On June 2, 2026, Connecticut Governor Ned Lamont signed Senate Bill 5 into law, designated as Public Act 26-15 and also known as the Connecticut Artificial Intelligence Responsibility and Transparency Act (the “CART Act” or “Act”).1 The CART Act is among the most comprehensive state AI laws enacted to date, creating distinct obligations for employment-related automated decision tools, consumer chatbots, frontier-model developers, generative-AI provenance, and online platforms used by minors, while also addressing AI applications in healthcare through targeted carveouts and innovation initiatives.
Continue Reading Connecticut Enacts Sweeping AI Law Covering Employment, Healthcare, and Online Safety
Briana Fasone
Supreme Court Reinforces Donor Privacy Protections, Permitting Immediate Federal Court Challenge to State Subpoena
On April 29, 2026, the United States Supreme Court issued a unanimous opinion in First Choice Women’s Resource Centers, Inc. v. Davenport, where it held that a nonprofit suffered an injury to its First Amendment right of association when it was subpoenaed by a state attorney general to produce donor information, including donor identities.1 Justice Gorsuch, writing for the Court, held that the nonprofit petitioner could challenge the subpoena in federal court without first waiting for a state court to compel compliance.
Continue Reading Supreme Court Reinforces Donor Privacy Protections, Permitting Immediate Federal Court Challenge to State SubpoenaNewsom Signs Executive Order Establishing AI Vendor Certification and Procurement Framework
On March 30, 2026, Governor Gavin Newsom signed Executive Order N-5-26 (the “Order”), directing California state agencies to develop new certification requirements and procurement standards for companies seeking to provide AI-enabled products or services to the state.1 The Order represents the latest move in an intensifying contest between California and the federal government over the future of AI regulation in the United States.
Continue Reading Newsom Signs Executive Order Establishing AI Vendor Certification and Procurement Framework
Supreme Court to Consider the Video Privacy Protection Act
Last week, the U.S. Supreme Court agreed to hear a case that is expected to resolve a long-developing split among federal courts of appeals over the scope of the Video Privacy Protection Act of 1988 (“VPPA”), 18 U.S.C. § 2710. In granting certiorari in Salazar v. Paramount Global, the Court will address a question that has increasingly shaped VPPA class action litigation in recent years: who qualifies as a “consumer” protected by the statute.
Continue Reading Supreme Court to Consider the Video Privacy Protection ActOn the Ninth Day of Data… State of the States: This Year’s Key Privacy Law Developments Across the U.S. States
The continued absence of a comprehensive federal privacy law once again positioned state legislatures as the primary forces behind data privacy developments in the U.S. this year. In 2025, eight new comprehensive state privacy laws took effect, adding to a growing patchwork of regulations that now spans 20 states. These laws generally reinforce established standards but introduce some important differences in applicability, exemptions, and sensitive data protections, making multi-state compliance increasingly complex.
States also continued to refine their data breach notification requirements, with notable amendments in New York, California, and Oklahoma aimed at strengthening consumer protections and reporting standards. Meanwhile, the rapid proliferation of state-level AI legislation—alongside a controversial new executive order directing federal agencies to challenge such laws—added a new layer of considerations for businesses leveraging artificial intelligence. With additional privacy laws set to take effect in 2026 and even stricter proposals on the horizon, organizations should remain proactive in adapting to this dynamic and increasingly fragmented regulatory environment.
Continue Reading On the Ninth Day of Data… State of the States: This Year’s Key Privacy Law Developments Across the U.S. StatesOn the Sixth Day of Data… CISA, CIRCIA, and the Future of Critical Infrastructure Security
This holiday season—following a year of headline breaches, surging supply-chain attacks, and major regulatory changes—cyber resilience tops every corporate wish list.
The Cybersecurity and Infrastructure Security Agency (“CISA”) remains at the forefront of U.S. cybersecurity amid a turbulent year of leadership change and policy realignment. With the long‑awaited Cyber Incident Reporting for Critical Infrastructure Act (“CIRCIA”) rules slated for May 2026 and a continuing focus on international cyber strategies, the agency is poised to shape the future of critical infrastructure security. CIRCIA will introduce mandatory cyber incident and ransomware payment reporting for covered critical infrastructure, driving faster federal response and shaping compliance programs, contractual obligations, and risk governance across sectors. At the same time, CISA’s 2025–2026 International Strategic Plan outlines the federal government’s purported approach to cross‑border cyber defense—prioritizing partnerships, information sharing, and supply‑chain risk mitigation—with direct implications for transnational firms. Yet CISA faces major challenges, including leadership gaps, workforce constraints, and increased political scrutiny, that may threaten its ability to fulfill its mission in the year ahead.
Continue Reading On the Sixth Day of Data… CISA, CIRCIA, and the Future of Critical Infrastructure SecurityOn the Fourth Day of Data… All is Calm, All is Bright? Securing Agentic AI Before the Lights Go Out
As 2025 draws to a close and some organizations slip into a quieter holiday rhythm, their AI systems continue humming in the background—summarizing customer inquiries, triaging security alerts, generating code, and synchronizing records across critical systems. Within that uninterrupted activity, however, lies a less festive truth: agentic AI introduces cyber risks of unprecedented complexity and novelty, beyond what conventional architectures were designed to manage.
Agentic AI—the class of systems that can reason, plan, act, and adapt toward goals with reduced human oversight—promises measurable gains across legal services, finance, healthcare, and supply chain operations. But the same autonomy that drives new efficiencies also creates a distinctly complex cybersecurity risk profile. By initiating actions, calling tools, exchanging data with other agents, and escalating privileges to meet objectives, autonomous systems expand the attack surface and introduce “digital insiders” that can err at scale, leak data silently, and even be co-opted by threat actors. For those advising on governance, cyber preparedness, and emerging-tech strategy, the takeaway is clear: companies need a practical, defensible program tailored to agentic environments—one that reduces the likelihood and blast radius of failures before a single misaligned step turns out all the lights.
Continue Reading On the Fourth Day of Data… All is Calm, All is Bright? Securing Agentic AI Before the Lights Go OutChange Healthcare Cyberattack: HHS OCR Publishes Early Guidance on Breach and UnitedHealth Group Provides Critical Status Update
On March 13, 2024, the U.S. Department of Health and Human Services (“HHS”) Office for Civil Rights (“OCR”) announced that it had opened an investigation into the monumental cyberattack on Change Healthcare (“Change”), a unit of UnitedHealth Group (“UHG”). The attack is one of the largest assaults against the U.S. health care system, with far-reaching…
NIST Publishes Long-Awaited Cybersecurity Framework 2.0
On February 26, 2024, the National Institute of Standards and Technology (“NIST”) released version 2.0 of its Cybersecurity Framework (“CSF 2.0”)—the first significant update to the cybersecurity guidance since its initial publication a decade ago.[1] While the original guidance was tailored to critical infrastructure entities, the new version has a broader scope and applies to organizations of all sizes across industries, from large corporations with robust data protection infrastructure to small schools and nonprofits that may lack cybersecurity sophistication.[2] CSF 2.0 notably incorporates new sections on corporate governance responsibilities and supply chain risks; additionally, NIST has released supplemental implementation guides and reference tools that can assist organizations measure cybersecurity practices and hone data protection priorities.[3]
Continue Reading NIST Publishes Long-Awaited Cybersecurity Framework 2.0Making a List and Checking it Twice: The Impact of Cybersecurity Regulations on Financial Services in 2023
Not that long ago, financial sector regulations seldom mentioned cybersecurity expressly, instead addressing the issue indirectly through restrictions focused on general system safeguards and omnibus reporting requirements. Gone are those days. Over the past few years, federal and state regulators have increased focus on information security issues impacting financial institutions, introducing a spate of cyber rules that often include stringent regulatory reporting and disclosure requirements. This year was no different.
Continue Reading Making a List and Checking it Twice: The Impact of Cybersecurity Regulations on Financial Services in 2023