Source: JD Supra

The AI Quarterly aggregates the firm’s AI‑focused insights, recent regulatory and enforcement developments, and upcoming events. The FBI’s April 6, 2026 release of the 2025 IC3 Annual Report documents for the first time the expanding use of AI by cybercriminals—citing over 22,000 complaints referencing AI and adjusted losses exceeding $893 million—and highlights AI‑enabled phishing, synthetic video, and voice cloning. On March 26, 2026 a bipartisan group of U.S. lawmakers introduced H.R.8094, the AI Foundation Model Transparency Act, which would require disclosure by developers of certain large models regarding training, design purpose, limitations, risks, and evaluation/monitoring practices without imposing direct regulatory controls.

Multiple policy and enforcement actions are summarized from early 2026: the NAIC Spring National Meeting (March 22–25, 2026 in San Diego) focused on oversight of third‑party data and models, insurer AI use, cybersecurity preparedness, and consumer privacy; California’s Governor signed Executive Order N‑5‑26 on March 30, 2026 directing responsible procurement and deployment of generative AI across state agencies with most deliverables due within 120 days; and the Trump Administration released a National Policy Framework for AI on March 20, 2026, which aligns broadly with Senator Marsha Blackburn’s March 18, 2026 Trump America AI Act discussion draft but diverges on copyright, developer liability, and repeal of Section 230. The European Data Protection Board and EDPS issued a joint opinion on March 10, 2026 regarding the proposed EU Biotech Act and its AI implications for clinical trials. Google Threat Intelligence Group reported state‑sponsored misuse of Gemini by actors from North Korea, Iran, China, and Russia to support coding, reconnaissance, vulnerability research, malware development, and post‑compromise activity. The Southern District of New York ruled on February 10, 2026 that documents produced using a commercial AI tool did not retain attorney‑client privilege despite privileged inputs. Additional items covered include California Attorney General Rob Bonta’s January 28, 2026 investigative sweep into “surveillance pricing,” the Spanish DPA’s early January 2026 guidance on image uploads to generative AI tools, the FTC’s December 22, 2025 decision to set aside its 2024 consent order against Rytr, and New York’s RAISE Act enacted December 19, 2025 (effective March 19, 2026) imposing obligations on certain large AI model developers. The publication concludes with a standard disclaimer that its general updates are not a substitute for tailored legal advice.