Debevoise’s AI practice is currently advising approximately 150 clients—including 100 financial services and insurance clients—on a broad range of AI issues, including: responding to AI regulatory exams; negotiation of complex AI data licensing agreements; AI deal diligence; board oversight responsibilities for AI risk; AI vendor risk management; AI policies and governance; AI data privacy and scraping issues; risk assessments for core AI use cases; managing bias risk for AI insurance underwriting and consumer credit; defending against deepfakes and other AI-enabled cybersecurity attacks; deploying customer-facing chatbots; implementing AI webmeeting tools (such as Zoom AI Companion and Teams Copilot for meeting summaries, transcriptions, and recordings); and training and deploying foundation models.

At the core of our practice is a dedicated team of several full-time AI lawyers, who are organized into specialized AI subject-matter teams and work closely with regulatory compliance experts in other practice groups who have the technical proficiency and government experience to help clients take a risk-based approach to applying existing laws to novel AI use cases and anticipate how new AI laws may be applied to our clients’ use of AI.

Debevoise’s AI team has also developed an innovative, monthly subscription-based Suite of Tools for Assessing AI Risk (STAAR). The legal industry has recognized the STAAR platform as a visionary model for AI legal services in the Law.com article, “Debevoise & Plimpton Is Building a New Model for Delivering AI Adoption Advice” and in the Law360 article, Debevoise Builds Tool To Help In-House Attys Assess AI Risk.

The STAAR platform contains continuously updated AI legal resources, including policies and training materials, governance lessons, regulatory trackers, and detailed descriptions of generic AI use cases, each of which has been vetted through the Debevoise AI Risk Assessment Tool (“DART”). Each DART use case provides the recommended AI tools and configurations; sample prompts, reference materials, and outputs; lists of applicable risks and corresponding mitigations; technical implementation suggestions; and guidance for pilot programs.

Our AI attorneys are frequently published and quoted in leading journals on AI issues, including The American Lawyer, Bloomberg, Law360, and Directors & Boards, and speak at major conferences—including SIFMA’s Annual Compliance Conference, Stanford Directors’ College, and the Society for Corporate Governance National Conference. The AI practice also spearheads Debevoise’s internal AI initiatives, involving the rigorous vetting, strategic piloting, and continuous refinement of numerous AI applications across the firm.

Debevoise’s Chambers-ranked artificial intelligence (AI) practice is the country’s premier AI practice for financial services and insurance clients. Our AI practice pairs the leaders of our Chambers Band 1 Securities Enforcement team, our Band 1 Insurance Regulatory practice, and our Band 1 Trademark and Copyright practice with our market-leading AI practice run by Avi Gesser, who is ranked Chambers Band 1 for AI and has more than a decade of experience advising financial services clients on AI issues. Debevoise’s AI practice is currently advising approximately 150 clients—including 100 financial services and insurance clients—on a broad range of AI issues, including: responding to AI regulatory exams; negotiation of complex AI data licensing agreements; AI deal diligence; board oversight responsibilities for AI risk; AI vendor risk management; AI policies and governance; AI data privacy and scraping issues; risk assessments for core AI use cases; managing bias risk for AI insurance underwriting and consumer credit; defending against deepfakes and other AI-enabled cybersecurity attacks; deploying customer-facing chatbots; implementing AI webmeeting tools (such as Zoom AI Companion and Teams Copilot for meeting summaries, transcriptions, and recordings); and training and deploying foundation models.At the core of our practice is a dedicated team of several full-time AI lawyers, who are organized into specialized AI subject-matter teams and work closely with regulatory compliance experts in other practice groups who have the technical proficiency and government experience to help clients take a risk-based approach to applying existing laws to novel AI use cases and anticipate how new AI laws may be applied to our clients’ use of AI. Debevoise’s AI team has also developed an innovative, monthly subscription-based Suite of Tools for Assessing AI Risk (STAAR). The legal industry has recognized the STAAR platform as a visionary model for AI legal services in the Law.com article, “Debevoise & Plimpton Is Building a New Model for Delivering AI Adoption Advice” and in the Law360 article, Debevoise Builds Tool To Help In-House Attys Assess AI Risk. The STAAR platform contains continuously updated AI legal resources, including policies and training materials, governance lessons, regulatory trackers, and detailed descriptions of generic AI use cases, each of which has been vetted through the Debevoise AI Risk Assessment Tool (“DART”). Each DART use case provides the recommended AI tools and configurations; sample prompts, reference materials, and outputs; lists of applicable risks and corresponding mitigations; technical implementation suggestions; and guidance for pilot programs.Our AI attorneys are frequently published and quoted in leading journals on AI issues, including The American Lawyer, Bloomberg, Law360, and Directors & Boards, and speak at major conferences—including SIFMA’s Annual Compliance Conference, Stanford Directors’ College, and the Society for Corporate Governance National Conference. The AI practice also spearheads Debevoise’s internal AI initiatives, involving the rigorous vetting, strategic piloting, and continuous refinement of numerous AI applications across the firm. Debevoise serves as trusted AI counsel to approximately 150 clients, including many of the world’s leading asset managers and broker-dealers, several major insurers, global consulting firms, and other market leaders. We provide practical advice on AI-related governance, regulatory, transactional, and litigation matters, from granular-level tool onboarding to enterprise-wide AI frameworks. Because of the number of years we have been advising on AI, and the number of clients we are helping, there are few, if any, issues we have not encountered. Our unparalleled insight enables us to provide valuable benchmarking, develop industry best practices, and accelerate responsible AI adoption without dramatically increasing risk. AI Advisory, Governance & Regulatory Readiness

AI Policies & Risk Management: More than 60 asset managers and broker-dealers and more than 40 other clients on implementing AI policies, creating AI governance committees, federal bank supervisory expectations concerning AI and data governance, AI vendor risk management, AI training and risk management, including for portfolio companies.

Insurance Regulatory Compliance: More than 20 leading insurance companies on AI governance, regulatory compliance (including drafting Colorado AI certifications), NYDFS Circular 7, the NAIC Model AI rules risk assessments, AI policies, AI vendor management, bias assessments and training, AI incident playbooks, AI tabletop exercises, and board briefings on AI risk and oversight.

Data Rights: More than a dozen clients, including several technology clients, on data rights considerations for GenAI and the EU AI Act.

AI Tool Adoption: Dozens of clients on the adoption of AI tools, including negotiating vendor contracts; conducting tool diligence from a cybersecurity and IP perspective, among others; developing governance processes covering pilot programs through enterprise-wide implementation, including oversight of functionality, use cases, recordkeeping considerations, and risk management.

Webmeeting Tools: More than 40 asset managers, broker-dealers, and public companies on AI webmeeting platforms, including the functionality, use cases, recordkeeping considerations, and risks associated with various platforms and governance approaches.

STAAR: Several clients—including a global investment bank, a major bank, and a multinational FinTech company—on identifying, evaluating, and managing the evolving legal and regulatory risks associated with the development and deployment of AI via our subscription-based Suite of Tools for Assessing AI Risk (STAAR).

Model Development: A Fortune 500 financial services company on a comprehensive range of AI issues relating to model creation and fine tuning, including customer service chatbots, privacy disclosures, UDAP compliance, model developer regulatory obligations, AI governance, licensing negotiations with foundation model providers, and EU Digital Operational Resilience Act and EU AI Act preparedness.

Cybersecurity: Several clients including one of the world’s leading investment banks and a leading U.S. life insurance provider with cybersecurity work related to AI implementation including deepfake training and simulations, development of AI incident response plans, advice regarding cyber risks in connection with use of LLMs for coding, and DFS cybersecurity regulation.

Antitrust: A private equity firm with respect to emerging risks related to algorithmic collusion and AI-related antitrust considerations.

Data Privacy: Several clients across industries including leading financial services providers and a major sports league on AI and data privacy issues concerning use of machine learning and big data technologies, including related to the Fair Credit Reporting Act and the Gramm-Leach-Bliley Act.

Ethics: A global fraud prevention platform in developing a comprehensive AI ethics and governance framework, including relevant policies and procedures, governing committees, trainings, board briefings, and AI tabletop exercises.

Model Training and Orchestration: Advising clients on deploying agents alongside complementary software designed to detect and escalate potential patterns of insider trading for review by committees of human evaluators.

Chatbots: Several clients in financial services and other industries on the development and deployment of external customer-facing chatbots, including regulatory compliance considerations, quality control measures, training and feedback loop design, governance of agentic functionality, and management of issues relating to the use of training data.

Employment & HR: Advising nearly 20 clients across industries on AI in workforce management, including deployment of AI-driven resume screening tools, attrition prediction and workforce analytics models, and automated performance review synthesis.

AI Investigations, Regulatory Examinations & Defense

Regulatory Examinations: Multiple asset managers, broker-dealers and public companies in regulatory examinations and enforcement matters related to use and marketing of AI and machine learning.

SEC Investigations: Several clients with SEC investigations including related to AI washing and use of AI to facilitate stock recommendations.

Internal Investigations: AI-related internal investigations including for a large software company regarding possible data theft and a global pharmaceutical company regarding AI-related IP theft and data loss prevention.

AI Transactions & Licensing

License and Reseller Agreements: Drafting and negotiating software license agreements; data license agreements—including strategy for licensing proprietary data to foundation model developers for AI training; and reseller agreements involving the use of AI.

M&A Diligence: AI deal diligence, including for J.P. Morgan Securities, as financial advisor to Salesforce, a customer relationship management technology company, in its acquisition of Informatica, an AI-powered enterprise cloud data management company, in a transaction valued at approximately $8 billion.

AI Model Provider Negotiations: Negotiating agreements with Microsoft, OpenAI, AWS and/or Google related to generative AI services, including for use of GitHub, Copilot, and OpenAI on behalf of clients including a major entertainment company and a Fortune 100 financial services company.

Contracts with Third-party AI Service Providers: Negotiating AI contracts with third-party AI service providers, including Palantir and Anthropic, and developing vendor risk management and contracting frameworks, including for a multinational technology company and a multinational insurance company.

AI Intellectual Property, Content & Litigation

IP Trademark and Brand Protection: Safeguarding IP associated with AI-related research and development, including revisions to contract terms and disclosures; advising several clients, including a global investment bank and a FINRA-registered broker-dealer, a major U.S. medical data provider, and a global print-on-demand platform, regarding the use of AI tools for product creation, brand protection, and infringement monitoring.

Copyright Litigation: Ongoing copyright litigation related to the training of certain AI models including by two U.S.-based foundation model providers for a leading American trade publishing company and a software company.

False Advertising: A digital coaching platform regarding an allegation about false advertising in relation to AI in litigation.

AI Policymaking & Regulatory Engagement

The Securities Industry and Financial Markets Association (SIFMA) and the Global Financial Markets Association (GFMA), leading trade associations that represent the financial services industry, in preparing comment letters regarding regulatory developments in cybersecurity, operational resilience and AI.

Multiple clients in providing comments to draft state and federal legislation concerning AI.

Artificial Intelligence