FinTech

Happy October and Cyber Awareness Month! While October ends with ghosts and goblins and other scary monsters for Halloween, the entire month of October is dedicated to raising awareness of cyber security and preventing (and if necessary responding to) cyber security incidents.

The Cybersecurity Information Sharing Act of 2015 (CISA 2015) expired on September 30, 2025, after Congress missed the reauthorization deadline. That lapse removes the decade-old legal framework that encouraged and protected cyber threat information sharing among companies, Information Sharing and Analysis Organizations and Centers (ISAOs/ISACs), and the federal government.

On September 1, 2025, Texas amended its telephone solicitation law to include text messages and to add several new requirements, including a registration requirement with the Texas Secretary of State, plus a form of security (such as a bond) in the amount of $10,000.

The global money laundering and terrorist financing watchdog and intergovernmental body FATF published new requirements for cross-border payments and virtual asset transfers.

On July 23, 2025, the White House released a sweeping new policy framework titled “Winning the AI Race: America’s AI Action Plan” (the “Plan”), describing the federal government’s approach to artificial intelligence (“AI”).

Over the past month, the SEC has taken a mixed approach to crypto exchange-traded products signaling both openness and ongoing caution. Through its public statements, delayed approvals, and procedural stays, the agency is clearly evaluating how crypto funds are structured and brought to market

As organisations continue with their roll-out of AI, the global regulatory landscape is becoming increasingly complex. AI-specific laws like the EU AI Act already applicable and new AI-specific laws are proposed, adding to the range of existing laws and regulations applicable to AI.

The biggest AI privacy problems no one is talking about: Installment 1: The Agent2Agent (“A2A”) Protocol
In the privacy world, everyone is focused on fairness, bias, and data scraping. These issues, however, are not even among the top 3 AI privacy issues. And it’s not even close.

On June 22, 2025, the Texas Governor signed the Texas Responsible Artificial Intelligence Governance Act (HB 149), which will go into effect on January 1, 2026. Although much of the new law will focus on government agencies, some provisions could have an impact on companies.

Key Takeaways:
• Clear Regulatory Guardrails: The GENIUS Act provides guardrails for payment stablecoins, including strict reserve, disclosure, and anti-money laundering standards.
• Federal and State Regimes: Both the federal government and states, with certain limitations, may regulate stablecoins.
• Securities Exemptions: Payment stablecoins issued by permitted issuers are explicitly excluded from being classified as securities or commodities under federal law.
• Consumer Protections: The Act provides strong consumer protections, including first-priority claims on reserves in insolvency and strict asset segregation requirements.