Service Agreement Lessons From July's Global Tech Outage

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.

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.

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.

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 White House has released a National Artificial Intelligence Legislative Framework and new executive orders aiming to establish a single, nationwide standard for AI regulation...

The USPTO has released its latest economic impact report on IP-intensive industries, announced a new community engagement office in North Carolina, and issued several administrative updates including relief for Japanese applicants affected by a severe earthquake. The Patent Trial and Appeal Board has also designated new precedential and informative decisions addressing obviousness-type double patenting and Markush groupings.

California's Air Resources Board has released significant modifications to its greenhouse gas emissions reporting regulation, deferring the first reporting deadline to November 10, 2026, and clarifying key requirements for companies doing business in California with over $1 billion in annual revenue. The updates provide additional flexibility for 2026 reporting while enforcement of the Climate-Related Financial Risk Act remains paused pending federal litigation.

The US International Trade Commission has opened a rare public comment period on how it should fulfill its data collection and reporting obligations under Section 338 of the Tariff Act of 1930, a long-dormant authority recently invoked by the Trump Administration to impose restrictions on Canadian imports. This presents a unique opportunity for companies and stakeholders to shape from the ground up how the Commission interprets discriminatory foreign trade practices, evaluates allegations, and reports findi

The SEC has proposed a comprehensive overhaul of transfer agent regulations that would formally recognize distributed ledger technology and blockchain-based recordkeeping systems within the existing regulatory framework. This modernization effort imposes enhanced operational, safeguarding, and compliance obligations while establishing technology-neutral standards that could significantly impact tokenization initiatives and digital asset market infrastructure.

The sports and gaming industries are evolving faster than existing legal frameworks can accommodate, creating unprecedented jurisdictional battles, regulatory shifts, and commercial opportunities. From the escalating fight over prediction markets between federal regulators and states to the emergence of responsible gaming as a standalone policy priority, the first half of 2026 has reshaped the legal landscape governing these sectors while raising fundamental questions about innovation, consumer protection

As discussed in previous client alerts, the rapid growth of artificial intelligence (AI), cloud computing, and digital services has dramatically increased demand for data centers.

Washington Attorney General Nick Brown released the state's first Data Privacy Report, examining how the modern data economy incentivizes personal information collection and retention. The report catalogs resulting harms and recommends that lawmakers strengthen privacy protections, enforcement, and public education while highlighting Washington's continued lack of a comprehensive consumer privacy statute despite inspiring other states' privacy laws.

As investment in data center infrastructure accelerates globally, disputes are emerging from contractual and investment-related risks that commonly accompany large-scale infrastructure projects. This analysis examines the growing wave of contractual claims among owners, contractors, and subcontractors, as well as investment treaty claims that may arise when governmental actions impact overseas data center developments.

The US Department of Justice has signaled a potential expansion of enforcement under the Foreign Agents Registration Act (FARA) and Section 951, despite earlier indications of limited criminal enforcement. Recent regulatory developments, policy announcements, and high-profile prosecutions of US officials suggest a renewed focus on foreign agent disclosure requirements and potential criminal liability for undisclosed relationships with foreign governments.

The U.S. Department of Justice has announced three major settlements totaling over $558 million against healthcare providers partnering with Medicare Advantage plans for allegedly submitting false diagnosis codes. These enforcement actions reveal DOJ's intensified scrutiny of risk-sharing payment arrangements between Medicare Advantage plans and healthcare providers, while demonstrating the significant benefits that self-disclosure and cooperation can provide to companies facing potential False Claims Act l