BurgherGray Newsletter

On March 13, 2024, Utah passed a groundbreaking law—the Utah Artificial Intelligence Policy Act (“UAIP”)—that imposes new disclosure obligations on businesses utilizing generative AI. This includes mandatory disclosures when interacting with customers, but that’s not the most demanding new rule. Under the UAIP, covered businesses cannot blame AI for any consumer protection breaches that result from the use of AI tools to enhance their own products and services.

The Corporate Transparency Act (the “CTA”) went into effect on January 1, 2024, and requires “reporting companies” in the United States to disclose certain types of information about their “beneficial owners” (“BOI Report(s)”) to the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”).

On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) of the U.S. Treasury took a decisive step toward expanding the compliance obligations of certain types of investment advisers. By withdrawing its 2015 proposal and introducing a new set of proposed rules (the “Proposed Rules”), FinCEN aims to strengthen Anti-Money Laundering/Counter-Terrorist Financing (“AML/CTF”) measures among Registered Investment Advisers (“RIAs”) and SEC Exempt Reporting Advisers (ERAs). This update signifies a broadening of the scope for AML obligations, marking the first time ERAs have been explicitly included under such regulatory requirements.