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
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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…
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…
New York Department of Financial Services Issues Guidance on Cybersecurity Risks Arising from Artificial Intelligence
Last week, the New York Department of Financial Services (“DFS”) issued guidance addressed to executives and information security personnel of entities regulated by DFS to assist them in understanding and assessing cybersecurity risks associated with the use of artificial intelligence (“AI”), and implementing appropriate controls to mitigate such risks (the “Guidance”).[1] In particular, and…
EHDS – The EU Parliament formally adopts the Provisional Agreement: Key Takeaways and Next Steps
In our Alert Memorandum of 19 July 2022 (available here), we outlined the European Commission’s (the “Commission”) proposal for a regulation on the “European Health Data Space” (the “Regulation” or the “EHDS”). The proposal, which was published in May 2022, is the first of nine European sector- and domain-specific data spaces set out by…
EU Court of Justice confirms earlier case law on broad interpretation of “personal data” and offers extensive interpretation of “joint controllership”, with possible broad ramifications in the AdTech industry and beyond
On March 7, 2024, the Court of Justice of the European Union (the “CJEU”) handed down its judgment in the IAB Europe case, answering a request for a preliminary ruling under Article 267 TFEU from the Brussels Market Court.[1] The case revolves around IAB Europe’s Transparency and Consent Framework (“TCF”) and has been…
Biden Administration Executive Order Targets Bulk Data Transactions
The Biden administration recently issued Executive Order 14117 (the “Order”) on “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern.” Building upon earlier Executive Orders[1], the Order was motivated by growing fears that “countries of concern” may use artificial intelligence and other advanced technologies to…
European Health Data Space – The Commission’s Proposal on a Single Market For Digital Health Services, Products, and Data
On May 3, 2022, the European Commission published its proposal for a regulation on the “European Health Data Space”.
The EHDS is a talismanic European healthtech initiative that could revolutionize access to a deeper pool of EU-wide health data and unlock significant tech, AI and data analytics innovation. As a core part of the Commission’s…