Earlier this month, the Cybersecurity & Infrastructure Security Agency (CISA), in collaboration with the National Security Agency and other international partners, released guidance for organizations on adopting agentic artificial intelligence systems (i.e., systems composed of one or more agents that fundamentally rely on an AI model, such as an LLM, to interpret and reason about
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FTC Settles with Shutterstock Over Subscription Practices
On May 13, 2026, the Federal Trade Commission (“FTC”) announced that Shutterstock, Inc. had agreed to a $35 million settlement resolving allegations that the company engaged in unfair and deceptive subscription practices. The FTC asserted claims under Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act (“ROSCA”), alleging that Shutterstock charged…
EU AI Act Update: Timeline Relief, Targeted Simplification, and New Prohibitions
On 7 May 2026, negotiators from the Council of the European Union, the European Parliament, and the European Commission reached a provisional agreement on the terms of the Digital Omnibus on AI, marking the first set of amendments to the EU AI Act since its adoption in June 2024. The final package of amendments reflects…
Brazil’s House Approves New Critical and Strategic Minerals Legal Framework
On May 6, 2026, Brazil’s House of Deputies approved the text of the Critical and Strategic Minerals Bill. The bill establishes a new legal framework for critical and strategic minerals production with a focus on national security, local manufacturing, and sustainability. The bill was approved with wide political support and was sent to the Federal…
Italian DPA Publishes Guidelines on Email Tracking Pixels
On April 17, 2026, the Italian data protection authority (the “Garante”) published Provision No. 284 setting out guidelines on the use of “tracking pixels” in emails (the “Guidelines”). This publication closely follows the recommendation issued by the French data protection authority on the same topic, which is discussed in a separate blog post available here…
Today’s Press Release Could Be Tomorrow’s Subpoena: Bracing For the Possibility of Democratic Congressional Investigations
With fewer than 180 days until the midterm elections, Democratic Members of Congress are laying the groundwork for future congressional investigations in the event the party regains control of one or both chambers next year. Even as Democratic Members prepare for the possibility of winning the majority, developments such as the Virginia Supreme Court’s redistricting…
Proposed Rule Issued to Implement Expanded FOCI Disclosure and Risk Mitigation Requirements for Defense Contractors
On May 7, 2026, the Department of Defense (“DoD”) issued a proposed rule that would fundamentally expand the scope of foreign ownership, control, or influence (“FOCI”) disclosure and risk mitigation requirements for a significant number of companies that serve the national defense. The proposed rule, together with DoD Instruction (“DoDI”) 5205.87 (issued in 2024), would…
Senate Judiciary Committee Advances GUARD Act Regulating Minor Use of AI
On April 30, 2026, the U.S. Senate Judiciary Committee unanimously advanced S. 3062, the Guidelines for User Age-verification and Responsible Dialogue Act of 2025 (the “GUARD Act”), marking a significant development in federal efforts to regulate certain uses of artificial intelligence (AI) involving minors. The bill now awaits consideration by the full Senate.
Senators…
Tax-Exempt Organizations: Treasury Announces IRS Plans to Revise Form 990
On April 23, 2026, the U.S. Department of the Treasury announced that the IRS plans to revise the Form 990 to improve transparency and provide clearer reporting on certain transactions of 501(c)(3) organizations, including government contracts, government grants, and fiscal sponsorship arrangements. In this alert, we provide a summary of the announcement, an estimate…
Important Projects of Common European Interest (IPCEIs) on Artificial Intelligence and Compute Infrastructure Continuum
EU Member States are currently designing two possible new Important Projects of Common European Interest (“IPCEIs”) to support the development of AI and compute infrastructure in the EU (together the “Digital IPCEIs”), subject to European Commission (“Commission”) approval.
On 10 March 2026, the “matchmaking” phase under the IPCEI on Artificial Intelligence (“IPCEI-AI”) was officially launched…