Artificial Intelligence And Machine Learning Across The UK, EU And US: Bridging The Regulatory Divide

On 8 November 2023, Neil Robson, a partner in the Financial Markets and Funds practice, moderated a panel discussion on the regulatory divide for artificial intelligence (AI) across the UK, EU and US, with a focus on providing legal and compliance insights for the asset management industry. Following the event, we thought that it might be interesting to reflect on the following key takeaways from the panel discussion:

1. Approach to AI regulation. The EU, UK and US are taking different approaches to the regulation of AI. The EU is legislating to implement a prescriptive rules-based approach to AI governance, with clear guidelines and definitions. However, the proposed EU AI Act is yet to become law. On the UK side, there is a more pragmatic principles-based approach to the regulation of AI with the UK regulators exploring how AI can be "slotted into" existing frameworks. To contrast, the US regulators are focusing on curtailing and/or restricting certain AI use.