35 While artificial intelligence (AI) has been around for many years, the technology has exploded in both its use and development across virtually all industries in recent years. Although AI has the potential to be used in innovative and positive ways, it also can be used to perpetrate fraud and crime, cause discrimination and bias, promote and disseminate disinformation, violate personal privacy, and threaten national security. Thus, the rapid growth of AI technology and its associated risks has created an urgent need for regulation. Similar to data privacy laws, the European Union (EU) has led the way in efforts to regulate AI. In the U.S., there is no uniform federal law regulating AI nor is any such framework on the horizon. Thus, in addition to data privacy laws that apply to AI, individual state and local governments have begun enacting laws and regulations specifically addressing AI systems. These various laws, which differ in applicability and scope, create the possibility of there being a patchwork of overlapping and conflicting regulations and laws. It is important that entities doing business in the U.S. be vigilant about the various AI laws that may be applicable and ensure compliance. This advisory is intended to provide a broad summary of the AI regulatory landscape. European Union AI Act The EU’s Artificial Intelligence Act (the EU AI Act) was the first comprehensive legal framework for the regulation of AI systems, and is already becoming a The AI Regulatory Puzzle — from the EU to the U.S. Guy Ben-Ami Partner, Carter Ledyard
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