Cybersecurity Incident? Independent Financial Auditors Might Come Knocking

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...

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.

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 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.

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.

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...

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.

New York City has enacted the nation's first municipal click-to-cancel rule, requiring businesses to provide clear disclosures, simple cancellation processes, and advance renewal notices for subscription services. With approximately 30 states already implementing similar regulations and the federal landscape in flux following the FTC's vacated rule, companies now face an increasingly complex patchwork of compliance obligations. The rule takes effect October 1, 2026, and imposes penalties ranging from $525 t

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...

The U.S. government has dramatically expanded Iran-related sanctions through new sectoral determinations, entity designations, and the suspension of key authorizations, while simultaneously targeting third-country financial institutions that facilitate Iranian transactions. These measures significantly broaden secondary sanctions risks across aviation, digital assets, gold, shipping, and technology sectors, marking a comprehensive escalation in economic pressure against Iran and its international networks.

The U.S. Office of the Comptroller of the Currency and the FDIC have issued a joint final rule redefining "unsafe or unsound practice" and establishing new standards for matters requiring attention (MRAs) in bank supervision. How will these changes, which prioritize material financial risk over procedural deficiencies, reshape the regulatory landscape for financial institutions when they take effect in November 2026?

The Supreme Court's decision in National Republican Senatorial Committee v. FEC has fundamentally altered the landscape of political party spending by eliminating federal limits on coordinated expenditures between parties and candidates. This ruling preserves existing campaign finance guardrails while potentially reshaping the power dynamics of party committees, joint fundraising operations, and various political action committees.

Japan and the European Union recently announced an agreement to recognize each other's data protection regimes as adequate.

Rules requiring material agreements to be filed as exhibits to reports and registration statements with the Securities and Exchange Commission (SEC)

On September 9, 2019, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) proposed regulations (proposed regulations) addressing items of income ...

As recently noted, Saba Capital Management, L.P. (Saba) has begun to escalate its attacks on the closed-end fund asset class, at the expense of retail fund shareholders

The SEC staff's decision to stop reviewing shareholder proposal exclusions has fundamentally altered the risk calculus for companies. While this hands-off approach initially appeared to give companies more freedom, it has introduced new challenges including heightened litigation risk, potential bylaw-based proxy contests, and reputational concerns that boards must carefully weigh when deciding whether to exclude proposals from their proxy statements.