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Virginia Poised to Become Second State to Enact Comprehensive AI Legislation

By Reena Bajowala & Wouter van Wengen on March 5, 2025
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On Feb. 20, 2024, the Virginia General Assembly passed the High-Risk Artificial Intelligence (AI) Developer and Deployer Act (HB 2094). If signed by Gov. Glenn Youngkin, Virginia would become the second U.S. state to implement a broad framework regulating AI use, particularly in high-risk applications. The bill is closely modeled on the CAIA and would take effect on July 1, 2026.

This GT Alert covers to whom the bill applies, important definitions, key differences with the CAIA, and potential future implications.

Click here to read the full GT Alert.

Tags: AI
Photo of Reena Bajowala Reena Bajowala

Reena R. Bajowala has deep experience with data security, information technology, and privacy law issues, and litigating class, collective, and plan-wide litigation. She is a Certified Information Privacy Technologist (CIPT), a Certified Information Privacy Professional – US (CIPP/US) and a Certified Information Privacy

…

Reena R. Bajowala has deep experience with data security, information technology, and privacy law issues, and litigating class, collective, and plan-wide litigation. She is a Certified Information Privacy Technologist (CIPT), a Certified Information Privacy Professional – US (CIPP/US) and a Certified Information Privacy Manager (CIPM). Through a competitive process, she was selected as a 2021-2023 Fellow of the American Bar Association’s Business Law Section with the Cyberspace Law Subcommittee.

When faced with a data breach, including in business email compromise, ransomware, or wire transfer fraud scenarios, clients turn to Reena to investigate, remediate, and comply with legal obligations. She regularly conducts risk assessments, develops privacy and information security compliance programs, and leads proactive planning for potential data security incidents, including drafting incident response plans, communications plans, and conducting tabletop exercises. In addition, Reena helps evaluate legal risks relating to emerging technologies, including artificial intelligence, connected devices, and drones.

Reena assists Employee Retirement Income Security Act (ERISA) benefit plan sponsors with implementing cybersecurity policies and service provider management programs. The Department of Labor’s current emphasis on cybersecurity allows Reena to utilize her combined decade-plus ERISA and benefit plan counseling and litigation experience and her deep cybersecurity and vendor management practice.

Reena has wide-ranging litigation and trial experience, including over 100 days of first-chair trial experience. She represents buyers and providers of IT services regarding issues ranging from billing and performance disputes arising from Master Services Agreements and Service Level Agreements to copyright and licensing disputes pursuant to Software Licensing and SaaS agreements. Reena also works to protect the interests of companies during software audits.

With a broad-based background in complex dispute resolution, Reena understands the intricacies of class, collective, and plan-wide litigation in the employment and consumer fraud spaces. She has deep experience with lawsuits involving ERISA, having represented plan sponsors and service providers in both benefits and fiduciary matters.

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Photo of Wouter van Wengen Wouter van Wengen

Wouter van Wengen is a member of the corporate practice in Greenberg Traurig’s Amsterdam office. He focuses his practice on intellectual property law, IT contracts and data protection law. He represents national and international clients in the creative sector, the technology industry…

Wouter van Wengen is a member of the corporate practice in Greenberg Traurig’s Amsterdam office. He focuses his practice on intellectual property law, IT contracts and data protection law. He represents national and international clients in the creative sector, the technology industry, and a variety of other companies.

Wouter holds an LL.M. degree in information law at the University of Amsterdam, and an LL.M. degree in Intellectual Property Law at Indiana University Maurer School of Law and is a member of the Dutch Bar Association.

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  • Posted in:
    Privacy & Data Security
  • Blog:
    Data Privacy Dish
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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