Devika Kornbacher, Partner and Co-Head of the Global Tech Group and Dessislava Savova, Partner and Head of the Continental Europe Tech Group at Clifford Chance joined us to compare the EU-US regulatory approaches with respect to AI in financial services. Common themes in existing rules and standards include accountability, transparency and explainability. The proposed EU AI Act is the first comprehensive Regulation of AI which is expected to apply to all industries with very few exceptions and have extraterritorial reach. We anticipate a final version of the AI Act will be agreed by the beginning of 2024. In contrast, US regulators and policymakers are mainly relying on existing rules and regulation by enforcement, supplemented by frameworks on the horizon from several agencies. Globally we have seen different jurisdictions take different approaches with no globally agreed framework yet in place. We anticipate an EU-US code of conduct in the future.
