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Orrick, Herrington & Sutcliffe LLP

Downstream Modification of GPAIMs: Implications Under the EU AI Act

Orrick, Herrington & Sutcliffe LLP on

When a downstream actor modifies or fine-tunes a general-purpose AI model (GPAIM), who bears the burden of complying with the EU AI Act — the original provider, the modifier or both? ...more

Haynes Boone

EBA Clarifies Conditional Sale Agreements Cannot Confer Originator Status Under EUSR

Haynes Boone on

Overview On Aug. 8, 2025, the European Banking Authority (“EBA”) published a response to a 2021 query concerning whether an entity that manages or establishes a securitisation could qualify as an “originator” (and thereby be...more

Cooley LLP

Model Contractual Clauses for AI Procurement in the EU: Key Takeaways for AI Companies

Cooley LLP on

The European Commission (EC) has released an updated version of the Model Contractual Clauses for AI Procurement (MCC-AI), providing further guidance for public-sector buyers navigating AI procurement under the European Union...more

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