AI and White Collar Crime: Enforcement Trends, AI-Washing Liability, and Building a Compliance Framework

Jennifer Kennedy Park and Matthew M. Yelovich, partners at Cleary Gottlieb Steen & Hamilton LLP, will walk through how AI-related white collar enforcement has evolved across administrations, covering both AI-enabled fraud schemes and "AI-washing" cases where companies misrepresent AI capabilities to investors. Drawing on DOJ and SEC actions including the first criminal AI-washing indictment under the Trump administration and DOJ's AI-powered healthcare fraud takedown, they will explain how enforcement is increasingly being shaped by executive policy rather than clear statutory frameworks. Attorneys will leave with a practical understanding of current criminal exposure risks and what strong AI compliance and governance programs should address.

The Criminal Law Section is chaired by Michael Freedman and Yan Goldshteyn.