Omnibus Package
Background
On 19 November 2025, the European Commission presented its much-anticipated Digital “Omnibus” package[1] intended to ease the administrative and compliance burden facing European businesses. Executive Vice-President of the Commission Henna Virkkunen stated that “[f]rom factories to start-ups, the digital package is the EU’s answer to calls to reduce burdens on our businesses.”[2]
SEC Exam Priorities 2026 Priorities Largely Consistent: Will Approach to Deficiencies and Enforcement Referrals Change?
The U.S. Securities and Exchange Commission (“SEC”) Division of Examinations (the “Division”) released its 2026 examination priorities on November 17, 2025 (the “2026 Priorities”). As expected from the new leadership, the 2026 Priorities signal less (but still present) focus on private fund advisers and more focus on retail advisers and emerging technologies such as AI
UK High Court Issues Landmark Ruling in Getty Images v. Stability AI, with Narrow Trademark Infringement Win for Getty; Claim of Secondary Copyright Infringement Fails
On November 4, 2025, the UK High Court handed down judgment in Getty Images v. Stability AI,[1] a case emphasized for its significance to content creators and the AI industry and “the balance to be struck between the two warring factions”.[2] Despite significant public interest in the lawsuit, the issues that remained before
Italy Adopts the First National AI Law in Europe Complementing the EU AI Act
On 10 October 2025, Law No. 132/2025 (the “Italian AI Law”) entered into force, making Italy the first EU Member State to introduce a dedicated and comprehensive national framework for artificial intelligence (“AI”). The law references the AI Act (Regulation (EU) 2024/1689) and grants the government broad powers to implement its principles and establish detailed operational rules.