Oct. 29, 2025

California’s Landmark AI Transparency Law: Covered Entities, Reporting Requirements and Penalties

California’s new Transparency in Frontier Artificial Intelligence Act (TFAIA), signed into law last month, is the first law in the nation to impose transparency and safety obligations on certain developers of frontier AI models. The law, effective January 1, 2026, aims to highlight these models’ potential to create catastrophic risk that could result in critical safety incidents. This first article in a two-part series discusses to whom the TFAIA applies and examines the law’s reporting requirements, protections, exceptions and penalties, with commentary from AI law practitioners and former regulators at Crowell & Moring, Jones Walker, Mayer Brown, Skadden and Womble Bond Dickinson. Part two will provide practical steps covered companies can take to comply with the TFAIA. See “AI Governance: Striking the Balance Between Innovation, Ethics and Accountability” (Feb. 12, 2025).

Tackling Issues That Arise When Cybersecurity Collides With Bankruptcy

Cybersecurity issues are encountered at every stage of insolvency and, in some cases, can trigger a bankruptcy filing as well. From pre-filing vulnerabilities to protecting data during proceedings to impact on asset sales, these challenges demand proactive planning. This article examines pre-bankruptcy cybersecurity complexities, steps that parties can take to protect their data, both prior to and during bankruptcy proceedings, and cybersecurity considerations that arise during the sale process. See our two-part series on the sale of 23andMe’s genetic data: “Implications of the Motions for a Privacy Ombudsman and State Laws” (Apr. 16, 2025), and “Lessons for Companies Around Sensitive Data” (Apr. 23, 2025).

Risk and Compliance Survey Highlights the Role of Compliance in AI Governance

Compliance programs continue to mature, with teams’ responsibilities expanding to encompass AI governance and other topics as enforcement priorities shift, according to the recent NAVEX 2025 State of Risk & Compliance Report (Survey). Privacy and cybersecurity rank among the most important compliance issues facing organizations, the Survey reflects. This article synthesizes the Survey findings, based on responses obtained in cooperation with The Harris Poll, and the insights offered during a related webinar hosted by NAVEX. See “NAVEX Statistics on Internal Reporting and Substantiation” (Apr. 30, 2025).

Wiley Welcomes Former Google and FBI Cybersecurity Leader As Special Counsel

Erin Joe has joined Wiley as special counsel in the firm’s privacy, cyber and data governance practice. Most recently, Joe served as a cybersecurity readiness senior executive in Google Cloud’s office of the CISO. For insights from Wiley, see “Texas Adds New Type of State AI Law to U.S. Regulatory Mix” (Jul. 16, 2025); and “Prioritizing Public-Private Partnerships in an Increasingly Complex Regulatory Environment” (Mar. 2, 2022).