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
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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.
The French Authority Publishes Its 2025-2026 Roadmap and 2024 Report
California Enacts Landmark AI Safety Law But With Very Narrow Applicability
On September 29, 2025, Governor Gavin Newsom signed the Transparency in Frontier Artificial Intelligence Act (TFAIA, SB 53 or the Act)[1], establishing a comprehensive framework for transparency, safety and accountability in the development and deployment of the most advanced artificial intelligence models. Building upon existing California laws targeting AI such as AB 2013
EU Merger Guidelines Consultation – Our Views on Innovation and Other Dynamic Elements in Merger Control
As part of our response to the European Commission’s consultation on possible reforms to its merger control guidelines,[1] we provided our views on Topic C – Innovation And Other Dynamic Elements In Merger Control.
EU AI Act: Rules on General-Purpose AI Enter Into Force
The EU AI Act’s phased implementation continues: from 2 August 2025, the AI Act’s rules on general-purpose AI (GPAI) will enter into force (and become enforceable in respect of any new GPAI models in August 2026 and for existing GPAI models in August 2027). This milestone follows the recent publication of (non-binding) guidelines[1] developed