Artificial intelligence and digital marketing have become ubiquitous in real estate advertising. The widespread use of AI creates risk for consumers who don’t know whether images shown online or on the multiple listing services are real. A new California law that goes into effect in January 2026 tries to draw a clear line: innovation is welcome but deception is not. 

On December 18, 2025, President Donald Trump issued an Executive Order directing the United States Attorney General to expedite and complete its rulemaking process for reclassifying “marihuana” (today generally referred to as “cannabis”) as a Schedule III substance under the Controlled Substances Act (“CSA”). This Client Alert examines the Executive Order and the effects it may have on the state-legal cannabis industry if rescheduling comes to pass.

In furtherance of the Administration’s efforts to make the federal government the voice on artificial intelligence (AI), on December 11, 2025, President Trump issued an Executive Order (EO) titled “Ensuring a National Policy Framework for Artificial Intelligence” (the “Order”). This Order is aimed at advancing the federal government’s ambition to maintain U.S. global leadership in AI by preempting divergent state-level AI regulations and creating a cohesive national regulatory framework. As discussed below, this change is not simple, and businesses are well advised to follow these developments closely to minimize risks and maximize opportunities.

On December 4, 2025, U.S. Citizenship and Immigration Services (USCIS) updated its policy manual to reduce the maximum validity period for Employment Authorization Documents (EADs) for certain categories of noncitizens. The update also incorporates changes to these EAD validity periods made by recent legislation.

On November 4, 2025, the U.S. Court of Appeals for the Eleventh Circuit issued a long-anticipated decision in Shen v. Simpson, upholding the constitutionality of a Florida law, SB 264, which restricts ownership of or investment in Florida real estate by individuals “domiciled” in the People’s Republic of China and to a lesser extent, other countries of concern (which are identified in the statute as Russia, North Korea, Iran, Cuba, Venezuela and Syria) who are not American citizens or green card holders. The restriction encompasses residential, commercial and agricultural real estate. Oral argument in the case was held on April 19, 2024, and it took the court almost one year and seven months to issue its opinion, an unusually long turn-around time. 

The Trump Administration’s Genesis Mission, which President Trump established by Executive Order 14363 on November 24, 2025, marks the most consequential federal intervention in artificial intelligence (AI) to date, consolidating scientific datasets, supercomputing capacity, and national laboratory research assets into a unified, government-backed AI development platform. The initiative reflects a strategic shift toward federal coordination of frontier-level AI capabilities, with comparisons to the Manhattan Project, capturing the scale and urgency of this policy direction.

As 2025 draws to a close, the U.S. privacy landscape continues to evolve rapidly, with significant implications for how businesses handle consumer data and make use of artificial intelligence (AI). This year alone has seen the enactment of comprehensive privacy laws in eight (8) additional states, bringing the total to twenty (20) states with such legislation on the books. These laws impose strict privacy notice requirements that demand immediate attention to any company’s public facing privacy policy.

The Office of Foreign Assets Control of the United States Treasury Department (“OFAC”) announced on November 24, 2025 the imposition of a $4,677,552 financial penalty on a U.S. person (the “U.S. Person”) for violating U.S. sanctions against Russia. This action shows that notwithstanding energetic U.S. diplomatic efforts to end the armed conflict in Ukraine, enforcement of sanctions against the Russian Federation remains robust and could have serious financial repercussions for violators. Even individuals and businesses not focused on cross-border transactions on a day-to-day basis need to be alert to the risk of violating sanctions imposed on foreign countries and nationals.