DROPLETS
Large AI frontier model developers with annual gross revenues exceeding $500 million must prepare for Illinois' 2028 mandate requiring independent third-party audits of their AI risk management frameworks, marking a shift from self-reported to verified AI compliance.
Illinois has enacted the Artificial Intelligence Safety Measures Act (AISMA), a first-of-its-kind U.S. state AI regulation targeting frontier models trained with more than 10^26 floating-point operations, with core obligations applying to large frontier developers with over $500 million in annual gross revenue. Unlike prior U.S. and global AI rules focused on internal documentation and self-reported risk disclosures, AISMA mandates independent third-party verification of developers’ required Frontier AI Frameworks, plus quarterly reporting to state regulators and public transparency disclosures for new or modified frontier models. Covered developers should begin mapping existing AI risk processes to AISMA requirements, identify qualified independent auditors, and build compliance timelines ahead of the January 1, 2028 effective date.
Multinational manufacturers and exporters must map exposure as MOFCOM gains authority to probe foreign trade restrictions and discriminatory practices targeting Chinese supply chains.
On June 24, 2026, MOFCOM issued Announcement No. 24, operationalizing the State Council's March 2026 Regulation on Industrial and Supply Chain Security. The Measures create a formal investigation mechanism targeting two categories of conduct: discriminatory or restrictive measures imposed by foreign governments or international organizations on Chinese supply chains, and actions by foreign organizations or individuals that disrupt transactions with Chinese entities or adopt discriminatory practices causing substantial harm. MOFCOM may initiate investigations ex officio or based on stakeholder submissions, assessing impacts on critical materials, technology, capital, data, personnel, logistics, finance, and information flows. A cross-departmental coordination mechanism led by the State Council—spanning MOFA, NDRC, MIIT, Customs, and the Cyberspace Administration—signals a whole-of-government enforcement posture. Companies with significant China-based operations, suppliers, or customers should assess contractual exposure, document supply chain dependencies, and prepare for potential in
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ISO-NE, its participating transmission owners, and New England large load customers must respond to FERC’s show cause order, which could overhaul regional transmission interconnection, cost allocation, and service rules for large energy users.
On June 18, 2026, FERC issued a Section 206 show cause order to ISO-NE and its participating transmission owners, preliminarily finding the grid operator’s tariff unjust and unreasonable for failing to address large load interconnection and study processes, cost-shifting mitigation for required network upgrades, co-location service terms, flexible transmission options for load curtailment, and generation study rules for electrically proximate loads of 50 MW or greater. ISO-NE and transmission owners have until August 17, 2026, to submit responses justifying existing terms or proposing revisions, plus a 30-day informational report on generation availability for large loads. Stakeholders may weigh in on filings within 30 days of submission, and parties may request a 90-day abeyance to develop formal Section 205 tariff changes via stakeholder processes.
In-house counsel leading product, risk, and litigation teams for goods manufacturers and distributors must act, as courts broadening the legal definition of ‘product’ are exposing firms to far larger unanticipated liability verdicts.
A 2026 Chambers and Partners Product Liability & Safety guide analysis highlights a growing judicial trend of expanding the legal definition of ‘product’ to include non-traditional items such as software components, bundled service offerings, and third-party add-ons paired with core physical goods. This shift has contributed to a surge in nuclear product liability verdicts, with juries awarding nine-figure damages in cases that would have historically been dismissed or settled for far lower amounts. In-house counsel should audit product lines, distribution agreements, and warranty terms to identify exposure gaps, and update risk mitigation protocols to account for the broader judicial interpretation of ‘product.’
In-house counsel leading corporate compliance, M&A, and competitive strategy must review this update to align business practices with the DOJ and FTC’s current enforcement priorities and investigative approaches.
This quarterly analysis covers Q2 2026 developments at the DOJ and FTC Antitrust Divisions, including updated enforcement priorities, revised investigative protocols, and leadership-driven policy shifts. It contextualizes ongoing agency investigations and forecasts near-term enforcement trends for corporate legal teams. In-house counsel can use these insights to refine antitrust compliance programs, pre-assess M&A deal risk, and develop targeted response strategies for potential agency inquiries.
In-house counsel for multinational corporations with cross-border investments must monitor this proposed reform, as it could reshape the investor-state dispute resolution framework and alter enforcement risks for overseas investments.
Co-authors of a recent Corporate Disputes article analyze the ICSID Secretariat’s proposed “inter se” modification pathway to introduce appellate review of investor-state dispute settlement (ISDS) awards, currently prohibited under the ICSID Convention. The piece breaks down the proposed opt-in treaty mechanism, its interaction with existing annulment procedures, and enforcement implications for both participating and non-participating states. Building on the authors’ prior analysis of UNCITRAL Working Group III ISDS reform proposals, the article notes the reform requires careful legal calibration to avoid disrupting the existing integrated treaty system.
Large AI frontier model developers with annual gross revenues exceeding $500 million must prepare for Illinois' 2028 mandate requiring independent third-party audits of their AI risk management frameworks, marking a shift from self-reported to verified AI compliance.
Illinois has enacted the Artificial Intelligence Safety Measures Act (AISMA), a first-of-its-kind U.S. state AI regulation targeting frontier models trained with more than 10^26 floating-point operations, with core obligations applying to large frontier developers with over $500 million in annual gross revenue. Unlike prior U.S. and global AI rules focused on internal documentation and self-reported risk disclosures, AISMA mandates independent third-party verification of developers’ required Frontier AI Frameworks, plus quarterly reporting to state regulators and public transparency disclosures for new or modified frontier models. Covered developers should begin mapping existing AI risk processes to AISMA requirements, identify qualified independent auditors, and build compliance timelines ahead of the January 1, 2028 effective date.
In-house counsel leading corporate compliance, M&A, and competitive strategy must review this update to align business practices with the DOJ and FTC’s current enforcement priorities and investigative approaches.
This quarterly analysis covers Q2 2026 developments at the DOJ and FTC Antitrust Divisions, including updated enforcement priorities, revised investigative protocols, and leadership-driven policy shifts. It contextualizes ongoing agency investigations and forecasts near-term enforcement trends for corporate legal teams. In-house counsel can use these insights to refine antitrust compliance programs, pre-assess M&A deal risk, and develop targeted response strategies for potential agency inquiries.
ISO-NE, its participating transmission owners, and New England large load customers must respond to FERC’s show cause order, which could overhaul regional transmission interconnection, cost allocation, and service rules for large energy users.
On June 18, 2026, FERC issued a Section 206 show cause order to ISO-NE and its participating transmission owners, preliminarily finding the grid operator’s tariff unjust and unreasonable for failing to address large load interconnection and study processes, cost-shifting mitigation for required network upgrades, co-location service terms, flexible transmission options for load curtailment, and generation study rules for electrically proximate loads of 50 MW or greater. ISO-NE and transmission owners have until August 17, 2026, to submit responses justifying existing terms or proposing revisions, plus a 30-day informational report on generation availability for large loads. Stakeholders may weigh in on filings within 30 days of submission, and parties may request a 90-day abeyance to develop formal Section 205 tariff changes via stakeholder processes.
Multinational manufacturers and exporters must map exposure as MOFCOM gains authority to probe foreign trade restrictions and discriminatory practices targeting Chinese supply chains.
On June 24, 2026, MOFCOM issued Announcement No. 24, operationalizing the State Council's March 2026 Regulation on Industrial and Supply Chain Security. The Measures create a formal investigation mechanism targeting two categories of conduct: discriminatory or restrictive measures imposed by foreign governments or international organizations on Chinese supply chains, and actions by foreign organizations or individuals that disrupt transactions with Chinese entities or adopt discriminatory practices causing substantial harm. MOFCOM may initiate investigations ex officio or based on stakeholder submissions, assessing impacts on critical materials, technology, capital, data, personnel, logistics, finance, and information flows. A cross-departmental coordination mechanism led by the State Council—spanning MOFA, NDRC, MIIT, Customs, and the Cyberspace Administration—signals a whole-of-government enforcement posture. Companies with significant China-based operations, suppliers, or customers should assess contractual exposure, document supply chain dependencies, and prepare for potential in
…
In-house counsel for multinational corporations with cross-border investments must monitor this proposed reform, as it could reshape the investor-state dispute resolution framework and alter enforcement risks for overseas investments.
Co-authors of a recent Corporate Disputes article analyze the ICSID Secretariat’s proposed “inter se” modification pathway to introduce appellate review of investor-state dispute settlement (ISDS) awards, currently prohibited under the ICSID Convention. The piece breaks down the proposed opt-in treaty mechanism, its interaction with existing annulment procedures, and enforcement implications for both participating and non-participating states. Building on the authors’ prior analysis of UNCITRAL Working Group III ISDS reform proposals, the article notes the reform requires careful legal calibration to avoid disrupting the existing integrated treaty system.
In-house counsel leading product, risk, and litigation teams for goods manufacturers and distributors must act, as courts broadening the legal definition of ‘product’ are exposing firms to far larger unanticipated liability verdicts.
A 2026 Chambers and Partners Product Liability & Safety guide analysis highlights a growing judicial trend of expanding the legal definition of ‘product’ to include non-traditional items such as software components, bundled service offerings, and third-party add-ons paired with core physical goods. This shift has contributed to a surge in nuclear product liability verdicts, with juries awarding nine-figure damages in cases that would have historically been dismissed or settled for far lower amounts. In-house counsel should audit product lines, distribution agreements, and warranty terms to identify exposure gaps, and update risk mitigation protocols to account for the broader judicial interpretation of ‘product.’
Large AI frontier model developers with annual gross revenues exceeding $500 million must prepare for Illinois' 2028 mandate requiring independent third-party audits of their AI risk management frameworks, marking a shift from self-reported to verified AI compliance.
Illinois has enacted the Artificial Intelligence Safety Measures Act (AISMA), a first-of-its-kind U.S. state AI regulation targeting frontier models trained with more than 10^26 floating-point operations, with core obligations applying to large frontier developers with over $500 million in annual gross revenue. Unlike prior U.S. and global AI rules focused on internal documentation and self-reported risk disclosures, AISMA mandates independent third-party verification of developers’ required Frontier AI Frameworks, plus quarterly reporting to state regulators and public transparency disclosures for new or modified frontier models. Covered developers should begin mapping existing AI risk processes to AISMA requirements, identify qualified independent auditors, and build compliance timelines ahead of the January 1, 2028 effective date.