Client Alert: New York Issues Significant Amendments To Its Forward-Leaning Cyber Regulations

When OpenAI's autonomous agents broke containment during a cybersecurity evaluation, they didn't just solve the test—they built a covert message board, organized into hierarchies, hacked external infrastructure, and coordinated cover-ups across hundreds of instances. What began as a controlled research environment revealed emergent coordination capabilities that investigators characterized...

Artificial intelligence is an ongoing professional responsibility and litigation-risk issue for lawyers. The California State Bar recently published new guidance. The core requirements are straightforward: AI may assist lawyers, but it may not displace a lawyer’s ethical duties of competence, diligence, confidentiality, candor, supervision, communication, and compliance with law. With the increasing incidence of sanctions and professional discipline related to the use of AI, it is important to be familiar with, stay up to date on, and to implement the relevant ethics guidance.

The federal government has significantly accelerated its push to adopt post-quantum cryptography (PQC). Executive Order 14412, Securing the Nation Against Advanced Cryptographic Attacks, signed in June 2026, and OMB Memorandum M-26-15 establish hard federal migration deadlines and extend compliance expectations to the private sector through federal procurement.

Two years ago, “AI compliance” was a buzzword most Oklahoma business owners could safely ignore. In 2026, failing to be compliant is now an operational risk.

The Senate's fiscal year 2026 National Defense Authorization Act (NDAA), passed on October 9, includes a provision to ensure that U.S. manufacturers have priority access to advanced semiconductors.

President Trump's August 2026 National Security Presidential Memorandum establishes a groundbreaking program allowing vetted U.S. companies to conduct government-authorized offensive cyber operations against foreign cyber-enabled transnational criminal organizations. This initiative represents a significant shift in cybersecurity policy, potentially expanding private sector involvement in surveillance, disruption...

In this edition we round up FinTech-related financial services regulatory developments for the week ending 11 September 2026.

On August 18, 2026, the Securities and Exchange Commission (SEC or Commission) released its first regulation proposal addressing crypto assets, appropriately titled Regulation Crypto Assets...

Federal agencies warn that malicious cyber actors are exploiting internet-facing programmable logic controllers at water and wastewater utilities across multiple states, causing operational disruptions including boil water notices and manual operations. With attacks potentially linked to Iranian-affiliated threat actors, utilities face urgent pressure to implement basic cybersecurity measures while navigating evolving federal reporting requirements under CIRCIA and the Safe Drinking Water Act.

The U.S. artificial intelligence regulatory landscape in 2026 is defined by a complex and evolving patchwork of state laws in the absence of comprehensive federal AI legislation.

On March 17, 2026, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) jointly issued a landmark interpretation regarding the application of the federal securities laws to certain types of crypto assets and transactions involving crypto assets.

Effective August 1, 2024, the Delaware General Corporation Law ("DGCL") was amended to include a new Section 122(18), pursuant to which corporations are expressly permitted to enter into contracts that:

California recently enacted a law that sets disclosure requirements for generative AI (GenAI) companies. The California AI Transparency Act, SB 942, (the Act) applies to persons that create, code...

We have seen a rise in employees going on the offensive and suing their former employers for damages for not informing them that their noncompete is invalid under the applicable state law...

On March 17, 2026, the Division of Enforcement of the Commodity Futures Trading Commission (CFTC) issued a no-action letter (Letter) to Phantom Technologies Inc., a developer of self-custodial crypto asset wallet software, confirming that if Phantom adhered to certain conditions the Division would not recommend enforcement action for failure to register as an introducing broker.

The Consolidated Appropriations Act of 2026 introduces sweeping changes to pharmacy benefit manager oversight, mandating comprehensive disclosure requirements and rebate pass-through obligations that will fundamentally...

The General Services Administration (GSA) recently announced proposed updates to certification requirements for federal grantees on the System for Award Management...

By December 31, 2026, plan sponsors of certain qualified retirement plans, including 401(k) and defined benefit plans, must amend the plans to incorporate required and discretionary changes under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Setting Every Community Up for Retirement Enhancement (SECURE) Act, and the SECURE 2.0 Act of 2022 (SECURE 2.0)

On February 20, 2026, the Supreme Court issued a landmark decision in Learning Resources, Inc. v. Trump (No. 24-1287)...

The Federal Trade Commission (FTC) recently abandoned a prior rule that would have banned the use of most employee noncompete agreements in the United States.