Particularly with a new US administration in place, the first half of 2025 is witnessing a substantial reconfiguring of regulatory and enforcement priorities that promise to have profound impacts on companies as the year...more
8/15/2025
/ Automotive Industry ,
California Consumer Privacy Act (CCPA) ,
COPPA ,
Data Privacy ,
Federal Trade Commission (FTC) ,
Gramm-Leach-Blilely Act ,
Online Safety for Children ,
Popular ,
Sensitive Personal Information ,
State Privacy Laws ,
Video Privacy Protection Act
Since the beginning of the second Trump Administration, we have seen a dramatic shift in US AI policy away from mitigating AI’s social and physical harms to promoting America’s AI domination on the world’s stage, advancing...more
8/7/2025
/ Artificial Intelligence ,
Department of Defense (DOD) ,
Executive Orders ,
Government Agencies ,
Innovative Technology ,
National Security ,
NIST ,
Regulatory Agenda ,
Regulatory Reform ,
Risk Management ,
Technology Sector ,
Trump Administration ,
U.S. Commerce Department
On July 24, 2025, the California Privacy Protection Agency (CPPA) unanimously adopted a comprehensive rulemaking package under the California Consumer Privacy Act (CCPA) that primarily addresses automated decisionmaking...more
7/31/2025
/ Algorithms ,
Automated Decision Systems (ADS) ,
California Consumer Privacy Act (CCPA) ,
Consumer Privacy Rights ,
Cybersecurity ,
Data Privacy ,
Employee Rights ,
Job Applicants ,
New Regulations ,
Regulatory Requirements ,
Risk Assessment ,
Risk Management ,
Technology
The first piece of major US federal legislation in the global digital assets space was signed into law on July 18, 2025, by President Trump.1 Declared by President Trump as positioning the United States to be the “crypto...more
On July 7th, the NAIC’s Big Data and AI Working Group (Working Group) exposed a draft of an AI Systems Evaluation Tool (Evaluation Tool). The stated purpose is to provide regulators with a tool that enables them to identify...more
7/30/2025
/ Algorithms ,
Artificial Intelligence ,
Compliance ,
Consumer Protection Laws ,
Data Collection ,
Financial Services Industry ,
Insurance Industry ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management ,
Technology
The Texas Responsible Artificial Intelligence Governance Act (TRAIGA), which was signed into law by Governor Greg Abbott on June 22, 2025, and is effective January 1, 2026, establishes a framework for regulating the...more
The Consumer Financial Protection Bureau recently signaled a retreat from its regulatory and enforcement posture by outlining its 2025 supervisory and enforcement priorities and rescinding 67 regulatory guidance documents. In...more
On April 23, 2025, President Donald Trump issued an Executive Order titled “Restoring Equality of Opportunity and Meritocracy” (order). The order declares disparate impact theory to be “wholly inconsistent with the...more
5/12/2025
/ Artificial Intelligence ,
Civil Rights Act ,
Colorado ,
Disparate Impact ,
Executive Orders ,
Insurance Regulations ,
New York ,
NYDFS ,
Preemption ,
Regulatory Reform ,
Technology ,
Title VI ,
Trump Administration
In litigation challenging unclaimed property examination findings, the Michigan Supreme Court took a first step towards curtailing the seemingly never-ending examination process, but left open an opportunity for the State to...more
Pivotal litigation, targeted legislation, and aggressive regulatory interpretations will reshape the unclaimed property landscape for US companies in 2025. States continue to expand the application and enforcement of their...more
1/20/2025
/ Cryptocurrency ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Financial Services Industry ,
Reporting Requirements ,
Retirement ,
SCOTUS ,
State Attorneys General ,
Whistleblowers
On October 16, 2024, the New York State Department of Financial Services (DFS) issued an industry letter providing guidance on how DFS-regulated entities (covered entities) should be evaluating and responding to artificial...more
10/30/2024
/ Artificial Intelligence ,
Covered Entities ,
Cyber Threats ,
Cybersecurity ,
Deep Fake ,
Industry Letters ,
New York ,
NYDFS ,
Popular ,
Regulatory Agenda ,
Regulatory Requirements ,
Reporting Requirements ,
Risk Management
On September 24th and 25th, the National Institute of Standards and Technology (NIST) convened a symposium to generate new insights about the next steps needed to unleash AI innovations that will enable trust in this...more
Imagine a world in which powerful computers can instantaneously break a company’s standard encryption, threatening the most valuable financial data, intellectual property, personal information, and even national security...more
On February 26, 2024, the Connecticut Insurance Department (the CID) adopted Bulletin No. MC-25 on the “Use of Artificial Intelligence Systems in Insurance” (Connecticut Bulletin). This Connecticut Bulletin is similar to the...more
3/15/2024
/ Artificial Intelligence ,
Compliance ,
Corporate Governance ,
Insurance Industry ,
Model Rules ,
NAIC ,
NIST ,
Popular ,
Regulatory Oversight ,
Risk Management ,
State Insurance Administrations
Technological advances, especially in Artificial Intelligence and quantum computing, will continue to amaze in the coming years. They will open up vast new opportunities while presenting profound regulatory, litigation, and...more
3/1/2024
/ Artificial Intelligence ,
Business Losses ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Cyber Crimes ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Enforcement Actions ,
Federal Trade Commission (FTC) ,
Financial Services Industry ,
NAIC ,
Popular ,
Securities and Exchange Commission (SEC) ,
State Privacy Laws ,
Technology ,
Website Design ,
Websites
Unclaimed property examinations and new types of regulatory inquiries will pose major challenges for US companies in 2024. Not only are states pushing ahead with more examinations, but many states are using new techniques to...more
On January 17, 2024, the New York State Department of Financial Services (NY DFS) released for public comment a proposed circular letter (Proposed Letter) to regulate the use of artificial intelligence systems (AIS) and...more
Many organizations have recently received a notice from the Delaware Department of Finance Office of Unclaimed Property requesting a sworn verification of the completeness and accuracy of their unclaimed property reporting....more
On September 28, 2023, the Colorado Division of Insurance (CDI) released the first-of-its kind draft proposed regulation (Testing Regulation) for testing the outcomes of certain life insurance underwriting practices for...more
On November 1, 2023, the New York Department of Financial Services (NY DFS) published its highly anticipated final amendments to its influential cybersecurity requirements for financial services companies (Part 500)....more
11/15/2023
/ Chief Information Security Officer (CISO) ,
Compliance ,
Covered Entities ,
Cybersecurity ,
Final Rules ,
Financial Services Industry ,
Incident Response Plans ,
Multi-Factor Authentication ,
NYDFS ,
Policies and Procedures ,
Risk Assessment ,
Risk Management ,
State Data Breach Notification Statutes
Welcome to the latest edition of Updata – the international update from Eversheds Sutherland’s dedicated Privacy and Cybersecurity team.
Updata provides you with a compilation of privacy and cybersecurity regulatory and...more
11/7/2023
/ Banking Sector ,
Cybersecurity ,
Data Breach ,
Data Privacy ,
Data Protection ,
Data Security ,
Data Subject Access Requests ,
Employee Monitoring ,
Enforcement Actions ,
EU ,
Hong Kong ,
New Legislation ,
Privacy Framework ,
Privacy Laws ,
UK
The Colorado Division of Insurance (CDI) adopted a new regulation on September 21, 2023 (Final Regulation) establishing requirements governing the use of external consumer data and information sources (ECDIS), as well as...more
10/2/2023
/ Algorithms ,
Anti-Discrimination Policies ,
Artificial Intelligence ,
Big Data ,
Casualty Insurance ,
Department of Insurance ,
Final Rules ,
Insurance Industry ,
Life Insurance ,
Predictive Analytics ,
Property Insurance ,
Proposed Legislation ,
Proposed Regulation ,
Risk Management
On September 15, 2023, the Consumer Financial Protection Bureau (CFPB) published an outline of expansive rulemaking proposals to modernize the coverage of the Fair Credit Reporting Act (FCRA) to include data brokers, data...more
9/26/2023
/ Artificial Intelligence ,
Comment Period ,
Consumer Financial Protection Bureau (CFPB) ,
Credit Reports ,
Creditors ,
Data Brokers ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
Medical Debt ,
Proposed Rules ,
Rulemaking Process ,
SBREFA ,
Small Business ,
Underwriting
On July 17, 2023, the Innovation, Cybersecurity and Technology (H) Committee of the National Association of Insurance Commissioners (NAIC) released for comment a highly anticipated model bulletin (Model Bulletin) on...more
7/27/2023
/ Artificial Intelligence ,
Casualty Insurance ,
Comment Period ,
Corporate Governance ,
Insurance Industry ,
Model Forms ,
NAIC ,
Property Insurance ,
Regulatory Oversight ,
Request For Information ,
Risk Management ,
Third-Party Service Provider ,
Unfair or Deceptive Trade Practices
Welcome to the latest edition of Updata – the international update from Eversheds Sutherland’s dedicated Privacy and Cybersecurity team.
Updata provides you with a compilation of privacy and cybersecurity regulatory and...more