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Sam Jungyun Choi

Recognized by Law.com International as a Rising Star (2023), Sam Jungyun Choi is an associate in the technology regulatory group in Brussels. She advises leading multinationals on European and UK data protection law and new regulations and policy relating to innovative technologies, such as AI, digital health, and autonomous vehicles.

Sam is an expert on the EU General Data Protection Regulation (GDPR) and the UK Data Protection Act, having advised on these laws since they started to apply. In recent years, her work has evolved to include advising companies on new data and digital laws in the EU, including the AI Act, Data Act and the Digital Services Act.

Sam's practice includes advising on regulatory, compliance and policy issues that affect leading companies in the technology, life sciences and gaming companies on laws relating to privacy and data protection, digital services and AI. She advises clients on designing of new products and services, preparing privacy documentation, and developing data and AI governance programs. She also advises clients on matters relating to children’s privacy and policy initiatives relating to online safety.

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On 3 June 2026, the European Commission published several legislative and policy measures wrapped up in one “tech sovereignty” package (see our posts summarising the package as a whole here, and diving deeper into the Cloud and AI Development Act here). But the EU’s tech sovereignty drive has a long history, and is by no means limited to this package. In this post, we take a closer look at the current and forthcoming EU legislative measures aimed at increasing the resilience of services provided in the EU against external, malicious influence, a key aspect of tech sovereignty. Relevant legislation falls into two broad categories: (1) laws promoting cyber resilience generally, to prevent malicious actors from disrupting services and critical infrastructure; and (2) laws focused on building supply chain resilience and reducing dependencies on certain external actors by building European industrial capacity in key tech sectors. … Continue Reading Looking beyond the tech sovereignty package: how the EU is moving to ensure tech sector resilience

Since our prior post on Singapore’s Model AI Governance Framework for Agentic AI, Singapore’s Infocomm Media Development Authority (“IMDA”) has published an updated version (Version 1.5) (the “Updated Framework”), incorporating feedback from over 60 organizations.

The Updated Framework, published on May 20, 2026, retains the same four-pillar structure—(1) assess and bound the risks upfront, (2) make humans meaningfully accountable, (3) implement technical controls and processes, and (4) enable end-user responsibility—but expands the guidance in several notable respects. These include a new discussion of multi-agent systemic risks, more granular guidance on technical controls, and real-world case studies illustrating how the Framework can be applied across sectors. We summarize some of the key updates below.

Continue Reading Singapore Updates Model AI Governance Framework for Agentic AI

On 19 May 2026, the European Commission published its long-awaited draft, non-binding guidelines on the classification of high-risk AI systems (“HRAIs”) under the EU AI Act (the “Guidelines”). Across three documents—covering general principles, high-risk classification in the context of regulated products (Annex I), and high-risk use cases (Annex III)—the Commission sets out its approach to one of the AI Act’s central questions: when does an AI system fall within the high-risk regime (and, just as importantly, when does it not)?

Continue Reading EU AI Act Update: The European Commission Publishes Draft Guidelines on HRAIs

On May 8, 2026, the European Commission (“Commission”) published draft guidelines (“Guidelines”) on the implementation of the transparency obligations under Article 50 of the EU Artificial Intelligence Act (“AI Act”), opening a targeted consultation that runs until June 3, 2026.

The Guidelines are non-binding, but they are the first Commission instrument to provide interpretive guidance across the full scope of Article 50. They were prepared in parallel with the related, but more narrowly scoped, Code of Practice on Transparency of AI-Generated Content (“Code of Practice” or “Code”), the second draft of which was published on March 5, 2026.

Continue Reading 10 Takeaways: European Commission Draft Guidelines on AI Transparency under the EU AI Act

International regulators are finalizing the first global safety standards for Automated Driving Systems (“ADS”). In January, the UN Working Party on Automated/Autonomous and Connected Vehicles (“GRVA”) approved a draft UN Regulation (“UNR”) under the 1958 Agreement and a draft Global Technical Regulation (“GTR”) under the 1998 Agreement, submitting both for adoption by the UN World Forum for Harmonization of Vehicle Regulations.

Developed in parallel to ensure harmonized technical requirements across jurisdictions, the UNR and GTR are expected to be adopted at the 199th WP.29 session in June 2026. In the meantime, work continues on finalizing the accompanying Guidance and Interpretation Document. This post provides an overview of the UN regulatory framework, the legislative status of the ADS instruments as of May 2026, an outline of the key provisions, and implications for companies across the ADS value chain.

Continue Reading UN Regulation and GTR on Automated Driving Systems: Current State of Play

Artificial intelligence (“AI”) continues to reshape the UK financial services landscape in 2026, with consumers increasingly relying on AI-driven tools for financial guidance and firms deploying more autonomous systems across their businesses.

The Financial Conduct Authority (“FCA”), Prudential Regulation Authority (“PRA”) and Bank of England (“BoE”) (together “the Regulators”) have consistently signalled that AI will be overseen through existing regulatory frameworks, rather than through bespoke AI-specific rules. At the same time, political scrutiny is intensifying, supervisory expectations are rising, and the Regulators are investing heavily in sandbox initiatives and long-term reviews to test whether those frameworks remain fit for purpose.

This article explores the latest policy signals, supervisory initiatives and regulatory tools shaping the UK’s evolving approach to AI in financial services.

Continue Reading UK Financial Services Regulators’ Approach to Artificial Intelligence in 2026

On March 25, 2026, the UK’s Office of Communications (“Ofcom”) and the Information Commissioner’s Office (“ICO”) published a joint statement setting out their common expectations for age assurance on online services (“Joint Statement”). The Joint Statement is aimed at services likely to be accessed by children that fall within the scope of the Online Safety Act 2023 (“OSA”) and UK data protection legislation, and is designed to help providers comply with both their online safety and data protection obligations when deploying age assurance.

The Joint Statement arrives alongside a broader push from both regulators—including Ofcom’s recent call to action directed at major tech firms, an open letter from the ICO urging platforms to strengthen their age checks, and several enforcement actions by both regulators.

Continue Reading Ofcom and ICO Issue Joint Statement on Age Assurance

On March 2, 2026, the UK Department for Science, Innovation and Technology (“DSIT”) launched its consultation, titled “Growing up in the online world: a national conversation”. The consultation is open until 26 May 2026, after which the government will publish a summary of responses and its proposed approach. DSIT has indicated that it intends to move quickly on the consultation’s findings, drawing on newly granted powers that allow for accelerated implementation of online safety measures.

The consultation seeks views on a wide range of potential measures to strengthen children’s safety and wellbeing online, including more robust age‑assurance mechanisms, a statutory minimum age for social media, raising the UK’s age of digital consent, restrictions on certain features (such as livestreaming and disappearing messages), and new obligations for AI chatbots and generative‑AI services.

DSIT’s proposals could significantly expand regulatory expectations beyond the Online Safety Act 2023 (“OSA”)—including potential age‑based access limits (including differing safeguards as between teens and younger children), feature‑level restrictions, and enhanced duties for AI‑enabled services. Early engagement will be important to ensure that the government takes account of the views of affected service providers and understands the operational and technical implications of the measures proposed.

Continue Reading UK Government Launches Consultation on Children’s Online Experiences, Including New Obligations for AI

On 8 October 2025, the European Commission published its Apply AI Strategy (the “Strategy”), a comprehensive policy framework aimed at accelerating the adoption and integration of artificial intelligence (“AI”) across strategic industrial sectors and the public sector in the EU.

The Strategy is structured around three pillars: (1) introducing sectoral flagships to boost AI use in key industrial sectors; (2) addressing cross-cutting challenges; and (3) establishing a single governance mechanism to provide sectoral stakeholders a way to participate in AI policymaking.

The Apply AI Strategy is accompanied by the AI in Science Strategy, and it will be complemented by the Data Union Strategy (which is anticipated later this year).

Continue Reading European Commission Publishes Apply AI Strategy to Accelerate Sectoral AI Adoption Across the EU

On June 26, 2025, the European Parliament’s Committee on Employment and Social Affairs published a draft report (“Draft Report”) recommending that the Commission initiate the legislative process for an EU Directive on algorithmic management in the workplace.  The Draft Report defines algorithmic management as the use of automated systems—including those involving artificial intelligence—to monitor, assess, or make decisions affecting workers and solo self-employed persons.

This Draft Report follows a Commission study published in March 2025 (“Commission Study”), which found that while existing EU legislation, such as the GDPR, addresses some risks to workers from algorithmic management, others remain.  The Commission Study also recognizes that the AI Act does not establish specific rights for workers in the context of AI use, which is noted as a concern.

The Draft Report encloses the proposed text for a new Directive on algorithmic management in the workplace (“Proposed Directive”).  The Draft Report has not yet been endorsed by the European Parliament.

Continue Reading European Parliament Committee Recommends Commission to Propose EU Directive on Algorithmic Management