On February 28, 2024, President Biden signed Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and U.S. Government-Related Data by Countries of Concern” (the EO), under the authority of the International Emergency Economic Powers Act (IEEPA). Among other things, the EO directs the Department of Justice (DOJ) to issue regulations that prevent the large-scale transfer of certain types of “sensitive personal data” to “countries of concern,” including China and Russia. In tandem with the EO, DOJ released an Advance Notice of Proposed Rulemaking (ANPRM) to outline its plan for these regulations.