ICO Publishes Its Strategic Approach to Regulating AI

On 30 April 2024, the UK’s Information Commissioner’s Office (“ICO”) published its strategic approach to regulating artificial intelligence (“AI”) (the “Strategy”), following the UK government’s request that key regulators set out their approach to AI regulation and compliance with the UK government’s previous AI White Paper (see our previous blog post here). In its Strategy, the ICO sets out: (i) the opportunities and risks of AI; (ii) the role of data protection law; (iii) its work on AI; (iv) upcoming developments; and (v) its collaboration with other regulators. The publication of the ICO’s Strategy follows the recent publication of the Financial Conduct Authority’s (“FCA”) approach to regulating AI.


A New Wave of Class Actions: The Genetic Information Privacy Act

Largely dormant for the last 25 years, Illinois’ Genetic Information Privacy Act (GIPA) has been sharing the limelight recently with its sibling, the Biometric Information Privacy Act. (BIPA). GIPA includes a number of restrictions related to the use and disclosure of genetic testing and genetic information, and it provides a private right of action and permits recovery of steep statutory damages. In 2023 alone, over 50 GIPA complaints were filed, and new suits continue to be filed in 2024. In this article, published on AML, Sidley lawyers Kathleen Carlson, Lawrence Fogel, and Colleen Brown explore some of GIPA’s emerging issues and unanswered questions.


Top 10 Questions on the EU AI Act

The EU AI Act will be the first standalone piece of legislation worldwide regulating the use and provision of AI in the EU, and will form a key consideration in AI governance programs. The AI Act will have a significant impact on many organizations inside and outside the EU, with failure to comply potentially leading to fines of up to 7% of annual worldwide turnover.


EU Formally Adopts Cyber Law for Connected Products

On 12 March 2024, the European Parliament approved the EU Cyber Resilience Act (“CRA”) with a large majority of 517-12 votes in favor of the legislation (with 78 abstentions). The CRA aims to ensure that “products with digital elements” (“PDE”) i.e., connected products such as smart devices, and remote data processing solutions, are resilient against cyber threats and provide key information in relation to their security properties.


Chambers 2024 Global Practice Guides for Data Protection & Privacy and Cybersecurity

The newest editions of the Chambers Global Practice Guides have been published and, once again, Sidley lawyers have contributed to two guides: Data Protection & Privacy 2024 and Cybersecurity 2024. These publications cover important developments across the globe and offer insightful legal commentary for businesses on issues related to data privacy and cybersecurity, such as regulatory enforcement and litigation, global cooperation to combat cybercrime, international agreement on ‘Software Security by Design,’ a global approach to policy on artificial intelligence, and more. Sidley partner Alan Charles Raul is a contributing editor to both guides in addition to authoring the introductions. The UK chapters of Cybersecurity 2024, covering “UK Law and Practice” and “UK Trends and Development” were authored by Sidley lawyers William Long, Francesca Blythe, Denise Kara, and Eleanor Dodding.


Regulatory Update: National Association of Insurance Commissioners Spring 2024 National Meeting

The National Association of Insurance Commissioners (NAIC) held its Spring 2024 National Meeting (Spring Meeting) March 15 through 18, 2024. This Sidley Update summarizes the highlights from this meeting in addition to interim meetings held in lieu of taking place during the Spring Meeting. Highlights include proposed updates to the regulatory review process for affiliated investment management agreements, continued discussion of considerations related to private equity ownership of insurers, and continued development of accounting principles and investment limitations related to certain types of bonds and structured securities.


FinCEN Seeks Input on Banks’ Collecting Partial Social Security Numbers for Customer Identification Programs

On March 28, 2024, the Financial Crimes Enforcement Network (FinCEN), in consultation with the U.S. banking agencies and the National Credit Union Administration, issued a request for information (RFI) regarding the customer identification program (CIP) requirement for depository institutions (referred to herein as banks) to collect tax identification numbers (TINs).Comments are due by May 28, 2024.


District Court Finds Communications Decency Act Provides Automotive Device Manufacturer Immunity for Clean Air Act Violations

On March 28, 2024, in US v. EZ Lynk, the U.S. District Court for the Southern District of New York dismissed the Department of Justice’s (DOJ) claim that an automotive device manufacturer violated Section 203 of the Clean Air Act (CAA), holding that Section 230 of the Communications Decency Act (CDA) provided complete immunity from CAA liability for the sale of certain aftermarket automotive devices. This decision of first impression offers an important precedent in the automotive industry and beyond. The decision gives effect to the CDA as drafted and will make it significantly harder for the government to hold manufacturers and online retailers liable for content, including software, created and sold by third parties.


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Meet the Team

<a target=‘_blank’ href="">Kwaku A. Akowuah</a>

Kwaku A. Akowuah

Washington, D.C.
<a target=‘_blank’ href="">Sheila A.G. Armbrust</a>

Sheila A.G. Armbrust

San Francisco
<a target=‘_blank’ href="">Francesca Blythe</a>

Francesca Blythe

<a target=‘_blank’ href="">Colleen Theresa Brown</a>

Colleen Theresa Brown

Washington, D.C.
<a target=‘_blank’ href="">John M. Casanova</a>

John M. Casanova

<a target=‘_blank’ href="">Thomas D. Cunningham</a>

Thomas D. Cunningham

<a target=‘_blank’ href="">Sharon R. Flanagan</a>

Sharon R. Flanagan

San Francisco, Palo Alto
<a target=‘_blank’ href="">David A. Gordon</a>

David A. Gordon

<a target=‘_blank’ href="">Tomoki Ishiara</a>

Tomoki Ishiara

<a target=‘_blank’ href="">Robert D. Keeling</a>

Robert D. Keeling

Washington, D.C.
<a target=‘_blank’ href="">Amy P. Lally</a>

Amy P. Lally

Century City
<a target=‘_blank’ href="">David C. Lashway</a>

David C. Lashway

Washington, D.C.
<a target=‘_blank’ href="">William RM Long</a>

William RM Long

<a target=‘_blank’ href="">Joan M. Loughnane</a>

Joan M. Loughnane

New York
<a target=‘_blank’ href="">Geeta Malhotra</a>

Geeta Malhotra

<a target=‘_blank’ href="">Glenn G. Nash</a>

Glenn G. Nash

Palo Alto
<a target=‘_blank’ href="">Rollin A. Ransom</a>

Rollin A. Ransom

Los Angeles
<a target=‘_blank’ href="">Alan Charles Raul</a>

Alan Charles Raul

Washington, D.C., New York
<a target=‘_blank’ href="">Jennifer B. Seale</a>

Jennifer B. Seale

Washington, D.C.
<a target=‘_blank’ href="">Yuet Ming Tham</a>

Yuet Ming Tham

Singapore, Hong Kong
<a target=‘_blank’ href="">Jonathan M. Wilan</a>

Jonathan M. Wilan

Washington, D.C.
<a target=‘_blank’ href="">John W. Woods Jr.</a>

John W. Woods Jr.

Washington, D.C.


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