Lara Castellino

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For more insights and analysis from Cleary lawyers on policy and regulatory developments from a legal perspective, visit What to Expect From a Second Trump Administration.

On December 11, 2025, President Donald Trump signed an executive order titled Establishing A National Policy Framework For Artificial Intelligence (the “Order”)[1]. The Order’s policy objective is to “enhance the United States’ global AI dominance through a minimally burdensome national policy framework for AI”[2] and comes after Congress considered but did not advance federal legislation that would have preempted state AI regulation earlier this year. The Order justifies federal intervention on three grounds:

On September 29, 2025, Governor Gavin Newsom signed the Transparency in Frontier Artificial Intelligence Act (TFAIA, SB 53 or the Act)[1], establishing a comprehensive framework for transparency, safety and accountability in the development and deployment of the most advanced artificial intelligence models. Building upon existing California laws targeting AI such as AB 2013[2], the Act, which takes effect January 1, 2026 and imposes penalties up to $1 million per violation, creates immediate compliance obligations for AI developers of the most powerful frontier models.