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New U.S. Export Controls on Advanced Computing Items and Artificial Intelligence Model Weights: Seven Key Takeaways

On January 15, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) published in the Federal Register updated export controls on advanced computing items (including advanced integrated circuits (ICs) and related equipment, software, and technology) and, for the first time, controls on artificial intelligence (AI) model weights under the Export Administration Regulations (EAR). These new regulations were published as an interim final rule and took effect on January 13, 2025, although compliance is not required until May 15, 2025. BIS also published in the Federal Register a smaller companion rule on January 16, 2025, that expands licensing requirements on foundries and packaging companies seeking to export advanced computing equipment and requires compliance by January 31, 2025.

Action Items for U.S. Public Companies for 2025

Rapid rulemaking and aggressive enforcement by the SEC, combined with legislative, judicial, and regulatory developments, have created new requirements and expectations for U.S. public companies.

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2025 Will Be a Brave New Tokenized World

Tokenization of real-world assets (RWAs) is revolutionizing the way we perceive and manage assets. “Tokenized RWAs,” or more simply the digital representation of physical or intangible assets using a token recorded on a blockchain, allows for the efficient recording, trading, transferring, and managing of tangible assets in a digital format.

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Spotlight on Women in Privacy: Nathalie Barrera

Check out the December issue of Spotlight on Women in Privacy, featuring Nathalie Barrera. Nathalie discusses her role as a privacy attorney at Palo Alto Networks, the importance of continuous learning, and some of the key developments she will be watching out for.

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U.S. Department of Commerce Seeks to Protect Drones Supply Chain From Foreign Adversaries

On January 3, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) Office of Information and Communications Technology and Services (OICTS) published an Advance Notice of Proposed Rulemaking (ANPRM) on the national security risks posed by foreign adversary involvement in the supply chain for unmanned aerial systems (UAS) (i.e., drones), including risks to critical infrastructure and U.S. sensitive data. BIS seeks public input to inform regulations on the supply of certain UAS components developed by entities linked to the People’s Republic of China (China) and Russia.

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Colorado Finalizes Privacy Act Rules: Key Updates for Businesses

The new year brings with it several state privacy law developments, including the effective dates for comprehensive privacy legislation in Delaware, Iowa, Nebraska, New Hampshire and New Jersey.  Among this flurry of new state law obligations, however, privacy officers should not lose sight of continuing developments in states that helped pioneer the wave of state privacy laws, such as in Colorado.

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UK Operational Resilience Rules: Are You Ready for 31 March 2025?

Several categories of UK financial services firms, including banks, insurers, electronic money institutions, and payment institutions, are required to comply with new requirements on operational resilience beginning 31 March 2025.

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NHTSA Proposes Sweeping Voluntary Program for Vehicles With Automated Driving Systems

On December 19, 2024, the Chief Counsel of the U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA or the Agency) signed a notice of proposed rulemaking (NPRM) in which the Agency proposed a sweeping voluntary program relating to the evaluation and oversight of motor vehicles equipped with automated driving systems (ADS). NHTSA defines ADS-equipped vehicles, which can also be called autonomous vehicles (AVs), as vehicles designed to fully perform the driving task without any expectation of an attentive human driver.

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