On July 12, 2024, the European Union’s long-awaited Artificial Intelligence Act (AI Act) was finally published. It will enter into force on the twentieth day following its publication; i.e., on August 1, 2024. The AI Act is a landmark legal framework that imposes obligations on both private and public sector actors that develop, import, distribute, […]
Advisories
SEC Settlement Suggests the Agency’s Attempt to Regulate Cybersecurity Controls
On June 18, 2024, the SEC announced a $2.125 million settlement with R.R. Donnelley & Sons Co. (“RRD”) related to the company’s 2021 ransomware attack (the “Incident”). The settlement, and the SEC’s accompanying cease-and-desist order (the “Order”), portend the agency’s continued and increasing oversight over registrants’ cybersecurity policies and practices. Background RRD is a global […]
EU Artificial Intelligence Act Signed Into Law
Today, the EU Artificial Intelligence Act (‘AI Act’) was signed into law. The AI Act will impose obligations on both private and public sector actors which provide, import, distribute, or deploy in-scope AI systems. It also contains obligations which apply in connection with general-purpose AI models. The AI Act has explicit extra-territorial effect, which means […]
State AGs and Other Stakeholders Weigh In On Proposed COPPA Rule Update
The Federal Trade Commission (FTC) received over 270 comments to its notice of proposed rulemaking (NPRM) for the amendments to the Children’s Online Privacy Protection Rule (COPPA Rule) during the public comment period that ended on March 11, 2024. The NPRM reflects the FTC’s continued effort to modernize the COPPA Rule, which implements the Children’s […]
Colorado AG Publishes Shortlist of Universal Opt-Out Mechanisms
On November 21, 2023, the Colorado Attorney General (the “AG”) published a shortlist of potential universal opt-out mechanisms (“UOOMs”) that the AG is considering recognizing as binding under the Colorado Privacy Act (the “CPA”). Beginning on July 1, 2024, the CPA will require covered controllers to comply with Colorado consumers’ requests to opt out of […]