The scope and enforcement mechanisms Tong's office will employ remain partially unclear. The memorandum does not identify specific companies or cases, and the full text of the advisory has not been made public. It is unknown whether the OAG plans immediate enforcement actions or will prioritize complaints from consumers and businesses.
Attorneys should monitor this guidance as a signal of state-level enforcement priorities independent of federal action. Tong's memo effectively weaponizes existing statutes—civil rights laws, privacy rules, and consumer protection acts—without waiting for new AI-specific legislation, even as Connecticut's legislature considers dedicated bills like Senate Bill 5 on chatbot regulation. Companies deploying AI in hiring, lending, tenant screening, or advertising should audit their systems for discriminatory outcomes and ensure compliance with CTDPA consent and deletion requirements. The memorandum invites complaints through the state's official portal, suggesting the OAG is prepared to act on reports of AI misuse.