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The Trump Administration’s plan to win the AI race – a legal perspective

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

NAIC proposes evaluation tool for AI systems used by insurers

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

AI regulation Texas-style: The Texas Responsible Artificial Intelligence Governance Act

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

New York’s proposed FAIR Business Practices Act – potential implications for business

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

Recent Executive Order on disparate impact: what it means for insurer’s use of AI

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

AI at the gate: NYDFS issues guidance on addressing new AI-driven cybersecurity risks under existing cybersecurity requirements

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

Beyond the binary: How NIST is shaping the policies and practices of AI innovation and 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

Connecticut Insurance Department adopts NAIC model bulletin on AI

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

New York Department of Financial Services proposes a circular letter on the use of artificial intelligence to underwrite insurance

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

Testing for AI bias: Colorado Division of Insurance proposes first-of-its kind regulation requiring life insurers to test their...

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

Colorado Division of Insurance adopts final rule on use of big data and predictive models

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

CFPB proposal signals a dramatic expansion of the Fair Credit Reporting Act to data brokers

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

NAIC releases highly-anticipated draft model bulletin on artificial intelligence systems used by insurers

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

Updata: Your quarterly privacy & cybersecurity update - January to March 2023

Welcome to the latest edition of Updata! Updata is an international report produced by Eversheds Sutherland’s dedicated Privacy and Cybersecurity team – it provides you with a compilation of key privacy and cybersecurity...more

Copyright office issues new guidance on AI-assisted works, but legal concerns linger

Artificial intelligence (AI) has dominated the headlines over the last several years. As technology has continued to advance, computers and robots have progressed from merely assisting human beings with common tasks to making...more

The march to regulatory change for artificial intelligence: the commonalities between the EU and US

This briefing links up some commonalities between the EU and US in terms of the AI march to regulatory change. Our global regulatory specialists have put their heads together for this update on EU, New York City (NYC) and...more

NAIC survey finds that overwhelming majority of Private Passenger Auto Insurers use or plan to use Artificial Intelligence/Machine...

In December 2022, the National Association of Insurance Commissioners (NAIC) Big Data and Artificial Intelligence (H) Working Group published a Report on the use of artificial intelligence (AI) and machine learning (ML)...more

New York City delays enforcement of its artificial intelligence bias audit in employment law as rule-making continues

New York City (NYC) has delayed to April 15, 2023 the enforcement of its first-of-its-type law on bias in artificial intelligence (AI) tools used in employment. Local Law 144 of 2021 prohibits employers in NYC from using...more

New NIST AI framework offers guidance on risk management and governance for trustworthy AI systems

On January 26, 2023, the National Institute of Standards and Technology (NIST) released its AI Risk Management Framework (AI RMF or Framework.) The AI RMF is a resource for organizations designing, developing, deploying, or...more

The White House releases its Blueprint for an AI Bill of Rights

​​​​​​​On October 4, 2022, the White House Office of Science and Technology Policy (OSTP) issued the Blueprint for an AI Bill of Rights (the Blueprint), which lays out guidelines for companies to use to protect the public...more

FTC report reveals Commission’s position on potential AI harms

On June 16, 2022, the Federal Trade Commission (FTC) issued a strongly worded report to Congress, “Combatting Online Harms Through Innovation,” warning that policymakers must use “great caution” when mandating the use of...more

EU-US Insurance Dialogue Project takes up new technologies and cyber threats that have no borders; Regulatory collaboration in a...

The EU-US Insurance Dialogue Project (“Project”) began in early 2012 as an initiative by the European Commission, the European Insurance and Occupational Pensions Authority (EIOPA), the Federal Insurance Office (FIO) of the...more

US House AI Task Force Is the latest authority to address algorithms and racism

On May 7, 2021, the US House of Representatives Task Force on Artificial Intelligence (AI) held a hearing on “Equitable Algorithms: How Human-Centered AI can Address Systemic Racism and Racial Justice in Housing and Financial...more

US Cybersecurity and Data Privacy review and update: Looking back on our 2020 articles and planning ahead for 2021

It was a tumultuous year for privacy and cybersecurity, and further uncertainty is all but guaranteed. The key to navigating this volatility, as 2020 proved, is to develop and maintain a proactive, agile and holistic data...more

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