On Jan 14, 2025, the SEC charged Presto Automation with the first public-company AI-washing action. Four enforcement surfaces — SEC, plaintiffs' bar, FTC, and EU AI Act — now scrutinize every public AI claim. The GC's pre-clearance workstream is the answer.

Two-front pressure: 92 SEC comments / 56 companies push toward disclosure; AI-washing enforcement (Presto) punishes overstatement. Six-element Item 1A architecture, four-step pre-clearance workflow, integrated documentary spine.