U.S. Department Of War Pauses CMMC Phase II Program Requirements

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.

The global CLO equity fund market is experiencing a cautious reopening after a period of tight arbitrage and challenging economics. With U.S. CLO issuance approaching $230 billion in the first half of 2026 and major platforms successfully raising billion-dollar funds, captive and third-party CLO equity fund structures are evolving rapidly as managers deploy sophisticated structuring technologies to provide stable execution capacity and attract institutional capital seeking diversified credit exposure with s

The CFTC has released its 2026 regulatory priorities agenda under new Chairman Michael Selig, outlining significant proposed changes to commodity pool operator exemptions, large trader reporting requirements, and foreign exchange product classifications. Asset managers participating in commodities and derivatives markets will need to understand how these regulatory modifications may affect their registration obligations, reporting burdens, and treatment of various financial instruments.

Preferred equity is transforming structured finance by enabling sponsors to attract third-party capital below rated debt without diluting residual positions or triggering additional rating requirements. This analysis examines how CFOs, CLOs, NAV facilities, and other securitization vehicles are deploying bespoke preferred structures to widen investor pools while preserving manager incentives. What contractual mechanics, legal considerations, and market dynamics are driving this shift from niche accommodatio

Germany's advance lump-sum taxation regime imposes annual deemed investment income on German tax-resident investors in qualifying investment funds, regardless of distributions.

Private equity investment in concierge medicine, aesthetic dermatology and medispas has surged due to cash-pay economics, recurring revenue models and fragmented markets ripe for consolidation. However, navigating state-by-state corporate practice of medicine prohibitions, licensure requirements and evolving GLP-1 regulations requires sophisticated legal structuring to protect valuations and enable successful exits.

The CFTC has taken coordinated actions to bring perpetual contracts under U.S. regulatory oversight, approving the first bitcoin perpetual contract on a domestic exchange.

Over the past decade, asset managers have sought to expand investor access to private markets assets, such as private credit, real estate, infrastructure and other illiquid assets, within the regulatory framework of the 1940 Act.

The NAIC has proposed significant revisions to statutory accounting principles that would restrict bond treatment for multi-collateral structured credit investments deemed to carry "significant embedded asset-liability management risk." This analysis examines the regulatory concerns driving the proposal, evaluates whether the proposed framework appropriately addresses those concerns, and identifies potential unintended consequences for insurance company investors and the broader structured credit markets.

The FTC proposes new enforcement guidelines requiring clear disclosure when businesses use consumer data to set personalized prices, while California's privacy agency launches its first enforcement actions against data brokers. Meanwhile, Meta agrees to pay up to $17.2 billion and implement sweeping product changes to protect teen users on Instagram and Facebook.

The European Union's International Procurement Instrument has issued its first implementing measure, targeting Chinese medical device suppliers with total exclusion from EU public procurement contracts valued at €5 million or more. The Lyon Administrative Court's landmark ruling establishes that contracting authorities must conduct genuine diligence into bidders' commercial substance, even when registered in the EU, to determine their true origin and eligibility to participate in tenders.