On February 14, 2024, Deputy Attorney General Lisa O. Monaco announced an initiative within the U.S. Department of Justice to ramp up the detection and prosecution of crimes perpetrated through artificial intelligence (AI) technology, including seeking harsher sentences for certain AI-assisted crimes. Monaco also announced a new effort to evaluate how the Department can best use AI internally to advance…

On Friday, February 9, 2024, from 11:00-11:30 AM Eastern, Eric Dinallo of the Insurance Regulatory Group, and Avi Gesser and Sharon Shaji of the Data Strategy & Security Group, hosted a discussion on the NYDFS Proposed AI Insurance Circular Letter that was released on January 17, 2024, which sets out detailed requirements for insurance companies operating in New York that…

In 2022, the UK ICO published the International Data Transfer Agreement (“IDTA”) and the International Data Transfer Addendum to the European Commission’s Standard Contractual Clauses (“the Addendum”). In short, the UK’s answer to the EU’s Standard Contractual Clauses for helping legitimise cross-border transfers of personal data. When announced, businesses were told that the EU SCCs would no longer be deemed…

On January 17, 2024, the New York State Department of Financial Services (the “NYDFS”) issued a Proposed Insurance Circular Letter regarding the Use of Artificial Intelligence Systems and External Consumer Data and Information Sources in Insurance Underwriting and Pricing (the “Proposed Circular” or “PCL”). The Proposed Circular is the latest regulatory development in artificial intelligence (“AI”) for insurers, following the…

Key takeaways from December include: Concept of non-material damage under GDPR: In an expansive reading of the right to compensation under GDPR, a data subject’s fear that their personal data may be misused can qualify as recoverable “non-material damage”, according to a new ruling from the CJEU. Businesses should keep this finding, and the court’s wider reasoning behind it, in…