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Enforcement timeline
Chronologically-ordered enforcement actions linked to the instruments and topics tracked in the Policy Window catalog. Closed cases sort by their resolution year; ongoing cases sort by initiation. Each entry links to the catalog topics + the catalog instruments the case touches, and (where possible) to the best-available primary source for the action.
13 catalogued cases total · 4 match the current filter (topic = Individual Redress; instrument = Executive Order 14110 on Safe, Secure, Trustworthy AI) clear all.
Filters
Cases (4)
- Settlement with remedy
- Consent decree
- Ongoing
- Open arrow = ongoing (no resolution year yet)
- Consent decree
2022 → 2023 · US
EEOC v. iTutorGroup, Inc.
EEOC v. iTutorGroup (AI age-discrimination consent decree)
E.D.N.Y. · No. 1:22-cv-02565
Enforcer: Equal Employment Opportunity Commission (EEOC)
Target: iTutorGroup, Inc.
Violation alleged: iTutorGroup's recruiting software automatically rejected female applicants aged 55 and older, and male applicants aged 60 and older, regardless of qualifications.
Lesson: First US EEOC-as-party suit against an AI-mediated hiring tool resolved by consent decree ($365,000 settlement + 5-year monitoring; required revised non-discriminatory application processes; mandatory anti-discrimination training; right to re-apply for rejected applicants). Establishes that pre-AI civil-rights statutes (ADEA, Title VII, ADA) can be applied to algorithmic hiring outputs without requiring a dedicated AI statute — the load-bearing precedent for the US 'sectoral / ex-post liability' regime in employment AI.
Source: https://www.eeoc.gov/newsroom/itutorgroup-pay-365000-settle-eeoc-discriminatory-hiring-suitregulator landing
- Ongoing
2023 → ongoing · US
Mobley v. Workday, Inc.
Mobley v. Workday (US AI-hiring class action)
N.D. Cal. · No. 3:23-cv-00770
Enforcer: Private civil class action; EEOC amicus participation
Target: Workday Inc.
Violation alleged: Workday's algorithmic hiring tools allegedly screened out applicants on disability, age, and race. Class action seeks to certify Workday as an 'employment agency' under Title VII so disparate-impact theory applies to the algorithm's outputs rather than only its developers.
Lesson: First major US AI-hiring class action with EEOC amicus support. If Workday is certified as an 'employment agency', US sectoral approach (EEOC + Title VII) substantially expands AI-hiring liability without requiring an AI statute. This is the load-bearing test of whether US 'principles + ex-post liability' approach can substitute for EU AIA Annex III §4 (high-risk employment AI obligations).
Source: https://www.eeoc.gov/newsroom/eeoc-files-amicus-brief-supporting-mobley-v-workdayregulator landing
- Ongoing
2023 → ongoing · US
FTC investigation of OpenAI
Enforcer: Federal Trade Commission
Target: OpenAI
Violation alleged: Civil Investigative Demand alleging consumer-protection violations: misleading claims about ChatGPT capabilities, training-data privacy, and consumer harm from hallucinations.
Lesson: First US federal enforcement action against a frontier-AI developer. Establishes that pre-AI-statute consumer-protection authority (FTC §5) can be applied to AI services — supports the US 'sectoral / ex-post liability' regime (vs EU's ex-ante AIA). Action remains pending; no judgment yet.
Source: https://www.washingtonpost.com/technology/2023/07/13/ftc-openai-chatgpt-sam-altman-lina-khan/news secondary
- Settlement with remedy
2018 → 2022 · US
HUD / DOJ v. Facebook (ad-targeting Fair Housing Act)
Enforcer: US Department of Housing and Urban Development (HUD) + Department of Justice (DOJ)
Target: Meta Platforms, Inc. (Facebook)
Violation alleged: Facebook's ad-delivery and ad-targeting tools (including 'Special Ad Audience' / Lookalike Audiences) allowed advertisers to exclude users on the basis of protected classes (race, colour, religion, sex, familial status, national origin, disability), and the platform's algorithmic delivery further skewed ad reach.
Lesson: First major US federal settlement holding a platform liable for discriminatory algorithmic delivery under a pre-AI civil-rights statute. DOJ settlement (June 2022) required Meta to develop a new 'Variance Reduction System' to redress racially-skewed ad delivery + sunset the Special Ad Audience tool. Establishes that algorithmic-delivery discrimination — not just user-facing targeting options — is reachable under FHA. Subsequently cited as the template for analogous reasoning under ECOA (lending) and ADEA (employment).
Source: https://www.justice.gov/opa/pr/justice-department-secures-groundbreaking-settlement-agreement-meta-platforms-formerly-knownregulator landing
Editorial scope
This timeline reflects enforcement cases tracked in the Policy Window catalog. It is not exhaustive; coverage focuses on high-precedent matters relevant to the catalogued instruments (currently 13 cases across EU, US, UK, China, India, Italy, France). The catalog deliberately omits routine regulator letters and ongoing investigations whose materials are not public.
For the inclusion rubric (when a case enters the catalog, what level of source-defensibility is required, how jurisdictional balance is managed), see /wiki/methodology. Cases marked “ongoing” remain editorial-watch items; outcomes get backfilled as the public record settles.