Regulation (EU) 2023/2854 (the Data Act) entered into force on January 11, 2024, and applied from September 12, 2025, with certain provisions phased in through 2026 and 2027. The Data Act is intended to create a harmonized framework for fair access to and use of data across the EU, supplementing…
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Sustaining and Modernizing Mainframe Systems in the Global Economy
Mainframe computers are the backbone of many global industries, and integral to industry sectors such as finance, health care, transportation and government. However, the personnel trained to manage these systems are aging out of the workforce while mainframes are not—they continue to provide unmatched reliability, resiliency and security. In Sustaining…
EU AI Act at the Crossroads: GPAI Rules, AI Literacy Guidance and Potential Delays
The EU AI Act (AI Act), effective since February 2025, introduces a risk-based regulatory framework for AI systems and a parallel regime for general-purpose AI (GPAI) models. It imposes obligations on various actors, including providers, deployers, importers and manufacturers, and requires that organizations ensure an appropriate level of AI literacy…
New Changes to GDPR Proposed: An Indication of Shifting Policy Priorities?
The European Commission’s proposed amendments to the General Data Protection Regulation (GDPR) mark the first substantive reworking of the regulation since its enactment, signaling a material shift toward economic pragmatism. These changes warrant close attention not only for what they include, but also for what they omit. The Proposed Changes…
Legal Definitions of AI: Considerations and Common Threads
By now, we all know what AI is. Some of us use ChatGPT as our search engine, confidant, secretary, travel agent, and much more. Others, at least, are acutely aware that AI exists, because everyone else is talking about it, possibly making money from it, or losing their jobs to…
An Update on Cloud Computing in the Financial Sector
In 2023, we summarized the U.S. Department of Treasury report that raised concerns about the growing reliance of financial institutions (FIs) on cloud computing. Treasury highlighted structural imbalances and regulatory blind spots in the relationship between FIs and cloud service providers (CSPs). Since then, in an effort to encourage more…
Why Your Organization Should Be Thinking About Quantum Computing and the Future of Encryption
Quantum computing (QC) is poised to disrupt cybersecurity in ways that business leaders and legal professionals cannot afford to ignore. But what exactly is quantum computing, why does it pose such a significant threat to encryption, and what should businesses be doing about it today? What Is Quantum Computing? To…
Apple’s $500B U.S. Manufacturing Push and New AI Server Facility in Houston: What It Means for Data Centers
As we covered previously, President Trump has made clear that the U.S. is focused on increasing investments into building, scaling and speeding the development of AI infrastructure and data centers in the U.S., and Big Tech is responding in kind. On Monday, Apple announced its largest-ever spend commitment: $500 billion in the U.S.…
AI Action Paris Summit 2025: Key Takeaways on Global AI Governance
The AI Action Summit brought together a wide-ranging assembly of influential figures to discuss the future of artificial intelligence (AI) governance, risk mitigation and international cooperation. The attendees included government leaders and executives from multinational and emerging companies. The event was held on February 10 – 12, 2025, in Paris.…
EU AI Act: First Set of Requirements Go into Effect February 2, 2025
The first binding obligations of the European Union’s landmark AI legislation, the EU AI Act (the Act), came into effect on February 2, 2025. Essentially, from this date, AI practices which present an unacceptable level of risk are prohibited and organizations are required to ensure an appropriate level of AI…