Does California’s Delete Act Have the “DROP” on Data Brokers?: Updates and Insights from the Recent Stakeholder Session
Compliance and Enforcement
by Ari Gutenmacher
5d ago
 by Christine E. Lyon, Christine Chong, Jackson Myers, and Ortal Isaac From left to right: Christine E. Lyon, Christine Chong and Jackson Myers. (Photos courtesy of Freshfields Bruckhaus Deringer LLP) The California Delete Act will make it easier for California consumers to request deletion of their personal information by so-called “data brokers,” a term that is much broader than companies may expect (see our prior blog post here). In particular, the Delete Act provides for a universal data deletion mechanism—known as the Data Broker Delete Requests and Opt-Out Platform, or “DROP”—that ..read more
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Supreme Court Punches SEC APs Right in the Seventh Amendment
Compliance and Enforcement
by Joseph P Facciponti
1w ago
by Andrew J. Ceresney, Charu A. Chandrasekhar, Arian M. June, Robert B. Kaplan, Julie M. Riewe, Kristin A. Snyder, and Jonathan R. Tuttle Top left to right: Andrew J. Ceresney, Charu A. Chandrasekhar, Arian M. June, and Robert B. Kaplan. Bottom left to right: Julie M. Riewe, Kristin A. Snyder, and Jonathan R. Tuttle. (Photos courtesy of Debevoise & Plimpton LLP) Recently, in a long-awaited ruling with significant implications for the securities industry and administrative agencies more generally, the U.S. Supreme Court affirmed the Fifth Circuit’s decision in Jarkesy v. SEC, holding that ..read more
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CNIL Publishes New Guidelines on the Development of AI Systems
Compliance and Enforcement
by Joseph P Facciponti
2w ago
by David Dumont and Tiago Sérgio Cabral David Dumont and Tiago Sérgio Cabral (photos courtesy of Hunton Andrews Kurth LLP) On June 7, 2024, following a public consultation, the French Data Protection Authority (the “CNIL”) published the final version of its guidelines addressing the development of AI systems from a data protection perspective (the “Guidelines”). Read our blog on the pre-public consultation version of these Guidelines. In the Guidelines, the CNIL states that, in its view, the successful development of AI systems can be reconciled with the challenges of protecti ..read more
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Incident Response Plans Are Now Accounting Controls? SEC Brings First-Ever Settled Cybersecurity Internal Controls Charges
Compliance and Enforcement
by Judy Jiang
2w ago
by Andrew J. Ceresney, Charu A. Chandrasekhar, Luke Dembosky, Erez Liebermann, Benjamin R. Pedersen, Julie M. Riewe, Matt Kelly, and Anna Moody Top left to right: Andrew J. Ceresney, Charu A. Chandrasekhar, Luke Dembosky and Erez Liebermann. Bottom left to right: Benjamin R. Pedersen, Julie M. Riewe, Matt Kelly and Anna Moody. (Photos courtesy of Debevoise & Plimpton LLP) In an unprecedented settlement, on June 18, 2024, the U.S. Securities & Exchange Commission (the “SEC”) announced that communications and marketing provider R.R. Donnelley & Sons Co. (“RRD”) agreed to pay approx ..read more
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Treasury and FSOC Sharpen Focus on Risks of AI in the Financial Sector
Compliance and Enforcement
by Ari Gutenmacher
2w ago
by Alison M. Hashmall, David Sewell, Beth George, Andrew Dockham, Megan M. Kayo and Nathaniel Balk Top left to right: Alison M. Hashmall, David Sewell and Beth George. Bottom Left to Right: Andrew Dockham, Megan M. Kayo and Nathaniel Balk. (Photos courtesy of Freshfields Bruckhaus Deringer LLP) On June 6-7, 2024, the Financial Stability Oversight Council (FSOC or the Council) cosponsored a conference on AI and financial stability with the Brookings Institution (the FSOC Conference).  The conference was billed as “an opportunity for the public and private sectors to convene to ..read more
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Recently Enacted AI Law in Colorado: Yet Another Reason to Implement an AI Governance Program
Compliance and Enforcement
by Judy Jiang
3w ago
by Avi Gesser, Erez Liebermann, Matt Kelly, Martha Hirst, Andreas Constantine Pavlou, Cameron Sharp, and Annabella M. Waszkiewicz Top left to right: Avi Gesser, Erez Liebermann, Matt Kelly, and Martha Hirst. Bottom left to right: Andreas Constantine Pavlou, Cameron Sharp, and Annabella M. Waszkiewicz. (Photos courtesy of Debevoise & Plimpton LLP) On May 17, 2024, Colorado passed Senate Bill 24-205 (“the Colorado AI Law” or “the Law”), a broad law regulating so-called high-risk AI systems that will become effective on February 1, 2026.  The law impo ..read more
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Succor Borne Every Minute
Compliance and Enforcement
by Joseph P Facciponti
3w ago
by Michael Atleson Federal Trade Commission Earnest chats with objects are not so unusual. Mark “The Bird” Fidrych, the famed Detroit Tiger, used to stand on the pitching mound whispering to the baseball. Forky, the highly animate utensil from Toy Story 4, once posed deep questions about friendship to a ceramic mug. And many of us have made repeated queries of the Magic 8 Ball despite its limited set of randomly generated answers. Our talking to computers also goes way back, and that history is getting weirder. We’re seeing a wave of avatars and bots marketed to provide companionship, r ..read more
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DOJ National Security Division Issues First-Ever Declination Under Enforcement Policy
Compliance and Enforcement
by Joseph P Facciponti
1M ago
by Satish M. Kini, David A. O’Neil, Jane Shvets, Rick Sofield, Douglas S. Zolkind, Carter Burwell, Connor R. Crowley, and Hillary Hubley Top left to right: Satish M. Kini, David A. O’Neil, Jane Shvets, and Rick Sofield. Bottom left to right: Douglas S. Zolkind, Carter Burwell, Connor R. Crowley, and Hillary Hubley. (Photos courtesy of Debevoise & Plimpton LLP) Key Takeaways Even in criminal national security matters, early self-reporting, remediation and cooperation can enable companies to avoid prosecution and penalties. Federal enforcement agencies are continuing to collaborate in inv ..read more
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CFPB “Firing On All Cylinders” After Surviving Constitutional Challenge To Funding Structure
Compliance and Enforcement
by Ari Gutenmacher
1M ago
by Nowell D. Bamberger, Elsbeth Bennett, and Andrew Khanarian From left to right: Nowell D. Bamberger, Elsbeth Bennett and Andrew Khanarian. (Photos courtesy of Cleary Gottlieb Steen & Hamilton LLP) The Supreme Court recently upheld the Consumer Financial Protection Bureau’s funding structure in a 7–2 decision that will likely pave the way for renewed regulatory activity by the agency in the near future.  Enacted as part of the Dodd-Frank Act, the CFPB’s unique funding structure permits the agency to annually request an unspecified portion of funds from the Federal Reserve System, s ..read more
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Understanding the FTC’s Non-Compete Clause Rule and Its Impact on NDAs
Compliance and Enforcement
by Ari Gutenmacher
1M ago
by Joshua H. Lerner, Laura E. Schneider, and Andrew Stauber From left to right: Joshua H. Lerner, Laura E. Schneider, and Andrew Stauber (Photos courtesy of WilmerHale) As we previously reported, the Federal Trade Commission (FTC) announced on April 23, 2024, its Non-Compete Clause Rule (Final Rule), which aims to ban all new post-employment non-competition restrictions and invalidate most existing ones. The Final Rule already has sparked multiple lawsuits seeking to prevent it from taking effect as scheduled on September 4, 2024. The United States District Court for the Northern District of ..read more
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