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AI Trends for 2026 – Return of the Brussels Effect: AI Transparency Requirements Come to California

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Recently-enacted AI transparency regulations took effect in California on January 1, 2026. To enterprises with a global...

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We are Morrison Foerster — a global firm of exceptional credentials. Our clients include some of the largest financial institutions, investment banks, and Fortune 100, technology, and life sciences companies. Our lawyers are committed to achieving innovative and business-minded results for our clients, while preserving the differences that make us stronger.Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Prior results do not guarantee a similar outcome.

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Recently-enacted AI transparency regulations took effect in California on January 1, 2026. To enterprises with a global footprint, these California regulations will bear a striking resemblance to transparency obligations under the EU AI Act. Although these laws differ from EU law, examining them together enables enterprises to implement globally-applicable AI compliance programs. Read the <a href="https://mofotech.mofo.com/topics/ai-trends-for-2026-return-of-the-brussels-effect-ai-transparency-requirements-come-to-california" target="_blank">full blog post</a>.

AI Trends for 2026 – Return of the Brussels Effect: AI Transparency Requirements Come to California

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Justin Haan is the chair of the firm's Technology Transactions Group, advising leading technology industry pioneers to help them navigate their most critical IP and technology needs.Justin’s practice focuses on transactions and counseling involving intellectual property and technology, including licensing arrangements, technology transfers, and joint development activities. Justin structures, drafts, and negotiates a wide range of commercial agreements, including software and content licenses, service agreements, reseller arrangements, and collaboration, manufacturing, supply and distribution agreements. He advises clients on the development, procurement and commercialization of cutting-edge technologies, including artificial intelligence, machine learning, augmented/virtual reality, semiconductors, data centers, cloud computing services, autonomous vehicles, and unmanned aircraft systems.  Justin also counsels clients on open source software, complex patent-related transactions, and the intellectual property aspects of M&A transactions. Justin’s experience includes advising OpenAI, Arm, Autodesk, Meta, Salesforce, SoftBank, Unity, and others on the IP aspects of complex projects involving cutting-edge technologies and fast-evolving areas of law. Justin serves on the firm’s AI industry committee, where he helps to lead and collaborate with attorneys across multiple practices on the rapid advances of generative AI. Justin is also a sought–after speaker and thought leader on artificial intelligence and has spoken at SXSW on the subject of multimodal AI.Before joining the firm, Justin was an intellectual property associate in the New York office of another global law firm.Justin received his J.D., with a certificate in law and technology, from the University of California, Berkeley School of Law, where he won the Prosser Prize in intellectual property in the entertainment industries and was an articles editor for the Berkeley Technology Law Journal. He received his A.B. from Harvard University.

Justin Haan

Chair of Technology Transactions Practice

Marijn Storm specializes on the intersection of law and technology, with a focus on cutting-edge technologies, such as (generative) artificial intelligence (AI) and large language models, ethical tech, and biometrics. Based in Morrison Foerster’s Amsterdam office, he advises global companies and organizations on a wide range of their most complex and pressing privacy and data security challenges.Marijn’s deep experience in both law and technology enables him to navigate the rapidly evolving landscape of privacy, data security, and technological innovation. Bridging the gap between legal requirements and technological advancements, Marijn advises and educates in-house legal teams on how to effectively manage and oversee technical applications such as AI and, specifically, generative AI. In addition, Marijn trains technical teams on implementing technical solutions in a privacy-by-design fashion, enabling compliance with AI and data protection laws around the world.Marijn also represents clients in class action and other litigation. For example, he has defended both digital advertising and public health clients against claims of alleged GDPR violations. In addition, he counsels clients on investigating and responding to major cybersecurity and ransomware incidents, including notification and related obligations. Marijn has also assisted a number of companies in obtaining regulatory approval for their Binding Corporate Rules, in both the EU and the UK.A recognized thought leader, Marijn regularly speaks at international data protection conferences (including IAPP) on topics such as the future of behavioral biometrics, the ethical application of AI, and developments in EU class actions. Marijn frequently publishes articles and client alerts on a variety of evolving topics, such as the EU AI Act and the NIST AI Risk Management Framework. Since 2019, he has been a guest lecturer at the Tilburg Institute for Law, Technology, and Society, where he teaches Algorithmic Accountability within the biannual course on AI & Law.Marijn is a Dutch-qualified lawyer and is fluent in Dutch and English.

Marijn Storm

Partner

Marisa is an associate in the Technology Transactions Group of Morrison Foerster’s San Francisco office.Marisa’s practice focuses on transactions involving a broad range of intellectual property and technology. She advises clients in the artificial intelligence, enterprise software, and digital media industries. She also provides product counseling on technology development and deployment.Prior to law school, Marisa worked at a global consulting firm, focusing on communications, media, and high-technology clients.Marisa earned her J.D. from Stanford Law School and her LL.M. in European and international business law from the University of Vienna. She also holds a B.A. from Georgetown University.